EASA NPA 2020-15 - Reinventing The Wheel?
Sometimes something happens that changes the way you view the world, or what you had always considered to be “the norm” or normal, and you try to think back to how and where it all started. No, I am not talking about COVID, although that would certainly qualify, sat here in COVID central, the UK, wondering when the next time I will be able to stand at a bar in my village pub drinking a pint of warm British real ale and chatting to the local neighbours.
What I am actually referring to is how we came to be on the verge of the most significant change ever in the way we evaluate and regulate the use of FSTDs in training; we are not just tweaking the process, we have effectively written a whole new one. Let me explain what I mean by this.
Birth of an idea/revolution
30+ years ago, as a young FSTD engineer, I sat in my first Royal Aeronautical Society (RAeS) Flight Simulation Group (FSG) conference in London listening to some well respected key industry guys posturing about the need for an international standard for simulator recognition and evaluation. In those days every conversation on the subject featured only one type of device, the Full Flight simulator (FFS).
Fixed Base Training Devices (FTDs), were only for avionics/maintenance guys to practice their troubleshooting on (right!), Flight Navigation Procedure Trainers (FNPTs) hadn’t even been invented, Microsoft flight sim was in its infancy and virtual reality/artificial intelligence was something you only maybe saw in Star Trek (along with their version of mobile phones and tablet computers with voice recognition). Little did I realise at the time that this conference was the beginning of a 30-year journey along a familiar path to a fork in the road. What is currently manifesting itself in an EASA NPA 2020-15, if adopted, will revolutionise the way we describe, evaluate and use FSTDs in training. At the outset I should say in my view long overdue and for the better.
And so was born, at conclusion of that RAeS FSG conference, the International Working Groups that gave birth to ICAO 9625 Manual of Criteria for the Qualification of FSTDs that set a common standard for FSTD qualification, albeit only for the FFS at the time in 1995. Move the clock forward 10 years to 2005 and, thanks to Dr Ed Cook’s (then of the FAA) prompting, we agreed to update 9625 to reflect all types of FSTD to cover all types of training, both for fixed and rotary wing.
The initial concept (stating the obvious!)
After some initial meetings of the IWG involving up to 100 people, partly to understand what on earth a Multi-crew Pilots Licence (MPL) was at the time and why it was relevant, it was agreed that the key philosophy was to be able to describe training tasks in terms of how much simulation you needed to accomplish the tasks individually or as a group as part of a training type/license. Blindingly obvious really but we actually hadn't done that before had we? We traditionally just built FSTDs and then tried to figure out what we could use them for. Obviously the wrong way round huh?
I fondly remember standing in front of 30 something training experts from the IWG in a hotel meeting room in Toulouse, France and looking at the blank faces staring back at those of us supposed to be chairing this training group. But we persevered and came up with the concept of describing common FSTD features and fidelity levels that in the right combination were needed for any training task or license type. 4 years and thousands of man hours later, the IWG published ICAO 9625 edition 3 that covered all FSTD types.
Now we waited with bated breath for all the world's aviation authorities to pick it up, adopt it or implement it into their national regulations for FSTD qualification and Flight Crew Licensing.
Lack of Adoption
So what happened next? Not a lot if I am honest. One authority CAAS (Singapore) adopted the regulation and implemented it but not, with the benefit of hindsight, in the way it was intended, adopting it for FSTD qualification only and not Flight Crew Licensing.
Over the next 6 years industry was too busy recovering from the financial crisis and building FFS based on increasing demands for predicted pilot shortages, agreeing new UPRT training and FSTD requirements in the aftermath of the Colgan Air flight 3407 accident, etc etc. Unless one of the big two authorities picked it up (FAA/EASA) then it probably wasn’t going to happen, other than for the FFS technical qualification standards being commonly agreed.
A lot of us that had been involved felt frustrated, god knows I did, but maybe the world just wasn’t ready for a system that described how much simulation you needed for training tasks rather than constantly trying to figure out what training could be achieved in regulatory prescribed FSTD specifications, especially for anything that wasn’t a FFS.
A new dawn
And then some events conspired to start to change the way we thought.
An increasing commoditization of FSTD technology saw many new entrants to the TDM market offering FNPT and FTD solutions and even FFS. Their frustration was for their customers to get enough credits for the very capable devices they were offering.
We became more environmentally/economically conscious, train at home if we could, but using what sort of FSTD if I didn’t have access to an FFS? Even more relevant now due to COVID implications that we never foresaw at the time.
Emergence of new VR / AI applications into the world of FSTDs, but how to evaluate and credit them?
New training paradigms like EBT / CBTA / ABLE came to the fore with the focus on developing pilot competencies using a variety of means and technologies.
Suddenly, EASA responded to industry requests for guidance on evaluating new FSTD types and technologies and implementing new training concepts, culminating in various Rule Making Task groups, including RMT.0196 to update FSTD usage and evaluation.
Now EASA has taken a leap of faith and recently published the NPA 2020-15 that effectively inserts ICAO 9625 Part I into Part FCL (for type rating training only initially), and ICAO 9625 Part III into CS FSTD A, and associated impacts into Parts ORA and ARA. Thus was born the concept of the FSTD Capability Signature (FCS) where every training task can be described in terms of a set of commonly agreed FSTD features and fidelity levels required for that training task. The subject of a previous SIM OPS blog.
EASA have shown the overall intent is to enable a better recognition and crediting of existing, as well as emerging, training device/tool capabilities in all FCL- and OPS-related pilot training requirements. Not just for type rating and operator recurrent training but for rotary wing as well as fixed wing.
To quote EASA from the NPA “Without this rule change, FFSs will continue to dominate the training industry, flight training devices (FTDs) will continue to have limited and unstandardised capabilities, and emerging innovative training devices/tools that are tailored to a specific training need will not obtain (deserved) credits for regulatory training.”
The benefits from a training and operations perspective have been beautifully summarised in a recent blog from MPS (Captain Phillip Adrian) that highlights how this supports new technology insertion such as VR/AI.
The NPA itself is also summarised nicely in a YouTube video from Traficom, the Finnish regulator. I strongly suggest you check both these out.
Let’s do this!
There is one more step we haven’t yet taken though… if you appreciate that the FCS links the training tasks directly to FSTD feature fidelity levels then why would we need, eventually, to even have FSTD types and qualification levels ever again, all we need is the FCS. It’s where we are headed when we are ready... but then, Rome wasn't built in a day.
It continues to be a privilege to participate in this process and I salute all the people who have contributed to this effort, especially everyone involved in the IWG and also EASA for pushing ahead now on this. I hope one day the FAA and other authorities will follow so we can have true mutual recognition, but I am not going to hold my breath.
I implore you to comment on the EASA NPA 2020-15 so that we can maintain our progress towards its eventual adoption in 2023.
HOW CAN SIM OPS HELP
The NPA 2020-15 is such a fundamental change to our previous way of thinking that an extensive communication and training process is required to get everyone on the same page. Sim Ops has already developed a 9625 App that simplifies the process of determining the correct FCS for any given training tasks and the corresponding FSTD specification required. Sim Ops is also already helping FSTD OEMs and ATOs to understand the implications and business advantages of getting ready for the eventual adoption of this NPA and why it will revolutionise the way we train and use FSTDs.
Contact us here if you want to find out more.
- Mark Dransfield, January 20th 2021