NPA-STD 12NPA-STD 12(JAR-FSTD H) (JAR-FSTD H)

Comment ReviewComment Review

Presentation to OSTPresentation to OST

Bruno HALLER (DGAC France)Bruno HALLER (DGAC France)

31 May 200631 May 2006

NPA-STD 12NPA-STD 121.1. Background Background

2.2. Comment ProcessComment Process

3.3. Comment Response DocumentComment Response Document

4.4. Harmonisation with NPA-STD 11 Harmonisation with NPA-STD 11 (FSTD A)(FSTD A)

5.5. Outstanding WorkOutstanding Work

Background to JAR-FSTD H Background to JAR-FSTD H (1/6)(1/6)

► JAR-STD 1H, 2H and 3H covering JAR-STD 1H, 2H and 3H covering FFS, FTD, FNPT had been developed FFS, FTD, FNPT had been developed by different WG at different times.by different WG at different times.

►This resulted in a number of This resulted in a number of inconsistencies between the inconsistencies between the technical standards, the processes technical standards, the processes and the presentation of the three and the presentation of the three documents. documents.

Background to JAR-FSTD H Background to JAR-FSTD H (2/6)(2/6)

► JAR-STD 1H was most fully developed JAR-STD 1H was most fully developed and was, therefore, used as the basis and was, therefore, used as the basis for the new requirement.for the new requirement.

►The collective Term STD is replaced by The collective Term STD is replaced by FSTD (Flight Simulation Training Device)FSTD (Flight Simulation Training Device)

►The Term FS (Flight Simulator) is The Term FS (Flight Simulator) is replaced by FFS (Full Flight Simulator).replaced by FFS (Full Flight Simulator).

►These new Terms are chosen to align These new Terms are chosen to align with the FAA/JAA revised Terminology.with the FAA/JAA revised Terminology.

Background to JAR-FSTD H Background to JAR-FSTD H (3/6)(3/6)

►Appendix 1 to JAR-FSTD H.030 Appendix 1 to JAR-FSTD H.030 combines the Standards for all combines the Standards for all Types and Levels into a single table.Types and Levels into a single table.

►ACJ 1 to JAR-FSTD H.030 combines ACJ 1 to JAR-FSTD H.030 combines the Objective / Functions and the Objective / Functions and Subjective Testing Requirements for Subjective Testing Requirements for all Types and Levels into two Tablesall Types and Levels into two Tables..

Background to JAR-FSTD H Background to JAR-FSTD H (4/6)(4/6)

►Limited Changes ensure previous texts Limited Changes ensure previous texts from JAR-STD 1H, 2H and 3H are now from JAR-STD 1H, 2H and 3H are now unified and consistent.unified and consistent.

► In parallel, the Standards for In parallel, the Standards for Aeroplane STDs have been combined Aeroplane STDs have been combined in a JAR-FSTD A Document (NPA-STD in a JAR-FSTD A Document (NPA-STD 11).11).

Background to JAR-FSTD H Background to JAR-FSTD H (5/6) (5/6)

►The Standards for all types of The Standards for all types of Device remain unchanged.Device remain unchanged.

►The STD Standards were reviewed The STD Standards were reviewed to ensure compliance with JAR 11.to ensure compliance with JAR 11.

►Regulatory Process for Qualifying Regulatory Process for Qualifying STDs was aligned with current best STDs was aligned with current best practice.practice.

Background to JAR-FSTD H Background to JAR-FSTD H (6/6)(6/6)

Regulatory Impact AssessmentRegulatory Impact Assessment

►No Impact on SafetyNo Impact on Safety►No Economic ImpactNo Economic Impact►No environmental or social impactNo environmental or social impact►A positive impact on HarmonisationA positive impact on Harmonisation

Comment Review (1/4)Comment Review (1/4)

► Initial consultation with interested Initial consultation with interested parties (Authorities and Industry) parties (Authorities and Industry) took place during development NPA. took place during development NPA.

►NPA-STD 12 went out for a formal NPA-STD 12 went out for a formal public comment period of two public comment period of two months from 1st October to 1 months from 1st October to 1 December 2005.December 2005.

►232 comments were received 232 comments were received against NPA-STD 12.against NPA-STD 12.

Comment Review (2/4)Comment Review (2/4)

►Comments reviewed by a group with Comments reviewed by a group with members from Authorities, simulator members from Authorities, simulator manufacturers, simulator operators.manufacturers, simulator operators.

►Review included regularly Review included regularly consultation with JAR-FSTD A WG to consultation with JAR-FSTD A WG to ensure consistency between both ensure consistency between both documents.documents.

Comment Comment reviewreview (3/4)(3/4)

List of meetings attendees List of meetings attendees (Authorities)(Authorities)

- Peter Barrack (UK CAA)Peter Barrack (UK CAA)- Frank Reimann (German LBA)Frank Reimann (German LBA)- JM Sacazes (DGAC France)JM Sacazes (DGAC France)- Bruno Haller (DGAC France – Chairman)Bruno Haller (DGAC France – Chairman)

Comment review Comment review (4/4)(4/4) List of meetings attendees (Industry)List of meetings attendees (Industry)

► René Tassan / Eric Jansonnie : Eurocopter FranceRené Tassan / Eric Jansonnie : Eurocopter France► Bernard Josseaux / Michel Deparis : HelisimBernard Josseaux / Michel Deparis : Helisim► Francesco Pasqualetto : Agusta / RotorsimFrancesco Pasqualetto : Agusta / Rotorsim► Therje Thorrud : CHC Norway Therje Thorrud : CHC Norway ► Hubert Kinnel : SogitecHubert Kinnel : Sogitec► Eric Merck : French ArmyEric Merck : French Army► Bernard Delgingharo : Thales France (Secretary)Bernard Delgingharo : Thales France (Secretary)

Comment Response Comment Response Document (1/4)Document (1/4)

► Over 50% of comments (140) accepted :Over 50% of comments (140) accepted :

Accepted comments covered errors in Accepted comments covered errors in translation from existing standards, translation from existing standards, typographical and formatting errors or typographical and formatting errors or sought clarification of existing standards.sought clarification of existing standards.

► Declined comments (41) included :Declined comments (41) included :- a large proportion that proposed a a large proportion that proposed a

change in technical standards. change in technical standards. - not relevant comments.not relevant comments.

Comment Response Document Comment Response Document (2/4)(2/4)

► Partially accepted comments (27) included Partially accepted comments (27) included by definition comments for which a part is by definition comments for which a part is relevant.relevant.

► Noted comments (29) : 26 of them have Noted comments (29) : 26 of them have been considered « reserved for been considered « reserved for future work ».future work ».

Comment Response Document Comment Response Document (3/4)(3/4)

► WG members paid a particular attention that WG members paid a particular attention that the incorporation of accepted comments not the incorporation of accepted comments not leaded to a change of the existing technical leaded to a change of the existing technical standards.standards.

► JAR-FSTD H is now : JAR-FSTD H is now :

- a very consistent and a much more clear - a very consistent and a much more clear documentdocument

- much less typographical and formatting - much less typographical and formatting errors.errors.

Comment Response Comment Response Document (4/4)Document (4/4)

Completed Comment Response Completed Comment Response DocumentDocument

and final revised version of JAR-FSTD and final revised version of JAR-FSTD HH

delivered to CJAA on delivered to CJAA on 12 April 200612 April 2006. .

Harmonisation with NPA-STD Harmonisation with NPA-STD 11 (1/2)11 (1/2)

► Prior to submission of revised JAR-FSTD H, Prior to submission of revised JAR-FSTD H, a review of consistency with JAR-FSTD A a review of consistency with JAR-FSTD A was carried out (Gatwick meeting : 28 & was carried out (Gatwick meeting : 28 & 29 March 2006).29 March 2006).

► Section 1 of the two requirements are Section 1 of the two requirements are identical with exception of different dates identical with exception of different dates for implementation of Grandfather Rights.for implementation of Grandfather Rights.

► Section 2, Terminology, Process and Section 2, Terminology, Process and Quality System material identical.Quality System material identical.

Harmonisation with NPA-STD Harmonisation with NPA-STD 11 (2/2)11 (2/2)

► Technical standards consistent, as far as Technical standards consistent, as far as possible, within the constraints of the possible, within the constraints of the different operational and training needs different operational and training needs of aeroplanes and helicopters.of aeroplanes and helicopters.

► Guidance and interpretative material Guidance and interpretative material standardised as far as possible.standardised as far as possible.

Outstanding Work (1/2)Outstanding Work (1/2)

►Experience with current standards Experience with current standards has identified a number of has identified a number of shortcomings.shortcomings.

►Several comments submitted Several comments submitted proposing a change often relevant proposing a change often relevant in technical standards.in technical standards.

►A number of comments considered A number of comments considered valid.valid.

Outstanding Work (2/2)Outstanding Work (2/2)

►Document to be prepared, based on Document to be prepared, based on comments, identifying areas of JAR-comments, identifying areas of JAR-FSTD H where future revision to the FSTD H where future revision to the requirements may be justified.requirements may be justified.

►Document to provide justification for Document to provide justification for change.change.

►Document to be submitted through Document to be submitted through JAR-STD StG at June meeting, for future JAR-STD StG at June meeting, for future rulemaking activity by JAA/EASA.rulemaking activity by JAA/EASA.

THANK YOUTHANK YOU

ANY QUESTION ?ANY QUESTION ?