I suspect that is because there was “a lot” of discussion about what was going to be required of simulators to be able to comply with the kinds of training that was going to be mandated after the huge effort that was mounted by the relatives of the Colgan accident victims and had the US Congress pretty much dictate the kind of rule that the FAA was going to have to institute. The specifics that were included in that Congressional mandate was training on Full Stall Training Maneuvers, Upset Recognition and Recovery Training Maneuvers, Airborne Icing Training Maneuvers, Microburst and Windshear Recovery Maneuvers, Takeoff and Landing in Gusting Crosswinds, and Bounced Landing Training Maneuvers, all of which were to be fully addressed in airplane flight simulators.
Because of the fact that the training that is going to be required, is going to be required to be conducted in an airplane flight simulator, the FAA has to make sure that when the simulator is used, it has been programmed for, and tested to ensure, that it is able to be used for the newly prescribed tasks to train and test pilots – who will be required to be knowledgeable about how to recognize and, where necessary, recover from any of these kinds of occurrences.
The logic they are using for this program is based on the potential of inadequate fidelity of any FSTD used to conduct such training that could then lead to a misunderstanding of recognition cues, learning of inappropriate recovery techniques, and an unrealistic understanding, or a lack of understanding of dangerous flight conditions that must be avoided – and actually, this specific kind of “look” at any simulator, is exactly the kind of thing some of us have been advocating for quite a while. As a result, the additions to simulators described by the FAA, and after proper evaluation of those FSTDs that have been modified (and I understand that this will include those previously qualified FSTDs that hold “grandfather rights”) must be used to conduct these training tasks.
Apparently, according to what they’ve said, the plan that the FAA is going to follow is designed to keep the “cost” of modifying both new and previously qualified FSTDs to a minimum, and to do this, they have proposed to apply the requirements of this FSTD Directive ONLY to those FSTDs that would be used to accomplish specific training tasks as described in that FSTD Directive. This would allow the sponsors to choose to qualify any number of FSTDs to conduct the individual tasks as required to meet the needs of their training programs. Again, according to the FAA, those FSTDs that have included these necessary modifications in accordance with the FSTD Directive would have their Statements of Qualification modified to indicate the FSTD has been evaluated and qualified specifically for those specific tasks.
The concept of a Flight Simulation Training Device (FSTD) Directive (similar to an “AD” – Airworthiness Directive) is to ensure that the simulator that is to be used for this kind of training or testing has been modified to be able to be used properly for those specific applications. The FSTD Directive is not a “new” way to get a simulator evaluated or qualified, but rather is a way to address the specific kinds of capabilities in any specific simulator that is to be used to conduct a specifically designated training/testing application.
So … essentially, we have some enraged family members pounding the tables at the governmental/congressional level – someone puts together something that sounds like it might be appropriate to do – and the regulatory authority is saddled with the responsibility of putting it all together and making it work. It will be interesting to see how it all turns out.