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Simulator Training for strong crosswind landings

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Simulator Training for strong crosswind landings

Old 14th Jul 2014, 03:55
  #121 (permalink)  
 
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AirRabbit,
My apologies if I have offended you or your reputation in any form or manor. I was trying to make a small joke (and failed) that you had been in contact with the NSP on the release of the change. I knew it was coming sometime this summer, just not a set date. Again, my apologies.

Downloaded Part II of the change, not sure where Part I went to…
A little more than a small change (293 pages worth) to Part 60, now I understand the NPRM. I still think at some point it was discussed that a FSTD Directive would not have to go through the NPRM. Typically it takes 5+ years (as stated at this year’s AEA convention) from the start of the change to see the change to any FAR. I did notice in a March 2011 NSP briefing that a FSTD Directive is “Similar in nature to an Airworthiness Directive.” ADs have to go through the NPRM, unless they are emergency AD’s. We shall see…
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Old 14th Jul 2014, 14:43
  #122 (permalink)  
 
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Hi mnttech

No sir … it is I who should apologize … I was not offended at all and, in fact, I, too, was attempting to respond in a “humorous” manner … obviously … not very successfully, it would seem (and, even if I had been “verbally poked,” I am fully aware that my reputation is very likely beyond repair anyway …… hint – that’s another attempt). However, you are correct … I was, indeed, in contact with some on the FAA’s NSP staff (although “Dr. C” is no longer there), but I’m also in contact with other colleagues in the simulation industry – and hopefully I can stir up enough interest between those sources that someone, somewhere, might be motivated sufficiently to pursue a path of determining the best way to improve the lateral handling qualities of simulators.

The problem, as I see it, is that the handling qualities of today’s simulators is pretty darn good (certainly, not perfect, but darn good) – and making it noticeably better – even in only one aspect – is likely to further exacerbate the cost-for-benefit issues that have always been present – but historically has provided significant gains in benefits for the comparatively (and that is comparatively!) nominal increase in cost.

As I understand some of the posts on this thread, the majority of the concerns voiced with respect to “lateral stability,” or “lateral cueing,” has been primarily noticed during ground operations … either during taxi, during ground acceleration prior to takeoff, or during ground deceleration after landing. I’ll certainly attempt to make those points to whomever I can get interested in these issues – and maybe, just maybe – someone might be able to initiate some kind of “re-think,” or recognize, as at least one of my contacts has indicated, that merely modifying the existing programming might result in the improvement that many believe is, or should be, required. The “nitty-gritty” of such modifications is not my area of expertise, but I certainly understand it and I’m determined to follow through to see if a logical solution – or partial solution – may be possible.
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Old 14th Jul 2014, 16:59
  #123 (permalink)  
ZFT
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It seems that the thread has more or less now gone full circle, with interesting and pertinent deviations here and there.

The motion ‘deviation’ showed a general issue with simulation and motion specifically. All motion systems algorithms (quite nicely described in previous posts) basically fool or trick our balance sensors, the very same sensors we are training pilots (in FSTDs) to ignore and of course ignore in actual flight!

Some 7 years ago when the LMfC motion (as it was called then) ‘enhancement first raised its head it generated a lot of debate within this industry. (The major manufacturers were already having ‘issues’ with the FFT concept at that time and this was viewed by many as another unwelcome intrusion). The following extract was sent to me and I think it is as pertinent today as it was then;

Simulation lacks the rigour of other aeronautical disciplines and this is a very good illustration of my concerns with flight simulation. Quite possibly, the Belgians are wrong, but there is nothing that you can put forward to show or prove they are wrong. Moreover, their motion system may be less exact but actually lead to more effective training - we just don't know. But, to say that other simulators are more modern and therefore better or to say that you flew a simulator last week that felt good is not factual evidence - it's yet more subjective opinion and one opinion is then no more accurate or relevant than another.

All the time simulation backs off from doing real research it will suffer from this sort of stigma and we will have a discipline founded on nothing more than common sense and gut feel, with a few long technical words spread around to give the air of respectability."

What is certainly true today is that under current EASA and I assume FAA regs, there is still no requirement for any objective testing of motion systems (other than technical performance, vibs and latency). Every motion cue on a current Level C/D simulator is still only assessed subjectively!

ICAO 9625 Edition 3 does address this issue with both frequency and time domain objective testing BUT neither EASA nor the FAA have any plans to adopt Ed 3 in the foreseeable future.

I’m not going to repeat myself on the fidelity issue other than to reiterate that there really is no excuse with todays Level C/D FSTDs for anything less than perfection with systems simulation and performance within the normal envelope (within the confines of the obvious technical limitations).

There will be an issue with older FSTDs and hard and/or costly choices will need to be made. Excuses such as data or against our training policy are not limitations.
The FAA notice, whilst welcome will not in reality do anything to address the majority of the concerns raised here and with all the regulatory agencies being so ponderous it will not effect any changes until the next decade anyway.

Data does already exist to address many of the issues, the regulations are already there to be enforced and to quote AirRabbit “the handling qualities of today’s simulators is pretty darn good”

Better initial testing, more rigorous evaluations by both the operator and the qualifying body and the end User being more prepared to write up any defect not just accept them would go a long way.
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Old 14th Jul 2014, 21:13
  #124 (permalink)  
 
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Offered with no intent to be argumentative or accusatory - merely to provide yet another view - accurate by my training and experience, but not to suggest anything beyond that.

What is certainly true today is that under current EASA and I assume FAA regs, there is still no requirement for any objective testing of motion systems (other than technical performance, vibs and latency). Every motion cue on a current Level C/D simulator is still only assessed subjectively!
In that it was never a requirement for me to do so, I have not (as yet anyway) found it necessary to become familiar (let alone, intimately familiar) with the requirements levied on simulator users/sponsors by EASA, or any other regulatory outside of the US. But, I think it very likely to be misleading, at least, to indicate that there are no requirements for any objective testing of motion systems beyond those of vibrations and latency.

First, the testing for vibrations is not merely to see if the simulator can produce vibrations at the points and under the circumstances where the airplane is known to vibrate and do so within some established time frame. Of course it is true that the simulator must provide for the recording of the motion system response time(s) and a Statement of Compliance and Capability (SOC) is required for each. This SOC is a declaration that a specific requirement has been met, explaining how the requirement was met (e.g., gear modeling approach, coefficient of friction sources, etc.) and must also describe the capability of the FSTD to meet the requirement, including references to sources of information for showing compliance, rationale to explain how the referenced material is used, mathematical equations and parameter values used, and conclusions reached.

Additionally, with respect to vibrations, the simulator must provide characteristic motion vibrations that result from operation of the airplane if the vibration marks an event or airplane state that can be sensed in the flight deck. The simulator is to be programmed and instrumented in such a manner that the characteristic buffet modes can be measured and compared to airplane data. That is a description of an “objective” test.

Basically, the motion system tests outlined in the FAA regulations are intended to qualify simulator motion cueing systems from a mechanical performance standpoint. Additionally, the list of motion effects provides a representative sample of dynamic conditions that should be present in the flight simulator. An additional list of representative, training-critical maneuvers, which are to be selected from performance tests, and handling qualities tests, are recorded during initial qualification (but without tolerance) to indicate the flight simulator motion cueing performance signatures have been identified, and are intended to compare with similar results from the airplane and from previous tests of the simulator itself. This was formulated to help improve the overall standard of simulator motion cueing, and to assist in ensuring that this cueing does not deteriorate over time.

The Motion System tests in the FAA rules are intended to qualify the simulator’s motion cueing system from a mechanical performance standpoint. Additionally, the list of motion effects provides a representative sample of dynamic conditions that should be present in the flight simulator. An additional list of representative, training-critical maneuvers, selected from Performance tests and Handling Qualities tests, that are to be recorded during initial qualification (but without tolerance) to indicate the flight simulator motion cueing performance signature has been identified for each of those points. These tests are intended to help improve the overall standard of FFS motion cueing.

Motion System Checks, such as frequency response, leg balance, and turn-a-round check, as described in the FAA rule, are to demonstrate the performance of the motion system hardware, and to check the integrity of the motion set-up with regard to calibration and wear. These tests are independent of the motion cueing software and should be considered robotic tests.

Motion System Repeatability tests are to ensure that the motion system software and motion system hardware have not degraded or changed over time. This diagnostic test is to be completed during continuing qualification checks in lieu of the robotic tests. This will allow an improved ability to determine changes in the software or determine degradation in the hardware. The following information delineates the methodology to be used for this test.

(1) Input: The inputs should be such that rotational accelerations, rotational rates, and linear accelerations are inserted before the transfer from airplane center of gravity to pilot reference point with a minimum amplitude of 5 deg/sec/sec, 10 deg/sec and 0.3 g, respectively, to provide adequate analysis of the output.

(2) Recommended output:
(a) Actual platform linear accelerations; the output will comprise accelerations due to both the linear and rotational motion acceleration;
(b) Position of motion actuators.

Motion Cueing Performance Signature tests are designed to document and verify the following.

(1) The intent of this test is to provide quantitative time history records of motion system response to a selected set of automated QTG maneuvers during initial qualification. This is not intended to be a comparison of the motion platform accelerations against the flight test recorded accelerations (i.e., not to be compared against airplane cueing). If there is a modification to the initially qualified motion software or motion hardware (e.g., motion washout filter, simulator payload change greater than 10%) then a new baseline may need to be established.

(2) The conditions identified in the rule are those maneuvers where motion cueing is the most discernible. They are general tests applicable to all types of airplanes and are to be completed for motion cueing performance signature at any time prior to or during the initial qualification evaluation, and the results included in the master qualification test guide – as benchmarks.

(3) The motion system should be designed with the intent of placing greater importance on those maneuvers that directly influence pilot perception and control of the airplane motions. For the maneuvers identified in the rule, the flight simulator motion cueing system should have a high tilt co-ordination gain, high rotational gain, and high correlation with respect to the airplane simulation model.

(4) The minimum list of parameters that are to be recorded should allow for the determination of the flight simulator's motion cueing performance signature for the initial qualification evaluation. The following parameters have been accepted as sufficient to perform such a function:
(a) Flight model acceleration and rotational rate commands at the pilot reference point;
(b) Motion actuators position;
(c) Actual platform position;
(d) Actual platform acceleration at pilot reference point.

Motion Vibrations are not merely “to be present.”

(1) Presentation of the characteristic motion vibrations may be used to verify that the flight simulator can reproduce the frequency content of the airplane when flown in specific conditions. The test results are to be presented as a Power Spectral Density (PSD) plot with frequencies on the horizontal axis and amplitude on the vertical axis. The airplane data and flight simulator data are to be presented in the same format with the same scaling. The algorithms used for generating the flight simulator data should be the same as those used for the airplane data. If they are not the same then the algorithms used for the flight simulator data should be proven to be sufficiently comparable. As a minimum, the results along the dominant axes should be presented and a rationale for not presenting the other axes should be provided.

(2) The overall trend of the PSD plot should be considered while focusing on the dominant frequencies. Less emphasis should be placed on the differences at the high frequency and low amplitude portions of the PSD plot. During the analysis, certain structural components of the flight simulator have resonant frequencies that are filtered and may not appear in the PSD plot. If filtering is required, the notch filter bandwidth should be limited to 1 Hz to ensure that the buffet feel is not adversely affected. In addition, a rationale should be provided to explain that the characteristic motion vibration is not being adversely affected by the filtering.

The amplitude should match airplane data as described below. However, if the PSD plot was altered for subjective reasons, a rationale should be provided to justify the change. If the plot is on a logarithmic scale, it may be difficult to interpret the amplitude of the buffet in terms of acceleration. For example, a 1×10−3 g-rms2/Hz would describe a heavy buffet and may be seen in the deep stall regime. Alternatively, a 1×10−6 g-rms2/Hz buffet is almost not perceivable; but may represent a flap buffet at low speed. The previous two examples differ in magnitude by 1000. On a PSD plot this represents three decades (one decade is a change in order of magnitude of 10; and two decades is a change in order of magnitude of 100).

All of the above should be sufficient to refute the idea that motion cues on a current Level C or Level D simulator is assessed only subjectively.

ICAO 9625 Edition 3 does address this issue with both frequency and time domain objective testing BUT neither EASA nor the FAA have any plans to adopt Ed 3 in the foreseeable future.
While the official FAA response was somewhat clouded when delivered by former FAA Administrator Babbitt, at the Annual RAeS International Flight Crew Training Conference, in September, 2011, where, from the podium, he said the following:

On the subject of flight simulation training devices, let me address some questions we have received about our position on ICAO Document 9625 (Manual for Criteria for the Qualification of Flight Simulation Training Devices). We appreciate the ground-breaking work that ICAO and the Royal Aeronautical Society have done in developing this document, and we support the principles and standards it contains. We share the view that those principles and standards will lead to significant improvement in simulator training worldwide, and the FAA is working to adopt them.

The timeframe for adoption is the challenge. The magnitude of the changes recommended in 9625 is significant, and many will require rulemaking. And, as you probably know, the FAA’s rulemaking resources and priorities are currently driven by the requirements Congress mandated last year in the Airline Safety and FAA Extension Act of 2010. But we are committed not only to looking at adoption of the principles and standards in 9625, but also to all manner of new technologies and new methodologies for improved flight crew training.


The specific reason there has been little movement in the direction Administrator Babbitt had indicated is 2-fold: first, Mr. Babbitt is no longer the FAA Administrator; and second, there is a small faction of former and current managers who desire to eliminate, or drastically reduce, the requirement for simulator motion from the requirements of a simulator for a proficiency check or for the ATPC certification check. There are also many FAA Safety employees who are mightily fighting this nonsense, but without any outside look, this ridiculous attitude may not be seen for the stupidity that it really is.

I’m not going to repeat myself on the fidelity issue other than to reiterate that there really is no excuse with todays Level C/D FSTDs for anything less than perfection with systems simulation and performance within the normal envelope (within the confines of the obvious technical limitations).
Unfortunately, this statement borders on suffering an internal, self-defeating conflict. The “obvious technical limitations” are what is limiting in some cases and preventing in others, the “perfection of systems simulation and performance.”

There will be an issue with older FSTDs and hard and/or costly choices will need to be made. Excuses such as “data” or (being) “against our training policy” are not limitations. The FAA notice, whilst welcome will not in reality do anything to address the majority of the concerns raised here and with all the regulatory agencies being so ponderous it will not affect any changes until the next decade anyway.
I so wish that the “ponderous” nature of regulatory achievements was not so “ponderous.” But, for whatever it is worth, having some built-in slowness in such endeavors, is probably a good thing, lest we wind up being “hoisted by our own petard.”

Even still, the regulatory requirements that I recognize are far more specific and far more productive toward achieving the kinds of things that make simulation good. Yes, of course, we have further to go … and initiating that movement cannot start earlier than now … I for one am going to attempt to provide information and interest to the persons who may be able to more than acknowledge the existence of todays’ somewhat “menial” standards – at least with respect to where it is I think we all would like to have them … and have them around the world. Also, I would encourage anyone here to do whatever they can to push this effort forward … talk to your management, talk to your fellow pilots, talk to your regulators, get your union involved, write letters or make phone calls to ICAO, to the RAeS, whatever thing you can and are willing to do.

There is an old, old saying that … “for evil (and, here I’d exchange “evil” to “mediocrity”) to triumph, it takes only good men to do nothing.”

Better initial testing, more rigorous evaluations by both the operator and the qualifying body and the end User being more prepared to write up any defect not just accept them would go a long way.
No one in their right mind would challenge any aspect of this statement.
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Old 14th Jul 2014, 21:59
  #125 (permalink)  
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AirRabbit,

Offered the same way.

I did state "other than technical performance, vibs and latency" My point with Motion systems is that whilst by regulation (on a Level D FSTD) the various buffets and vibrations are accurately matched and that there is aircraft data to support this, all other motion cues are very much subjectively assessed and are typically tuned by the acceptance team at IPA time. All the EASA regs state is that they should be representative! There is no objective standard and no 2 FSTDs of the same aircraft type would necessarily 'feel' the same.

Quote:
I’m not going to repeat myself on the fidelity issue other than to reiterate that there really is no excuse with todays Level C/D FSTDs for anything less than perfection with systems simulation and performance within the normal envelope (within the confines of the obvious technical limitations).
Unfortunately, this statement borders on suffering an internal, self-defeating conflict. The “obvious technical limitations” are what is limiting in some cases and preventing in others, the “perfection of systems simulation and performance.”
I didn't express this too well. By "obvious technical limitations" I was referring to issues such as sustained G. I still strongly believe that today's FSTDs are far more capable and that with desire far more can be achieved from them.

I so wish that the “ponderous” nature of regulatory achievements was not so “ponderous.” But, for whatever it is worth, having some built-in slowness in such endeavors, is probably a good thing, lest we wind up being “hoisted by our own petard.”
It's 3 years already since that FAA response and none of the major regulatory authorities are anywhere nearer adoption. The new technologies they were looking at are probably obsolete already!!
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Old 14th Jul 2014, 23:43
  #126 (permalink)  
 
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There is no objective standard and no 2 FSTDs of the same aircraft type would necessarily 'feel' the same.
If they use the same data, including specific data points, there may be some areas where a really astute pilot might notice some differences, no doubt. Also, one might expect to “feel” some differences with traditional hydraulic vs. newer electric motion systems. Additionally, I’ve flown airplanes of the same make/model/series and have found tremendous variations in feel and in performance. As I said, in one case all of us pilots referred to the fleet of airplanes as “Ed and Eli’s Used Airplane Lot.”
It's 3 years already since that FAA response and none of the major regulatory authorities are anywhere nearer adoption. The new technologies they were looking at are probably obsolete already!!
…and, as Mr. Babbitt said, the US Congress was running around (pants and hair on fire!) attempting to get ahead of the Colgan accident-generated family/news media hype about what rules were “in need” of change. One major FAA regulatory “over-haul” was almost completely gutted, and that effort’s basis and history was usurped to address the more panic-driven efforts. Of course, Mr. Babbitt could not say what was happening in those terms (I believe, because he was unaware) – but, as everyone surely recognizes, the FAA is a politically driven government agency – just as vulnerable to political and public pressures as any government organization … particularly when they’re standing at the edge of a gaping hole. So the rule that was likely to have incorporated a major portion of the ICAO details was sidetracked (very probably to die a death of inattention) and the focus and attention was given over to getting out a rule that was to address what the Congress was demanding be addressed.

What is unfortunate and will probably not be recognized, is what I indicated in my earlier post … and that is that small group of FAA safety employees (and I use that descriptor only because that is their FAA organization, NOT their personal or professional goal) that have historically allowed individual airlines the authority to deviate from published rules (without having the public and other airlines review and then concur or object to what was being granted) and granting the authority to complete the training and conduct the check, even for the issuance of a type rating or issuance of a certificate in a non-motion, Level 5 or 6 Flight Training Device (which as you know, is substantially less technically capable than a Level C or Level D simulator!) continues to offer essentially the same program - and some continue to believe that program will continue to compromise the production of competent, well trained aviators.

As you likely are aware, the ICAO document requires motion on the highest 2 levels of device (Type 6 and Type 7) – and the final training and all testing would be required in one of those 2 highest levels – even though the Type 6 has not yet been fully developed. This was not what that small group wanted. You might recall the huge “stink” raised when United Airlines merged with Continental. United was under the same authority to deviate but continued to use Level D simulators for those purposes, but Continental had been granted and had used the authority to use FTDs for those same purposes.

It was THIS that made up the primary differences between the management officials at the 2 airlines AND the Union representatives of each. This turned into a high priority, hotly debated issue. And the FAA stood by hoping that the specifics would not make it into the pubic venue – or if it did, they were hoping that “John Q Average-citizen” wouldn’t recognize the stupidity involved. It is this same stupidity that still today allows some specifically authorized airlines to replace required training tasks with other “approved” tasks, such that one major US airline had not been required to train or test in either recognition of, or recovery from, either approach to stall OR aerodynamic stalls – and had operated like that for several (likely close to 10!) YEARS!

With this recognition, some apparently reluctant FAA officials ensured that each such airline was told to ensure they were properly training and checking on stalls – as THAT was the basic premise of concerns coming out of the Colgan accident. It’s my personal opinion that had all of this been raised and the proper public and political recognition been taken, the FAA could have suffered very serious negative publicity and lots of “heads” would likely have “rolled” … some appropriately, and some not. I think no one wanted to take that risk – so better to keep it under wraps, make the changes that the Colgan factions were pounding the table about – and look like a governmental agency that responded to public pressure and once again achieved the public confidence. If the public only knew! With all of this, moving forward with an acceptance or an adoption of even a portion of ICAO 9625 just didn’t make the primary “to do” list – as you might well imagine.

Let me quickly add … I don’t believe that Mr. Babbitt was aware of the specifics with respect to the differences of opinion within the ranks, nor do I believe he was aware of the critical issues those differences included. He was briefed the way he was briefed, carefully, but not necessarily completely. And, with his own personal issues happening at just about that same time … I think a good share of the “worker level” blokes were relieved that Mr. Babbitt would not be around to look into such things – as his piloting background would likely have picked up on the seriousness of it all quite quickly.

In the “aftermath” of all this – about the time that the revised rule was being advanced to satisfy the Colgan contingent – quietly and “below the radar,” one rather senior manager retired (quite quickly) and one other was “reassigned.” No fanfare … lots of good words uttered … and we’re “done.” Unfortunately, what was done … won’t do the job … and the attitude remains. Unfortunately.

The specific reason there has been little movement in the direction Administrator Babbitt had indicated is 2-fold: first, Mr. Babbitt is no longer the FAA Administrator; and second, there was a small faction of former managers who desired, and there are some current managers apparently continue to desire, to eliminate, or drastically reduce, the requirement for simulator motion from the requirements of a simulator for a proficiency check or for the ATPC certification check. There are also many FAA Safety employees who are mightily fighting this nonsense, but without any outside look, this ridiculous attitude may not be seen for the stupidity that it really is. Motivation? Well, they say motion is not needed. I think, and there are many who feel as I do, that the overall authorizations wind up saving the airline significant amounts of money.

If this is true (and from all I can understand, that IS true) the airline managers, echoing the statements coming from the FAA, saying the crews are “better trained” and “more competent” under the “new” training and testing authorizations (of course there is NO, NONE, ZERO evidence of this) and the airline managers echo this, and in doing so, compliment the FAA managers for having the foresight and nerve to adopt this “new thinking” … which, in turn, is a “pat on the back” of those FAA managers, and that, then, justifies their being awarded bonuses and promotions. I’ve described this as the clearest example of a non-verbal “you-scratch-my-back-and-I’ll-scratch-yours” agreement known to exist today.

And, finally, without attempting to set the US up for anything in particular, I suspect that if the US were to have adopted ICAO 9625, we would have seen other national regulatory authorities doing the same thing.

Last edited by AirRabbit; 15th Jul 2014 at 16:28. Reason: completion of thought
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Old 15th Jul 2014, 09:00
  #127 (permalink)  
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AirRabbit,

My gasp is flabbered. (Something similar did occur with a European NRA going it alone during the JAA era approving what would be a Level 5/6 FTD under FAA standards for initial type training and checking but nothing near what you have related).

I can appreciate your stance.
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Old 24th Aug 2014, 02:40
  #128 (permalink)  
 
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Interesting, there has only been 2 comments to date on the proposed change to FAR 60.
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Old 24th Aug 2014, 21:03
  #129 (permalink)  
 
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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.
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Old 25th Aug 2014, 22:21
  #130 (permalink)  
 
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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!

Last edited by AirRabbit; 26th Aug 2014 at 19:39. Reason: clarity
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Old 26th Aug 2014, 11:03
  #131 (permalink)  
 
Join Date: Dec 2007
Location: Denver, Colorado, USA
Posts: 137
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.
Ah so very very true. I have felt the 1500 hour requirement was just a “do something” reaction to the Colgan accident, as it has been discussed here.

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.
Like so many other “systems”, this takes a complete buy in from management, finance, instructors, pilots, maintenance, and certification.
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Old 26th Aug 2014, 18:47
  #132 (permalink)  
 
Join Date: Apr 2005
Location: Southeast USA
Posts: 802
Thanks mnttech, I appreciate your recognizing the “big picture,” so to speak. I’ve always believed that while “tunnel vision” often has its very valuable contribution to a myriad of applications, I think it imperative to recognize that when it is used it must be used with frequent and regular glances at “the big picture;” if for no other reason than to maintain a realistic understanding of both position and direction. While, of course, this applies to flying an airplane, it is equally applicable to developing and following progressive procedures for any business function – and, if nothing else, the choices evident here are blatantly in contradiction to this basic understanding. Often, if tunnel vision is the only perspective used, when the activity is observed from the outside, what is seen is usually recognized as actions chillingly (and regretfully) reminiscent of something between the Marx Brothers and the Keystone Cops!
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