Simulator Training for strong crosswind landings

[AirRabbit]

As I sometimes do, I’ve just gone back and re-read what I posted not long ago – but it became apparent that, because of the somewhat narrow focus of the topic of this thread and the even more narrow focus of that particular post, I did not point out at least some one of the major concerns that I believe remain real and important.

The FAA has, indeed, published a proposal to expand the areas from which data will be required to more accurately and more completely program simulators, and has done so with the understanding that this data will be incorporated into the simulator to more accurately simulate the performance and handling of the airplane when subjected to the environments and circumstances where this “new” data would be representative (see the above posts). And, while this is very likely to be advantageous to being able to provide an even higher capability of “realism” in a simulated environment, there remains a glaring disconnect that has not yet been addressed. That “disconnect” is the determined effort on the part of some who continue to desire to redefine the features that are, and should be, required to be provided in an accurate and complete (as complete as physics will allow) airplane flight simulator.

Some “history”… observed by some outsiders and, likely, many more insiders, may be in order:

It is apparent that the current practice of allowing some training program applicants to be granted the use of “non-motion” devices on a case-by-case basis, under the provisions of an “alternate” training program development process, commonly referred to in the US as the Advanced Qualification Program, or “AQP,” will continue to be used. I am fully aware that those who have adopted AQP as a training philosophy do not automatically incorporate the use of non-motion simulators, and not all AQP training programs use non-motion simulators – but the fact is that some do. And, that fact, at least to me, flies in the face of realism and accuracy – which, should generate some level of concern on the part of the management of this particular regulatory authority – particularly when they are quite actively insistent that we modify the requirements for the inclusion of these new data driven training applications.

The operation of the AQP office in the FAA was seen for quite a while as the venue for very highly educated and very capable professional educators. As a result, none of the proposals for how they desired to “do their business,” regardless of how odd those proposals may have seemed, and regardless of what other, less educated pilot inspectors may have said in opposition, the positions taken by the AQP office was considered “forward thinking” and a “pathway into the future.” As a result, none, or very few, of the AQP positions were ever challenged, at least not successfully. Behind the scenes, there was an attitude that the need for motion systems, and their associated costs (purchase and maintenance), could be eliminated without compromising the quality of airline pilots being trained.

For some time, at least initially, most of the managers and most of the staff within the AQP office were not pilots, but rather educators (some with exceptionally fine resumes) who were not familiar with (…and I’m resisting saying “and oblivious to”…) the various inputs and perceptions pilots regularly use to fly an airplane. These inputs, provided through motion, visual, and/or feel cueing, when operating an airplane, either on the ground or airborne provide the pilot with an indication of what is happening and what he/she do to maintain – or regain, if necessary – the desired flight condition. Some of these AQP “non-pilots” adamantly stood on the premise that they, themselves, had personally seen pilots perform in simulation equipment, both with and without motion, and were convinced that what they saw was virtually identical performances in each – justifying, in their minds, that motion systems were irrelevant to competent and complete pilot training.

It didn’t take long before, there, in the isolation that was, and still remains, the AQP venue, that attitude eventually became “uncontested fact” – fact that had been verified by professional educators – motion systems were, indeed, irrelevant. There is little doubt that an AQP approval can include the authorization for the completion of pilot training, and the final “line oriented evaluation” (used for the issuance of a certificate or type rating) can be completed in a completely non-motion device. All of the AQP-assigned personnel were advocates of this strictly internal, AQP-approval-required training authorization.

It shouldn’t come as a surprise to anyone, that eventually, those persons having served as part of the AQP office would eventually be moved or promoted to other positions within the Air Transportation Division of the FAA. In fact, the final position of the FAA in response to a request from the UK’s Royal Aeronautical Society in regards to the FAA’s position on ICAO Document 9625 (which, by the way, was developed through an RAeS working group) was overseen and approved by a senior FAA manager who had previously been a very active part of the AQP office and had previously and personally approved AQP training programs using non-motion devices for the final training and the LOE/Proficiency Check/Type Rating evaluation.

I understand that, for some time now, there has been a rather nonchalant but determined effort, on the part of some in the FAA, to remove the motion on-set cueing requirement from the US rules. Some mid-level FAA managers, who apparently had “the ear” of some higher level managers, were apparently convincing enough to advocate the proposal to authorize US airlines to use simulation without the necessity of having properly programmed and validated on-set motion cueing systems – similar to what is and has been regularly authorized under AQP. It was (and still is thought by some) that doing so would enable airlines to retain full FAA-approval for training equipment that would be substantially less expensive. Less expensive? Yes, somewhat - usually in the neighborhood of 5% to 10% ... but substantially less? I'll leave that determination to you. Additionally, it is rumored that, in at least some cases, unsolicited accolades from some airlines, may have provided, or supported, some FAA managers with advancement or promotional opportunities or recommendations. There was evidently a somewhat surreptitious effort to expand the philosophy of fully accepting training programs that did not include the use of motion system equipped airplane flight simulators.

At least up to this point, such authorizations to deviate from regulatory requirements are limited to AQP applicants. Clearly, if the FAA were to outwardly acknowledge the value of simulators with functioning motion systems, which would certainly be the case by endorsing ICAO Document 9625, let alone adopting those standards, that would have resulted in either pointing up the problems with motionless simulation, but at least would complicate the widening of US airlines reaping the cost benefits of motionless simulation outside of the AQP approach.

This does not mean that the previous effort on the part of some in the US FAA who apparently remain determined to remove, or at least relegate to a significantly lesser level of importance, the current requirement in the US regulations for a motion cueing system in airplane flight simulators has waned or has been ended. That effort, as far as many can tell, remains alive and well – even if limited to only a very few advocates. It is a fact that those advocates are relatively highly placed within the FAA. Additionally, and I think importantly, this attitude is certainly the primary and perhaps the singular, reason that the FAA objected to the out-right adoption of the newly developed ICAO standards (Document 9625) for airplane flight simulation equipment, citing that the proposal was “too restrictive.” Actually, this language was used as a non-threatening and non-argumentative reference, but still communicating little more than “Opponent-Speak,” meaning that the FAA was not intending to adopt the provisions of that particular ICAO document. The specific reason was that this document specifically outlines the requirements for a motion system for the top 2 “types” of simulation.

At the moment, there appears to be 2 separate actions with respect to simulation: one to incorporate new areas of concern, bolstered by new data gathering and incorporation requirements – and one to eliminate (or at least minimize) a basic and important on-set cueing recognition capability in flight simulation – are at least questionable when seen simultaneously – and demonstrates what I believe to be the incongruent absurdity that exists as a result. The newly established requirement to gather and use more extensive airplane flight data to support the very deliberate attempt to ensure that simulators can and do provide the capability to more completely and more accurately provide more accurate and more complete training for pilots. Unfortunately, and, in my view, disingenuously (bordering on dishonestly) this is being done simultaneously with continuing a program that allows pilots to participate in a very specific program to complete their training AND demonstrate their competency as airline pilots, through the use of simulation that is completely devoid of one of the three (3) primary cueing inputs that forms the acceptance and realism of flight simulation. This primary cueing input is that of motion cueing.

Under the on-going approval of AQP training programs, the training and the testing completed by pilots may very well be accomplished in simulation equipment that has no motion capability. While training under traditionally developed training programs, can, and often do, provide the introduction of some flight maneuvering tasks in a device without motion capability … but, in each such case, the completion of the required training, and the demonstration of competency, is accomplished by using ALL of the appropriately recognized in-put cueing that would be present in an actual operating/airborne airplane – including motion on-set cueing. Eliminating the requirement for providing motion on-set cueing is eliminating what that pilot would be able to recognize and respond to in the airplane – and, therefore, we, as instructors/trainers, OWE it to those pilots to allow them to receive the very best simulation that we are capable of providing.

Of course, simulators today do NOT completely represent every aspect of an operating/airborne airplane – but they come VERY close – and they do it in a manner that will not require those pilots to “re-interpret” what they’ve seen, heard, and felt in that simulator when they get to the airplane. This simulator capability, together with competently and completely trained instructors, provides the very best opportunity to acquire the very best in operating flight crew members. The cueing recognized in the simulator, for all intents and purposes, will be the cuing that they will recognize in the airplane – of course, the cueing recognized in an operating/airborne airplane, in some cases, but not all, will likely be somewhat more robust – but it will be at least familiar and in some cases quite realistic.

My agitated sensibilities come from the fact that with the current regulatory environment (in the US at least) the only way these additional simulation requirements can be recognized as good and proper is IF the allowance to disregard the requirement for having and using a properly designed, and functional on-set motion cueing system is kept “under wraps” and out of the view of the public. Proceeding with both of these programs simultaneously is irony that rivals the most aggressive fantasy movie plot line – and makes no sense, what-so-ever!