Is A Part 60 Level D Simulator for an Aircraft Class possible?
Thread Starter
Is A Part 60 Level D Simulator for an Aircraft Class possible?
CASR Part 61 allows for Aircraft Class ratings. So, for example, pilots can be trained and tested in Seminoles and they are then legally allowed to fly in Barons. In effect the Seminole is performing the function of a Level D flight simulator for a Baron.
Is it possible then to have a Part 60 Level D simulator that is representative of the Multi-Engine Aeroplane Class but which does not specifically simulate a Seminole or Baron? But which can legally function as a flight simulator for a Baron?
Is it possible then to have a Part 60 Level D simulator that is representative of the Multi-Engine Aeroplane Class but which does not specifically simulate a Seminole or Baron? But which can legally function as a flight simulator for a Baron?
CASR Part 61 allows for Aircraft Class ratings. So, for example, pilots can be trained and tested in Seminoles and they are then legally allowed to fly in Barons. In effect the Seminole is performing the function of a Level D flight simulator for a Baron.
Is it possible then to have a Part 60 Level D simulator that is representative of the Multi-Engine Aeroplane Class but which does not specifically simulate a Seminole or Baron? But which can legally function as a flight simulator for a Baron?
Is it possible then to have a Part 60 Level D simulator that is representative of the Multi-Engine Aeroplane Class but which does not specifically simulate a Seminole or Baron? But which can legally function as a flight simulator for a Baron?
A Level D sim. is type specific, even different models of Baron would be difficult to cover for real "D".
The performance program covers a specific aircraft, you really only need Level D (ultimately) if you are doing zero flight time type ratings and renewals.
However, on small GA aircraft, most of the things you need to do can be done on an "approved" Flight Training Device, and flying the aeroplane is usually cheaper than a sim.
Search the web for the RAeS simulator projects, there you will eventually find a clear explanation of ICAO definitions, and how the FAA and EASA classifications fit in.
I am afraid this is something a lot of FOIs don't really understand, and CASA "policy" on sim. use is unnecessarily and expensively inflexible.
Tootle pip!!
Thread Starter
Thanks LeadSled, I'll have a look for the RAeS document.
It does seem though like there is a hole regarding simulators in the Part 60, and Part 61.
- We have aircraft type ratings, and there are standards defining the flight data requirement for aircraft type simulators.
- We have aircraft class ratings, but there are no standards for the flight data requirements for aircraft class simulators.
So the question is what in actual fact defines why an aircraft falls into a class vs a type? Is there any objective measure of that? Because if there was an objective measure of what defines why an aircraft falls into a class then we should be able to use those measure to build a simulator for that class.
It does seem though like there is a hole regarding simulators in the Part 60, and Part 61.
- We have aircraft type ratings, and there are standards defining the flight data requirement for aircraft type simulators.
- We have aircraft class ratings, but there are no standards for the flight data requirements for aircraft class simulators.
So the question is what in actual fact defines why an aircraft falls into a class vs a type? Is there any objective measure of that? Because if there was an objective measure of what defines why an aircraft falls into a class then we should be able to use those measure to build a simulator for that class.
Georgie,
The ICAO has seven levels, you will be looking at Level 5.
The real problem is how enlightened (or otherwise) certification authorities are or are not ----- those who actually understand the values and limitations of simulation are very thin on the on the ground.
In Australia, at GA Level, I have seen some astoundingly good results produced by people who know what they are doing, I have also seen "CASA approved" simulators where misleading is the dominant result, "simulators" that are barely fit to be approved as system trainers being "approved" at virtually Level D.
Unfortunately, in Australia "training" has become type specific to the degree that self-confessed "experts" would have you "trained" on a Falcon if you had only drive a Holden.
That is, treating every light aircraft as if it had to be flown differently.
I come from a category where you teach people to fly "aircraft".
Believe it of not, there are parts of the world where there is no such thing as "design feature" ratings, or whatever we call then now, just "aeroplanes", some of which may have variable pitch props, the "third wheel" at different ends, etc., that you deal with as required --- with no formal requirement for "instruction" or "training" ---- and guess what, at least one of them has a far better safety outcomes record than Australia.
Tootle pip!!
The ICAO has seven levels, you will be looking at Level 5.
The real problem is how enlightened (or otherwise) certification authorities are or are not ----- those who actually understand the values and limitations of simulation are very thin on the on the ground.
In Australia, at GA Level, I have seen some astoundingly good results produced by people who know what they are doing, I have also seen "CASA approved" simulators where misleading is the dominant result, "simulators" that are barely fit to be approved as system trainers being "approved" at virtually Level D.
Unfortunately, in Australia "training" has become type specific to the degree that self-confessed "experts" would have you "trained" on a Falcon if you had only drive a Holden.
That is, treating every light aircraft as if it had to be flown differently.
I come from a category where you teach people to fly "aircraft".
Believe it of not, there are parts of the world where there is no such thing as "design feature" ratings, or whatever we call then now, just "aeroplanes", some of which may have variable pitch props, the "third wheel" at different ends, etc., that you deal with as required --- with no formal requirement for "instruction" or "training" ---- and guess what, at least one of them has a far better safety outcomes record than Australia.
Tootle pip!!
When you enter the realm of Level D simulation, I have been told that there is little difference in cost between devices. In fact, true propeller characteristics are more complex to simulate than pure jet. So a King Air Level D simulator may well be hired out at around the same rate as, say, an A320 device. Producing a generic GA simulator to that level, then getting an organisation as anal as CASA to approve it, would not be worth any operator's while.
A candidate desiring a MEA Class using simulation-only may as well do it in the King Air and thus automatically gain privileges to fly a Baron or Chieftain or whatever. On that, I am with LeadSled - most GA light twins don't require vastly different flying techniques. In my ferry pilot days working under the enlightened FAA regulations, it was common to be presented with an unfamiliar and sometimes quite complex machine to move from one side of the world to the other. An evening buried in the books, an hour in the cockpit to find all the knobs and switches, a test flight to check that the ferry tanks worked, and away we went. Most lived to tell the tale.
A candidate desiring a MEA Class using simulation-only may as well do it in the King Air and thus automatically gain privileges to fly a Baron or Chieftain or whatever. On that, I am with LeadSled - most GA light twins don't require vastly different flying techniques. In my ferry pilot days working under the enlightened FAA regulations, it was common to be presented with an unfamiliar and sometimes quite complex machine to move from one side of the world to the other. An evening buried in the books, an hour in the cockpit to find all the knobs and switches, a test flight to check that the ferry tanks worked, and away we went. Most lived to tell the tale.
Thread Starter
LeadSled, I understand that I will probably run into difficulty when I pursue this with you-know-who. But I do wonder about the appropriateness of the Simulator Standards. For example, Part 60 MOS 3.2.2.4 specifies a tolerance for control forces of +/-2.2kg. But as you and I know, when you fly an approach in a Seneca with just an instructor and student on board the force required on the elevator during the flare might be 15kg (a double hander), but when you put some passengers in the back the force required on the elevator for the flare might only be 5kg. Yet the Part 60 MOS requires flight test data proving you have the control force within 2kg. I mean, 2+/-kg for just a Seneca is ridiculous, let alone across the whole MEA class rating. So surely, there is an argument that the generic requirements for flight dynamics found in the FTD documents should be sufficient for a flight sim being used for say an IFR proficiency check with a class rating endorsement? We have a situation where the regulations are potentially depriving the GA training industry of becoming safer and more cost effective for no good reason (at least no reason that I can see, happy to be corrected if I am wrong).
Georgie,
Without getting down into the weeds, suffice to say that for FAR 23 (and most twins are earlier CARs) the data just isn't really available.
I can tell you from experience that, even with a full Boeing (or Airbus) engineering package, "getting it right" is very hard, and way beyond anything needed for most training, and not just GA. And after the "certification" is over, you then tweek the software so the sim feels like the real aeroplane.
With the ICAO specs, you can do about 80% of type rating on a Level 5 sim, with only a couple of sessions at the end on a Level 7 (aka D+) for a zero flight time rating on, say, a B777.
Get the RAeS bumpf, and have a good look at it , google < International Standards For The Qualification Of Aeroplane Flight Simulators>. It is very good for background understanding.
Also the current addition of ICAO Doc. 9625, AN/938. The latest version of CASR 60 is supposed to incorporate Doc. 9625, but I have not examined CASR 60 to look at the result new CASR 60.
As for operating (selling) costs for simulator customers, the cost of the device and its maintenance is a minor part of the overall costs.
In my view, your suggestions are excellent, and the equipment is available from several sources, but the CASA approach to "certification" is "cost unknown", because it is open ended, partially because saying NO avoids liability, either of the CASA person or CASA itself, the scales are heavily weighted against innovation.
CASA is quite happy to "approve" installations in US and elsewhere, because they have already been approved by somebody else (FAA etc) and therefor CASA ducks any potential liability for the outcome.
As an aside, US and other sim. operators/examiners shake their head in dismay at the volume of paperwork CASA demands, often close to thirty pages of "sign-offs", versus FAA, typically just one piece of paper.
Tootle pip!!
Tootle pip!!
Without getting down into the weeds, suffice to say that for FAR 23 (and most twins are earlier CARs) the data just isn't really available.
I can tell you from experience that, even with a full Boeing (or Airbus) engineering package, "getting it right" is very hard, and way beyond anything needed for most training, and not just GA. And after the "certification" is over, you then tweek the software so the sim feels like the real aeroplane.
With the ICAO specs, you can do about 80% of type rating on a Level 5 sim, with only a couple of sessions at the end on a Level 7 (aka D+) for a zero flight time rating on, say, a B777.
Get the RAeS bumpf, and have a good look at it , google < International Standards For The Qualification Of Aeroplane Flight Simulators>. It is very good for background understanding.
Also the current addition of ICAO Doc. 9625, AN/938. The latest version of CASR 60 is supposed to incorporate Doc. 9625, but I have not examined CASR 60 to look at the result new CASR 60.
As for operating (selling) costs for simulator customers, the cost of the device and its maintenance is a minor part of the overall costs.
In my view, your suggestions are excellent, and the equipment is available from several sources, but the CASA approach to "certification" is "cost unknown", because it is open ended, partially because saying NO avoids liability, either of the CASA person or CASA itself, the scales are heavily weighted against innovation.
CASA is quite happy to "approve" installations in US and elsewhere, because they have already been approved by somebody else (FAA etc) and therefor CASA ducks any potential liability for the outcome.
As an aside, US and other sim. operators/examiners shake their head in dismay at the volume of paperwork CASA demands, often close to thirty pages of "sign-offs", versus FAA, typically just one piece of paper.
Tootle pip!!
Tootle pip!!
Thread Starter
Ahhh, the old ISQAFS! Got it, I will refresh my memory reading this.
BTW, I just found this article on another thread. The FAA is moving in the right direction. Hopefully it will drag our equivalent in a better direction.
https://generalaviationnews.com/2018...d-proficiency/
BTW, I just found this article on another thread. The FAA is moving in the right direction. Hopefully it will drag our equivalent in a better direction.
https://generalaviationnews.com/2018...d-proficiency/
Ahhh, the old ISQAFS! Got it, I will refresh my memory reading this.
BTW, I just found this article on another thread. The FAA is moving in the right direction. Hopefully it will drag our equivalent in a better direction.
https://generalaviationnews.com/2018...d-proficiency/
BTW, I just found this article on another thread. The FAA is moving in the right direction. Hopefully it will drag our equivalent in a better direction.
https://generalaviationnews.com/2018...d-proficiency/
Sadly, the reality of deep prejudice is that it is likely to do exactly the opposite.
To quote a particular "aviation identity" some time ago: " I don't f----- care if the f----ing septics are safer (and cheaper), we are not f----ing going to do what the f----ing septics do".
I have never been able to understand the depth of loathing for anything and everything that emanates from the US, as exhibited by this cohort, but is a very major factor in the failure of the "regulatory reform program", post the adoption of FAR 21-25 in 1968 ----- and 21-35 was fiercely opposed within CASA, to the degree it almost didn't happen.
The group, of which his views are typical, and their compatriots in CASA, are responsible for the emasculation of the PIFR at it originally was, greatly increasing its cost and reducing its utility.
They are also largely responsible for the impossibly complex (and unjustified) Part 61, compared to US/NZ Part 61, and have a good look at the proposed Part 91/133/135/121, the last nail in the coffin for most light GA.
Tootle pip!!
That was probably the same ‘aviation identiity’ who interviewed me for a gig at CASA several years ago. When asked the question “If you were in a position to make changes to the aviation legislation what would you do?”
”Oh, that’s easy” says I. “Introduce the Kiwi rules”. He almost had a baby. As they say in all the cop shows...interview terminated at x o’clock.
”Oh, that’s easy” says I. “Introduce the Kiwi rules”. He almost had a baby. As they say in all the cop shows...interview terminated at x o’clock.
