REGULATIONS – Market Makers or Killers?

How FAA Reg’s Created an Industry

 

When Rotorcraft Professional asked me to write a piece on how regulation influenced the simulator marketplace, I truly believed that it would be a relatively straightforward task. However, as I began to review the history, I found there was virtually nothing written until the 1960’s.

There is little doubt that simulators have been around for a long time, as illustrated in some of the historical photos in this article. The Antoinette Learning Barrel dates back to 1909 and was one of the first flight training devices. The original intent was to take fledgling pilots to a skill level and understanding of aircraft controls and movement so that they could step into the real thing and reduce the time necessary to develop their piloting skills.

This “hands on” simulator approach continued until the late 20’s and into the 30’s, when Mr. Ed Link introduced the Link Trainer in 1927. It was a more sophisticated device that incorporated an air source (bellows) to spin gyros and cause movement. Add a magnetic compass and the ability to spin the device through 360° and you have the first real practical flight simulator. With the advent of WWII,  serious R&D was spent to build ever increasing capability and sophistication into what was now called an FTD (Flight Training Device).  The first helicopter FTD did not come along until Sikorsky developed it  in 1939.

 

Two events happened that resulted in more formal documents. One was in Europe, when the Royal Aeronautical Society sanctioned a flight simulation ad hoc group (1967) to better define simulation. This resulted in the very first flight simulation symposium being held in 1970. At about the same time, the FAA created appendix B to FAR 121 air carrier regulations. Appendix B was then moved to the pilot examiners and Inspectors Handbook 8400.6.

Around 1975, the FAA created what was to be later called the Sim Team. Each FSDO, and subsequently each region, designated FAA personnel who would evaluate simulators being used by the airline(s). This evaluation resulted in an approval that allowed training to be accomplished in the simulator. How much credit to be allowed was the call of the inspector.

In 1977, a major effort was started by the FAA to work with airplane manufacturers such as Boeing and Lockheed to develop tests for simulators that would assure faithful and high fidelity representation of the aircraft. This effort resulted in FAA authorizing certified simulators to be used for recurrent pilot training, which heretofore could only be accomplished in the aircraft. New to this process was the introduction of flight test data, typically called reference data. Aircraft flight handling characteristics were determined to be a crucial ingredient when substituting simulator time for actual flight time. This is the first instance of regulation affecting the simulation marketplace. Prior to this, it can be comfortably stated that simulators were acquired because of economic factors, as they lowered the cost of overall flight training by allowing  the airplane assets to remain on the line.

In 1980, the FAA developed the Advanced Simulation Plan. It introduced the idea that motion enhanced the simulation experience to the point that simulation time would now be allowed to be substituted for the aircraft. The amount of credit depended on which phase (1,2,or3) it was certified to, with phase 3 simulators the most sophisticated, equal to today’s Level C/D. At this point, the marketplace was influenced because the phase 3 simulator could now be used for initial training.

Current FAA regulations (Part60) were being developed starting in 1997 and were not completed and released until 2006. The purpose of part 60 was to put in one place all simulation regulation and guidance. Part 60 includes flight training devices levels 5-7 and FFS (full flight simulators) A-C/D. FAR part 60 is under the cognizance and control of the National Simulator Program Office (AFS-205) and the National Sim Team. FAR 60 has not been a direct driver in the simulation marketplace. It has however, brought clarity to flight simulator design and development and is definitely a help to the simulator OEMs.

The helicopter simulation evolution really occurred about 15 years later than the airlines. With the increased sophistication and size of helicopters, utilization by on-demand charter, EMS and law enforcement operations that fall under FAR 135; there are many FTDs and FFS simulators being used by operators and  flight academies,  such as Flight Safety and Simuflight.

The results of this investigation reveal the following as it relates to the impact of regulations of the overall simulator marketplace:

·         There was little or no impact in the beginning because there were no regulations!

·         Right from the beginning, the sim market place was driven primarily by economic and cost considerations that allowed training to be conducted in the simulator instead of using the aircraft. Initial simulator training involved such things as start - up, systems management and control, and shut – down.

·         Starting in the mid 70’s, when the FAA approved internal flight training for airlines; regulations began to affect simulator acquisitions.

·         By 1977, the FAA was working with OEMs to develop testing and evaluation criteria for simulators that resulted in specific credit being given for specific simulators. A factor, but still not a primary driving factor.

·         1980 saw the development of FFS (motion based) resulting in, at the highest level, simulation being credited for recurrent and initial training for large transport category aircraft requiring a type rating.

·         1996-2006 FAR part 60 simulator regulation developed that defines all aspect of flight simulator requirements.

For this category of simulation, regulation had very little to do with driving the market place until the 1970’s, where it became necessary to meet the regulations. It should be noted that for this type of training, simulators improve the training experience and lower the overall cost, and that was the primary driver.

Aviation Training Devices (ATD) and Advanced Aviation Training Devices (AATD) have been gaining in popularity and recognition. This category of training devices has been entirely driven by FAA regulation. The devices have been evolving since about 1999. The standard and FAA approval has only been available since 2001. In the world of simulation, these devices are quickly becoming popular  not only for the flight schools which they were originally designed for, but also for fleet operators, EMS, Law Enforcement and transportation companies that are taking advantage of these new devices. FAA cognizance for these devices is AFS 800 (General Aviation and Commercial Division) not AFS 205 (National Simulator Program Office).

The difference between Level 5, 6 and 7 FSTDs and AATDs is their method of approval. The Level 5, 6, and 7 devices have objective testing as the basis for approval. Objective testing includes engineering flight data that is compared against the devices flight data objectively. The level 5 is somewhat less stringent in that the aeromodel reviewed can be a third part generic model (in fact the FAA has a model library that you can draw from) whereas levels 6 and 7 are developed against real flight test data. This flight testing or purchasing of flight test data is costly. A typical flight test program to capture the appropriate data could, and does go as high as $1M. The other method of obtaining the data is to obtain it from the OEM, but those data packages are as expensive or maybe more expensive than testing the aircraft yourself. In any event, you end up with a device that faithfully represents the aircraft aerodynamically.

Prior to the AATD, the above methodology was the only way to gain approval and use a flight training device that could be used in a flight training program. The problem therefore is simply cost. An R & D program that starts off with a $1M initial investment results in a device that is just too expensive for the average flight school or small operator.

In 2000, a small simulator company designed an inexpensive helicopter FTD that used Microsoft Flight Simulator as it graphics generator. This development took advantage of the advances in digital technology, graphics technology and PC computing power. The result was a generic helicopter replication that flew like a helicopter.

That same year, the device was brought to Heli Expo. It was housed in a 21 foot travel trailer and was the hit of the show. At that show, the simulator was actually sold to one forward thinking individual, Mr. Ken Pyatt of Sky Helicopters. It did not have FAA approval.

While it is true that like the early days of airline simulation you could make a case for reducing time in the helicopter to train, it was a hard sell and very few devices were sold.

The FAA was approached to see if there was some way to gain approval and credit for the device. Mr. Mike Henry and later, Mr. Bob Wright along with Larry Basham of AFS 800 stepped forward and put together an ad-hoc FAA/Industry team to develop a standard and evaluation criteria. The result was the ATD/AATD and the generation of AC61-136.

Today, the BATD and AATD are accepted forms by regulation and do receive training credit. This acceptance and regulatory approval has in fact brought affordable simulation to the General Aviation market. It is interesting to note that these relatively inexpensive devices approach the capability of the most sophisticated devices offered as recently as 15 years ago.

That fact has not gone un-noticed by the industry. Large helicopter operators are taking advantage of the AATD and regardless of credit approval have come to the same realization as that of the airlines back in the early days. If I you can train competency in the AATD, it can be used to reduce costs of the overall training by spending less time in the actual aircraft. Further AATDs are “approved by the administrator” and therefore with the approval of the cognizant POI, can be implemented in an internal training program.

With the AATDs taking advantage of affordable technology, the gap between high-end full flight simulators and AATD’s is closing. It is rumored that the FAA is reviewing the possibility of allowing training credits for a level 5 FTD which is generic in nature and very close technically to the AATD. I will go out on a limb and predict that the two approaches will at some time merge and the end result will be a win-win for aviation in much lower cost simulation and pilots that are ultimately better trained.