Hi ZFT
First, let me say that there is nothing you’ve said in your post (above) that I would disagree with – in fact there are some things you said with which I would agree, and others with which I would stand-up, IN the chair, punching the air, in agreement.
Of course you are correct with respect to a contracting user of a simulator belonging to someone else – and having that contracting user be able to find out ALL of the “nitty gritty” nastiness that may be found in the bowels of a particular simulator … very likely to NOT happen.
Please understand, I would advocate the very best of fidelity and the most accurate replication of the airplane in any simulator. And after the US regulations were initially written and there was a concerted effort to prescribe a more detailed and accurate replication of a simulated airplane there was the elephant in the room. That elephant was the already qualified, approved, and long-used simulators that wouldn’t have a prayer of meeting the newly developed requirements, without substantial expenditure of additional funds. It seemed illogical to conclude that simply because a device was more than a few years old, it no longer would be accepted the way it had been accepted. However, I think it is necessary to understand that the logic was not so much addressing those older devices as it was the precedence that would likely be set with such a determination. If the older simulators were to be relegated to some lesser capability (say, something like a “procedure trainer”) who would be able to say that the newly modern simulators bursting onto the scene with the newly developed 6-axis motion systems, stereophonic surround-sound, computer generated visuals with back-projected, front reflective view through (now) up to well over 180 degrees of uninterrupted view, might someday, be relegated to the same “procedure trainer” future when the next advancement in simulation becomes apparent? That was the potential facing the older 3-axis motion, CRT visual, and (well, mediocre) sound systems equipped simulators that were “new” a couple of years, perhaps a decade, earlier. So, the problem that had to be faced was how a regulatory requirement could be used to govern simulation standards and be found to be worthless at some unnamed time in the future … and perhaps a not-distant future. Who would want to invest – particularly invest the cost of one of these new devices – when there was even a possibility that in the some-time future, it might become essentially worthless? How does an industry encourage the expenditure of significant amounts of money when there is no guarantee that those funds will soon be seen to have been essentially lost? The solution – perhaps not the best solution – but the only solution deemed capable of making sense – was to “grandfather” existing simulators – allowing those devices to continue to meet the existing standards and continue to enjoy their currently authorized use. The fact that these now older simulators were not “zero flight time” simulators made this not only a logical premise, but one that would not compromise the expanded capabilities that these newly described simulators were capable of meeting. The historically “modern” simulators, originally known as “visual simulators” became what is now known as Level A or Level B. But it should be noted that to be designated a Level B simulator, that simulator had to be modified with additional landing data, gathered from airplane flight testing conducted well within ground effect and use modified computer programming for that new data. The Level A would be allowed to satisfy recurrent proficiency checks, as long as a check airman was to observe a landing on the line within an established time frame of the simulator check. The Level B, with the addition of the landing data, could be used to satisfy the recurrent proficiency check, including the landings required. The other two levels of simulator, Level C and Level D, each had requirements that included the advanced 6-axis motion systems, visual systems with wider fields-of-view, and additional sound requirements. The requirements for the Level C were not as specific nor quite as advanced as the Level D simulator, but Level C was authorized for “zero flight time training” only for those individuals who had rather extensive experience – and that experience was specifically outlined in the newly published regulations.
So … the concerns that you described are quite real – but it was at least attempted to be addressed in what requirements had to be met for each of the newly described 4 levels of full flight simulator. Of course, there remains a lot of issues that we all would like to see have a method of addressing. Not the least of which are individual issues with some (really any) individual simulator. Any user not employed by the owner/operator of the simulator may not be made knowledgeable of the specific short-comings of any particular device. The only way I know to deal with those kinds of problems is to have the instructor using that simulator be as knowledgeable about the simulator as is allowed by the owner/operator AND to be sure that the instructor has substantial experience in the airplane (being represented by the simulator) so that if the simulator demonstrates an anomaly not present in the airplane, the instructor will be knowledgeable as to the following: 1) whether or not that anomaly should be written up in the simulator log – and whether or not that log entry should include information about the known airplane response; and 2) whether or not it would be necessary or appropriate to point out that anomaly to the student being trained, and if it were appropriate, to know how to describe both that simulator anomaly and the correct airplane response, leading to instruction as to how the student would be expected to address that airplane response.
I think that regulatory authorities have a responsibility to ensure that the parameters of simulator operation are appropriate and fairly applied. But by the same measure, those authorities should not necessarily see a requirement to “move the goal” simply because technology improves. There is nothing wrong with expanding the technical capabilities of existing simulators, and most regulatory authorities do have methodologies in place to ensure the competence of pilots licensed by that authority, and when or if it becomes appropriate those authorities should use the existing process to alter the training requirements for pilots to ensure their individual competence … and if that means adjusting simulator qualification criteria, at least that process would ensure fair and equitable requirements are levied on both the pilots and the training mechanisms used to meet those requirements.