By Alexander Schaffler With no comments

Is the NPA 2020-15 the approach to new FSTD regulations a curse or a blessing?

No matter what we or you conclude after reading the NPA 2020-15, please take your time and read it for yourself and use EASAs CRT-Comment Response Tool to provide your own opinions, hints on problems and improvements. You can also check out our initial reference article NPA 2020-15: Adoption of new EASA FSTD Standards – Comment now!.

As of last week EASA has extended the period for commenting on the NPA so deadline in March 31st has been pushed further ahead so there is time for at least another 30 days.

Flight Simulator Traders view on the NPA

As we ourselves come from a simulator manufacturers background and have been doing sales, services, FSTD compliance and approvals for over 14 years now, we would like to take the opportunity to add our summarised view on the new NPA 2020-15. We might of course have a limited view point and that is why we encourage you to comment and improve the new regulation.

Pro NPA 2020-15

We like the approach to improve FSTD standards and update current regulation. I have to say that this has always been a problem handling a regulatory frame work that has been lagging behind and had gaps for certain topics and did not provide as much guidance for the Civil Aviation Authorities. I also see, that technology in flight simulation has strongly evolved since I started in 2007 and the ever ongoing acceleration in development will be difficult to cope with.

The step into merging ICAO Document 9625 into the new regulation is a great step with regards to further harmonisation and standardisation in Aviation. The need for a right guidance for interpretation of fidelity and crediting of flight training cannot be any higher and will still have to be improved. Introducing Fidelity Capability Signature (FCS) and a detailed Equipment Specification List (ESL) would be, if executed well, a great step forward to simplify the process of assessing a device for training. It is a good approach seeing a FSTD fidelity from a technical and a training standpoint and we recently have been exercising this for a project.

The further clarification of PART-ORA is mostly good, especially guidance for defining N, G, R, S FSTD Features.

Contra NPA 2020-15

Unfortunately, there are quite a number of points which are yet very immature. The idea is great, but the execution is weak in its current state and thus again please visit EASA website and use Comment Response Tool to help improving this. It is on you to improve this regulation.

We have recently exercised a project for a client looking into acquisition of a FTD2 (Issue 2)/ FTD B (Issue 3). Our intention/ our hope was  you may have more credits and training with a lower fidelity device but to say it upfront, it has not played out as we had hoped. It would be interesting to explore options for generic and FNPT devices to actually get higher recognition in training as they always improve their fidelity with the quick advancement of technology. We see this as procedure trainers and FNPTs and even non qualified devices nowadays  being used to reduce time on FFS but it would be great if FNPT devices could more be used in Type rating training as well, not only as OTD rather than actual devices providing more credit which is currently reserved for FTD1/FTD2 devices. This is what we had hoped for and have been discouraged. It seems the regulation has merely the intention to offload time from FFS into FTD2s rather than other FSTD of all levels as a whole.

The exercise, once you have a type specific cockpit and systems for 320/737 etc., does not play out as the requirements for Flight Modelling and Visual Systems are so high with the new regulation, that a potentially great device with a FCS (S R (Flight Model) R/G (Ground Model) S R G R G S G R will practically lacking a lot of usability in this system. Also generic devices that do not represent any particular aircraft I see having greater disadvantages where they could actually make much more use. A consideration of current Procedure Trainers (FTD1) is not recognisable at all in this system. The devices in the industry which make up the a big part of FSTDs in the industry (this is FFS as well as FNPTs) get left behind and here I do not see a true improvement towards the upside. But this is important if you want to improve the industry all-over and give sim time more significance, especially for safety.

Summarised, there are some major points really creating a lot of hassle in the new regulation, which are;

  • FSTD Matrix System together with Training Matrix is insufficiently detailed if you are not familiar with ICAO Doc 9625. Then if you apply the Matrix and hope for applicability of lower level devices you see mostly in Type Rating you always have to be “Specific.” FNPTs, Procedure Trainers and other lower level devices although posing the second biggest group in aviation training aside from FFS, will face difficult times ahead as upgradeability will be impossible or will have to be done at unreasonably high cost.
  • The new FSTD classification is misleading and basis for future conflicts. First FCS items R for certain trainers such as Procedure Trainers and Generic Devices are insufficiently represented and/ or recognised. The FFS Level(s) we think still makes sense to have FNPT Level E changed into FFS Level B, or use the FAA FSTD classification for future harmonisation.
  • The FSTD qualification requirements for Flight Modelling and Visual Systems are suddenly lifted in huge increments and then in most columns S and R requirements are combined in one, causing 2 major problems. One is, CAAs will always apply what is written and take higher requirements and secondly current FSTDs that seek FCS upgrading will not comply and upgrade cost will be in no relation. Ergo, the FNPT requirements would increase to FTD levels in general. Even for R requirements the new regulation is quite demanding putting it into question if this serves the industry.
  • There are many small items we comment in detail in the following text below that have to be explained, changed or referenced.

The NPA has been started with a great intention and then is poorly executed in certain parts. We encourage you to use EASA Comment Response Tool (CRT) in order to provide your own comments. If you have any hints and clues for us would also be welcomed.

Best regards

Alexander Schaffler

Flight Simulator Trader

FST detailed findings and conclusions inside the NPA 2020-15

In the following, we have commented on each point we raised in order to give some hints and clues and food for thought. You are invited to let us know your thoughts.

  • FCS & Grandfathering: Although the second hand market is not big I still think some operators will have a lot of problems, especially when they want to update the FCS and want to leave their grandfathering behind. Alth0ugh I share that new technology should be developed and old devices sitting for about 20 years in the market are removed, I guess you will limit the operators and manufacturers too much.

2.3.5. Update of CS-FSTD(A)

“Furthermore, CS-FSTD(A) creates a conversion table in CS FSTD(A).QB.101, ‘FSTD capability signature (FCS) summary matrix’, which links new FSTD types/levels and FCSs. It is possible of course that a FSTD may have a valid FCS that does not match a particular type/level combination. The types/levels are representative of the most common FCS combinations expected to provide the most benefit for use in different types of training (as specified in ICAO Doc 9625 Volume I Part I). Consequently, the mention of FSTD types and levels and type of training/licence is systematically replaced by ‘features and fidelity levels’.”

  • Just more confusion, we tried to match an FCS with a training requirement with Flight modelling R on a type specific device and tried to even have a selection of training tasks to perform but that does not work. I just see that this is clear for black and white choices but we have so many FSTDs that do not belong to a category. If you state there is a true benefit to do training on lower fidelity I think the matrix is failing. Think of Part-FCL and FTD/ OTD references. What about the OTDs? This is really not something that has been clarified in the matrix.

2.4. What are the expected benefits and drawbacks of the proposals

“The proposal for having FSTDs tailored to training needs is cost-effective and instils transformation of the system by applying an innovative approach that corresponds with ICAO provisions, and introduces this paradigm shift into the regulatory framework for initial (FCL) and recurrent (OPS) pilot training. The EU would be among the first globally in utilising the innovative possibilities provided by this latest revision of ICAO Doc 9625. The proposal strives for integrating flexibility in using the devices according to their actual capabilities and paving the way for further innovations when designing and producing new FSTDs.”

  • I see absolutely no change for Recurrent or initial TR. If you really think you can do training on lower level devices then the training matrix/ ICAO should provide more freedom when it comes to Flight Modelling and ground modelling as well as visual system requirements. Then you will have a true benefit and reduced cost for training. If you then have certain minimum requirements that are a bit higher fine. But for now you just change nothing. The jump from current FTD2 into FTD Level B from a visual and flight model perspective is huge. I´d give this more consideration and losen some of the requirements knowing that simulation technology actually is improving quickly.

“GM1 FCL.010 Definitions”

  • First, why is there no complete matrix for all current levels? Are you sure about the levels? why putting fnpti for ir when training is done on fnptii on that level and we do not see fnpti in the industry, or very rarely as well as BITDs. Why are you not trying to get closer to FAA simulator / ICAO Simulator types? For future harmonisation makes sense.Then the term FNPT Level D, being in sim sales for 14 years, I can tell you will get a lot of people confused with FFS Level D. Why not introduce Level 1-5 as more FAA? Then FNPT Level E. Please stop as this is misleading. A lot of people will come and try to get their Redbirds or C172 on motions as Level E qualified which is not manageable. As E Level is the former FFS Level B, I strongly suggest to either open a new category or push this into FFS category.

“AMC3 to Appendix 9 Training, skill test and proficiency check for MPL, ATPL, type and class ratings, and proficiency check for IRs”

  • We studied this matrix on an actual project for a CS25 aircraft FTD2/ FTD B. I have to say first is confusing as there is no reference to ICAO 9625 4th edition where these training tasks are better explained. Secondly, for the ordinary user is not clear on how to use their syllabus with this matrix. The training tasks are too general, so what is your intention here? More flexibility or more CAA confusion when it comes to crediting? this needs more explanation.
  • Also, we have tested this with the project to find possibilities for training on lower level devices. Actually, this might only work for FFS and FTD B but still is not working so well. If you rather look into going alternative ways for lower cost training and do some type rating on OTD, FNPT, FTD A/ B we have not found this approach so much of an improvement. We think the only benefit will be transitioning from FTD B to FFS and vice versa.

“AMC1 ARA.FSTD.100(b) Initial evaluation procedure”

  • The reduction of Finding Levels for FSTD: What I fear is that in future even comments or recommendations will be listed under B and then cause update/ upgrade troubles for operators in the future. I suggest to leave comment and recommendation for improvement section active.Then Level A and Level B…good god guys, you have Compliance 1 and 2 level, you have FNPT Level A to E and now you habe Level A and B…please do not confuse people. Use same classifications when you change them….

AMC2 ORA.ATO.125 Training programme

“Flight simulation training devices (FSTDs)
A type rating course for a multi-pilot aeroplane should include FSTD training.
The amount of training required when using FSTDs will depend on the complexity of the aeroplane concerned, and to some extent on the previous experience of the pilot. Except for those courses giving credit for previous experience (c.2.), a minimum of 32 hours of FSTD training should be programmed for a crew of a multipilot aeroplane, of which at least 16 hours should be in an FFS operating as a crew. FFS time may be reduced if the training objectives can be achieved by other type-specific FSTDs having the required FSTD capability signature (FCS).”

Here with the new requirements and inapplicability of the current FNPTs when they look type specific but are of generic nature, these will get left behind or upgrade cost will be in no reasonable cost -benefit ratio.

AMC1 ORA.FSTD.105(a)(1) Maintaining the FSTD qualification

  • can you specify does that mean they need to be closed or can this mean informing about a CAP?
  • some changes might need longer. Is this covered?

GM1 2 ORA.FSTD.200 Application for FSTD qualification

  • although footprinting guidance is for type specific FSTD only, a generic approach will be welcome to also facilitate easier FNPT qualifications
  • It would be good to reconsider generic devices as well to ensure

GM2 ORA.FSTD.210(a)(3) Qualification basis

  • I see potential conflict here. Also I am puzzled as you add this section to make it easier and then for the fidelity levels you make the requirements higher and an actual use of lower level devices in training we do not see in this NPA.

CS FSTD(A).GEN.005 Terminology: Term “Correct Trend and Magnitude CT&M)

  • We suggest to give a guideline for CT&M as this is still highly subjective

CS FSTD(A).QB.101 FSTD levels and FCS

  • again will raise a lot of problems as there will be a lot of people wanting to qualify their FNPT on motion and visual systems to Level E simply because they think it is on a motion base. The term S for ATC will cause a lot of people to not comply with this requirement simply because Collimated and ATC systems are quite high in cost. The question is if you possibly rethink, open another category or change this into R. I see this a big problem losing money for the ATOs and time for the CAAs to reduce fidelity levels on motion.
    Something is just not right here. I suggest clarification or explanation for this item.
  • Looking at the requirements for objective tests, visual cues R with ICAO lower level think that might cause trouble. You need to rework the objective test classification
  • Looking at the requirements for objective tests, visual cues R with ICAO lower level think that might cause trouble. You need to rework the objective test classification
  • FNPT Level E People will try to qualify their Redbird and C172 on motion to Level E, when this is indeed a FFS Level B requirement. I suggest to classify this Level E to FFS Level.
  • Option would be to integrate a former EASA terms for FSTDs in this matrix for clarity. Also lower fidelity as per EASA seems always lower D vs C and A vs B.

CS FSTD(A).QB.110 FSTD general requirements for feature fidelity levels

  • I will summarise this for a couple of points as this is a general problem throughout the table: We find for a lot of items that requirements R and S are in the same column and thus have the same requirement. We suggest to have this broken down as authorities will refer to it has to be the exact same seats. Please provide extra listing for 1.2.1.S/R
  • 1.3 G: would suggest to add …and are not irritating or eye-blinding. We often find this in FSTDs that are of lower quality and encourage this to be improved
  • 2.1.S.c Just a hint or question, does this always have to be actual flight test data or can this be wind tunnel or engineering data if validated? We find more guidance later in the document but still this point should be addressed in more detail.
  • 4.G Aeroplane Systems/ Reserved: A hint, special systems like CPDLC on lower level devices and other fitted systems more guidance appreciated
  • 4.2.S/R: This is misleading, meaning fitted on the Aircraft I assume? Or refers back to electronically simulated as well? Please provide more detail.
  • 4.4.R question: As also MCC portions could be delivered on CS 23 aircraft e.g. Business Jets/ Turboprop etc. wouldn´t it make sense to also add something here. I assume this could lead to problems for CS23 FSTDs which are being used for MCC as well.
  • 6.3.S/R Suggest to split up S and R requirements for interpretation reasons and be more specific as not all simulators have precipitation sounds for example. Encourage to be more detailed here and split in order to avoid unnecessary high cost for visual systems. This is quite a jump from current Issue to the new issue.
  • 6.5.R/S: I also suggest splitting this up as for R devices the CAAs might have too high standards. Also difficult for generic devices when it comes to directional when there is no real flight deck matching to a an aircraft A320 or B737 for example.
  • 7.S: question infinity= collimated if yes fine, if this leaves certain room for engineering developments maybe you can clarify or put more details.
  • 7.1.1.R: just a hint, might cause compliance problems for a lot of systems of lower fidelity when trying to update. Not sure if this makes sense for the 10 degrees as there are manifold systems with different geometries for lower level devices. This might cause problems for compact systems.
  • 7.1.4.S/R: suggest to open a new category for each part
  • 7.1.6.S/.R suggest to open a new category and decouple
  • 8.1.S.a /8.1.R.a: suggest to open a separate category as might cause CAAs to have too high expectations. Also there is the wording representative and specific in the text that does might not work as Motion Systems per se are representative and truly specific motion systems if they exist like Desdemona e.g. are rare. With the new categories for FFS and FNPT Level E which I had also highlighted as not working earlier I guess this means more confusion.
  • 8.4.R just a comment: just a comment as this shows that you require higher fidelity, this comes back to FNPT Level E and people thinking they can qualify their devices on simple motion to E for a C172 when this is truly for FFS Level B EASA under Issue 2.
  • 10.1.S: “For non-type-specific devices, the navigation database should be current within a period not exceeding 3 months where navigation equipment is replicated.” What does this mean. If I have the actual/ original Garmin for example in there is shorter? Please clarify. This is usually clear but as the paragraph above states AIRAC cycles for type-specific devices, I think this point should be checked. As S for specific could also mean FTD/ FFS type devices I am not sure this will work with 3 months cycles.
  • 11.R: suggest to split up as S and R most R models will not display microbursts as it now under Issue 2. Lower level devices or grandfathered FSTDs will have significant troubles.
  • 11.2.R see 11.R
  • 11.3.R: I fear these requirements are too high for lower level devices and there should be a solution that has more requirements and lower, see in cloud air speed effect.
  • 12.1.1.R: explain detailed, what is meant by accurate surface depiction? I find this very subjective. We are in times of satellite imagery with clear resolution requirements for texture and Digital Elevation models, yet most inspectors don´t understand this well. And again when you put a requirement this high you will sort out all low level FNPTs that make up most of the devices in the industry aside from the FFS. Split up the categories and find an accurate bridge gap.
  • 12.4.2.R: Generally I find requirements to high…I suggest splitting up for higher and lower level devices. G and R is so far off with ICAO requirements you will run into trouble.

CS FSTD(A).QB.115 General technical requirements for FSTD qualification levels, Table 6: General technical requirements for FNPT Level C

  • “This level of FNPT is analogous to ICAO Doc 9625 Type III to support training in approved courses for class ratings and MCC.” Not sure if MCC and class rating…maybe make this clear SEP?, MEP?, MEJ? SET?

CS FSTD(A).QTG.105 Table of FSTD validation tests versus feature fidelity levels

  • 1.c.1: “Flight test data is preferred; however, aeroplane performance manual data is an acceptable alternative.” Again I have to say that mixing R S column in combination with Flight Test data preferred will shake out the generic/ representative device categories. This needs to be improved. Split up the categories and diversify on flight test data (this should be validation data to illustrate that any form of suitable data can be used). CAAs will apply wording as is causing a lot of conflict.
  • 1.c.2: see 1.c.1 regarding Flight Test data and category split
  • 1.d.1 : see combination S and R in one column always problematic. Unless you refer to FNPT Level E but this is also misleading and needs clarification.
  • 2.a.1: “Uninterrupted control sweep to stops. Test results should be validated from in-flight data from tests such as longitudinal static stability, stalls, etc.” In-flight data? for R? Split categories and also specify inf-flight (during flight?) flight test data? validation data. Sorry might be stupid but just thoughts of a non-native speaker.
  • 2.a.2 : Split up S and R in separate categories: as R is also representative of a class I think thsi will lead to a lot of problems and misunderstandings
  • 2.a.3: “Uninterrupted control sweep to stops. Test results should be validated with in flight data from tests such as engine out trims, steady state sideslips, etc.” Does this mean in flight data during flight or flight test dat or validation data in general. Why in flight when the Flight Condition is highlighted as “Ground”?
  • 2.a.7: “Trim rate to be checked at pilot primary induced trim rate (ground) and autopilot or pilot primary trim rate in flight at go-around flight conditions.” analogue to 2.a.3.
  • 2.a.8 “Simultaneous recording for all engines. The tolerances apply against the aeroplane data. For aeroplanes with throttle detents, all detents to be presented and at least one position between detents/endpoints (where practical). For aeroplanes without detents, end points and at least three other positions are to be presented. Data from a test aeroplane or engineering test bench is acceptable, provided that the correct engine controller (both hardware and software) is used.” Are you sure you should have this in one column together wirh G and R and refer to aeroplane data when this is overkill and misleading? Data from a test aeroplane….well why not call it validation data and see where the appropriate source is coming from, wind tunnel, footprinting, engineering data….
  • 2.a.9 “± 2.2 daN (5 lb) ,or ± 10 % of force” for break pedal, I would not recommend to take this for R and generally kick this requirement out.
  • 2.c.1 “OR for fidelity level G Power change force ± 2.2 daN (5 lb),or ± 20 % pitch controller force”. I find this a strange requirement when you think in General G devices will probably not have any force feedback system, might be spring loaded .
  • 2.c.2 analogue to 2.c.1
  • 2.c.4 analogue to 2.c.1 and 2.c.2
  • 2.c.6
  • 2.d.4 “Aeroplane data averaged from multiple tests may be used. Test for both directions” Why not validation data and then have subsections for G, R, S with clearer explanations?
  • 2.d.7: General comment/ question: as there are a number of generic devices with no real dutch roll behaviour but is not relevant for training maybe you can find a subclassification for this.
  • 3 all following subpoints R and S in one column. again I see a problem with customers thinking a R Motion system is a low fidelity Motion system you find in the entertainment world knowing a current FFS Level B is what this means.
  • 4.a.1.b “Field of view should be measured using a visual test pattern filling the entire visual scene (all channels) consisting of a matrix of black and white 5 squares.” why this pattern? could be also another means of compliance. Suggest to make this requirement wider and leave room for demonstration.
  • 4.a.5: spilt up categories for G, R, S and give room for compliance instead of mixing all up in one requirement for all which is difficult to meet.
  • 4.a.7: “Light points should be displayed as a matrix creating a square. On calligraphic systems, the light points should just merge. If projectors using solid-state illuminators are employed, refer to CS FSTD(A).QTG.240.” I feel these requirements have been set to shake out lower level visual systems. Please take steps away from telling people how to do it rather than telling about the requirement and giving them room for demonstration.
  • 4.d.1: “For non-type specific ‘Flight Deck Layout and Structure’, an appropriate cut-off angle representative of the class of aeroplane should be used. Otherwise, a value of 15 degrees is assumed to be acceptable.” Suggest to have a range between 10 to 15 degrees as a range seeing this is a typical range for the devices we have qualified.
  • 4.e.1: split up categories for R and S and have less string requirements for lower visual systems
  • 5.a: “For sound feature fidelity levels R and S: All tests in this section should be presented using an unweighted 1/3-octave band format from band 17 to 42 (50 Hz to 16 kHz). A minimum 20 s average should be taken at the location corresponding to the reference data set.” I suggest to step away from these sound requirements for G and R levels as too strong.
  • 5.a.1 “Initial evaluation: subjective assessment of measured overall SPL. Recurrent evaluation: ± 3 dB SPL RMS compared to initial evaluation.” I see this not useful for requirements for G levels
  • 5.b “PROPELLER AEROPLANES For sound feature fidelity level G: All tests in this section may be presented as a single overall SPL level and are only required when the cockpit is fully or partially enclosed (e.g. installed in a dedicated room).
    For sound feature fidelity levels R and S: All tests in this section should be presented using an unweighted 1/3-octave band format from band 17 to 42 (50 Hz to 16 kHz). A minimum 20 s average should be taken at the location corresponding to the reference data set.” This will cause a lot of problems and is in no cost benefit ratio for lower level devices. Again R and S requirements combined means potential conflict.
  • 5.d FSTD Background noise: Why for R unless is a FFS Level B which in this document is still unclear with the FNPT Levels (E). This is colliding with the ICAO Doc 9625 Simulator Matrix. As for the current matrix this would concern a lot of low level devices.
  • 5.e Frequency Response: I see this only for specific requirements, R is not useful.
  • 6.a.1: Transport Delay: the delay times especially for G and R are to be discussed. Why isn´t 300ms enough?

GM1 CS FSTD(A).QTG.105 Table of FSTD validation tests versus feature fidelity levels

“(c) Incompatible FSTD features and fidelities”

“Flight model – S, ground handling – S, aeroplane systems – S, flight controls and forces – S Note however that this also then changes the FCS and thus the potential training credits as indicated in the relevant parts of the regulation where an FCS is specified for a training task or tasks.

As stating above that simulation has tremendously improved, we do not see a true benefit for lower level”

  • This is where you have to provide a wider range of options . This is the problem as you will create a huge gap instead of bringing device requirements closer together.

GM2 CS FSTD(A).QTG.105 Table of FSTD validation tests versus feature fidelity levels


(a) Background (1) The tolerances listed in CS FSTD(A).QTG.105 are designed to be a measure of quality of match using flight test data as a reference.”

  • Why flight test data? Please specify other data or call it validation data to open a wider range of possibilities.

“(6) Any differences between FSTD results and engineering simulation validation data should, however, be small and the reasons for any differences, other than those listed above, should be clearly explained.”

  • What means small, please be more specific.

“(8) The current increase in the use and projected use of engineering simulation validation data is an important issue because: (i) flight test data is often not available due to sound technical reasons; (ii) alternative technical solutions are being advanced; and (iii) cost is an ever-present consideration.”

  • We need more guidance here in general.

“(b) Non-flight test tolerances (1) Where engineering simulation validation data or other non-flight test data is used as an allowable form of reference validation data for the objective tests listed in the table of FSTD validation tests versus feature fidelity levels in CS FSTD(A).QTG.105, the match obtained between the reference data and the FSTD results should be very close. It is not possible to define a precise set of tolerances as the reasons for reaching other than an exact match will vary depending upon a number of factors discussed in point (a) of this GM.”

This is a problem in general as we have these CT&M discussions. So either give a guidance please as this is highly subjective with CAAs.

“CS FSTD(A).QTG.120 Engineering simulator validation data

(b) To be qualified to supply engineering simulator validation data, an aeroplane manufacturer should: (1) have a proven track record of developing successful data packages; (2) have demonstrated high-quality prediction methods through comparisons of predicted and flight test validated data;”

  • We are missing an approach for generic data packages or a reference to a part of the document where this is explained.

CS FSTD(A).QTG.235 Frequency domain motion cueing system performance test

(c) Image geometry Figure 9: Relative geometry test pattern showing zones

  • If you add such a pattern and requirement still the question remains is this for G, R or S a requirement or for all. What I see is the problem with less guidance for CAA applying higher standards to a lower fidelity devices.

CS FSTD(A).QTG.410 Applicability of CS-FSTD amendments to FSTD data packages for existing aeroplanes

  • Please add a section for generic data packages for lower level devices as this point is insufficiently covered

“Except where specifically indicated otherwise in CS FSTD(A).QTG.105, validation data for qualification test guide (QTG) objective tests is expected to be derived from aeroplane flight testing.”

  • No this is wrong wording in our eyes, can be all data from Engineering data, to wind tunnel data, etc. Why you say specifically flight testing…this is misleading. Say Validation data!

CS FSTD(A).FST.105 Table of function and subjective tests

  • where is the applicability as you have shown in the objective tests? It How to distinguish requirements for N, G,R,S? Or is this now for every sim? Then why applicability? I think this is not straight forward.

CS FSTD(A).MISC.020 Design and qualification of non-type-specific FSTDs

“Unlike type-specific FSTDs, non-type-specific FSTDs are intended to be representative of a group or class of aeroplane. The expression ‘non-type-specific’ has been used in place of ‘generic’ to preclude confusion with the simulation feature fidelity level G. It further reduces the implication that non-type-specific FSTDs are exclusively linked to simulation feature fidelity level G as they could include R or even S fidelity levels for some features. Fidelity level S could apply to one or more of the FSTD features for the aeroplane type relevant to the training programme, or to another type in the same group or class. The principles given in this CS are applicable to devices with fidelity level”

  • This is important as in the G R S Matrix of the objective validation data this is not clear. Ergo, we need a better definition especially for lower fidelity devices.

(2) Cockpit/flight deck components

“As with any training device, the components used within the cockpit/flight deck area do not need to be aeroplane parts: however, any parts used should be representative of typical training aeroplanes and should be robust enough to endure the training tasks. With the current state of technology, the use of simple flat display technology-based representations and touch-screen controls to represent objects other than basic push-button types of controls (e.g. rotary control knobs for setting barometric pressure or speed bugs) would not be acceptable. The training tasks envisaged for non-type-specific FSTDs are such that appropriate layout and feel is very important; for instance, the altimeter sub-scale knob needs to be physically located where it is in the represented class of aeroplane either equipped with glass cockpit avionics or classic instruments. With the use of flat display technologies, physical overlays incorporating operational switches/knobs/buttons replicating an aeroplane instrument panel may be required as described in CS FSTD(A).QTG.400, Table 1.”

  • We would just add….if flat screen technology is being used on the actual aircraft class this might be exempted….there are more touch screen systems now.

(3) Data package

  • I recommend to get this point relocated or a reference in the validation data section as this is important and the number of generic devices is high. Ergo, there should be more stress on such devices and a careful dealing.


We encourage you to use EASA Comment Response Tool (CRT) in order to provide your own comments. If you have any hints and clues for us would also be welcomed.

Best regards

Alexander Schaffler

Flight Simulator Trader

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Posted: March 10, 2021