as the commenters suggest. However, the range of validation envelopes
can vary significantly between FSTDs as a function of the extent of
flight test data, wind tunnel data, and other data used to develop the
model. Since those validation envelopes have not been transmitted by
the data providers to the FSTD operators in most cases, the FAA has
determined that the comments are unsupported and have concluded that
operators need to obtain the validation envelopes and ensure that their
training maneuvers remain within them.

    The FAA agrees with Airbus in that the evaluation of the FSTD
should consider the training that will be conducted in the device.
However, this rulemaking only addresses FSTD qualification standards
and the FSTD evaluation requirements were primarily developed to
support training as required by the Crewmember and Aircraft Dispatcher
Training final rule and public law. In developing the FSTD evaluation
standards for UPRT, the SPAW ARC recommendations, as well as the AURTA
recommendations, were reviewed to define a standard set of upset
recovery maneuvers that were needed to minimally qualify an FSTD for
such training. This set of maneuvers is considered to be the minimum
required for FSTD qualification that will provide a baseline evaluation
of the FSTD's capabilities to conduct UPRT, but in no way limits an
FSTD sponsor's decisions concerning which upset recovery maneuvers they
incorporate into their training programs.
    The FAA further notes that the qualification requirements for UPRT
in this final rule exceeds the current part 60 FSTD qualification
requirement for ``recoveries from unusual attitudes'' which limits
maneuvers to ``within the normal flight envelope supported by
applicable simulation validation data.'' \19\ If a training provider,
regardless of operational rule part, performs unusual attitude training
\20\ maneuvers that exceed the parameters that define an aircraft
upset, that FSTD must be evaluated and qualified for UPRT. The FAA does
not believe this will impose an additional cost burden on sponsors of
previously qualified FSTDs since UPRT qualification is only required if
the training provider chooses to conduct unusual attitude training that
exceeds the defined upset conditions.
---------------------------------------------------------------------------

    \19\ 14 CFR part 60, Appendix A, Table A1B, Entry No. 3.f.,
``Recovery From Unusual Attitudes''.
    \20\ Unusual attitude training is required training for an
instrument rating, an airline transport pilot certificate, and an
aircraft type rating.
---------------------------------------------------------------------------

    The FAA generally agrees that the validation limits are best
defined by the aerodynamic data provider and has provided clarification
in Attachment 7 in Appendix A of the final rule; however, there may be
instances where the original aerodynamic data provider cannot directly
provide this information (the original data provider is either no
longer in business or no longer supports the model) and the FSTD
sponsor must determine the validation envelope using data supplied with
the original aerodynamic data package. The FSTD sponsor will be
required to define such aerodynamic data sources in the required SOC.
b. Expansion of the FSTD Validation Envelope Using Existing Flight Test
Data
    In the existing part 60 rule, the objective testing requirements
found in Attachment 2 of Appendix A requires that testing be conducted
in weights and centers of gravity (CG) conditions that are typical of
normal operations. Furthermore, where such testing is conducted at one
extreme weight or CG condition, a second test must be provided at
``mid-conditions'' or as close as possible to the other extreme
condition.
    Airbus and Boeing commented that the existing part 60 requirement
for objective testing to be predominately conducted in mid-weight/mid-
CG flight conditions is outdated and a wider coverage of the alpha/beta
(e.g., AOA versus sideslip) envelope may be accomplished using critical
flight conditions testing during aircraft certification at extreme
weight and CG combinations. Boeing additionally stated that while the
current regulation supports this, it requires testing at the opposite
extreme conditions which increases the burden on the sponsor. Airbus
additionally commented that there is no need to have a global
requirement for this because the weight/CG requirements can be
specified for each test where relevant. CAE made similar comments on
this issue.
    FAA agrees with the commenters and supports allowing flexibility in
providing the best range of data to support not only extended envelope
training, but all training conducted in an FSTD. Where weight and CG
configuration is critical for validating a particular flight maneuver
(such as in some of the takeoff objective tests), those conditions are
described as a test requirement for that particular test. In general,
the FAA recognizes that weight and CG effects on the aerodynamic model
are well known and requiring redundant test conditions at varying
weight and CG ranges has questionable benefit for FSTD validation in
some required objective tests. The FAA has amended the final rule as
recommended by the commenters to allow for greater flexibility in
determining appropriate weight and CG conditions for some of the
required objective tests that do not have specific requirements
contained within Table A2A.
5. General Comments on UPRT
a. FSTD Qualification and FAA Oversight
    ALPA commented that while they support the requirements associated
with the simulator providing feedback to the instructors and
evaluators, they believe that only simulators that can perform all
aspects of the new training required in the Crewmember and Aircraft
Dispatcher Training final rule should be qualified. In addition, ALPA
further stated that since the proposed rule only requires FSTD
evaluation for those FSTDs used to conduct the additional training
tasks, a robust oversight system will be needed to ensure that only the
simulators qualified for this training are used in the required
training.
    In developing the proposed requirements in the NPRM, the FAA
considered the economic costs and benefits of mandating FSTD
modifications and evaluations to support training requirements. With
the considerable cost in the implementation of new aerodynamic stall
models on previously qualified FSTDs, the FAA could not justify
imposing this cost on FSTD sponsors who currently do not have a mandate
to conduct such training. Furthermore, the FAA determined that some
FSTD sponsors that do have a training mandate for stall and UPRT may
realize some cost savings by not having to qualify all of their FSTDs
where the training can be accomplished on a lesser number of devices.
Finally, with the large number of FSTDs that will require evaluation to
meet the part 121 compliance date of March 2019, this may provide some
practical relief in having to qualify all FSTDs within a relatively
short amount of time.
    The FAA appreciates ALPA's concern for proper FAA oversight to
ensure that the FSTDs are evaluated and qualified before extended
envelope training is conducted. The FAA notes that an oversight system
to track FSTD qualifications is already in place with the list of
qualified tasks that is currently required on the part 60 required SOQ
for all FAA qualified FSTDs.\21\ In the final rule, the FAA maintained
the requirement in FSTD Directive No. 2 that the individual training
tasks are to be reflected on the FSTD's SOQ once qualified. The FSTD's
SOQ will then serve as a tracking mechanism to ensure the FSTD has been
properly evaluated and qualified by the FAA NSP to conduct the
individual training tasks. Furthermore, the FAA

will coordinate internally with Principal Operations Inspectors (POIs)
to ensure that only FSTDs that are qualified in accordance with FSTD
Directive No. 2 are approved for use in training those specific tasks
as part of an FAA approved training program.
---------------------------------------------------------------------------

    \21\ See Sec.  60.17(b)
---------------------------------------------------------------------------

b. Maintenance Concerns
    A4A commented that further testing is needed to ensure that the
reliability and availability of FSTDs due to maintenance issues is
unchanged with the addition of UPRT training.
    The potential for stall vibrations to cause FSTD maintenance issues
has been acknowledged and discussed in a previous section on stall
buffet. The FAA acknowledges that conducting UPRT maneuvers in an FSTD
can produce significant motion system excursions, however, the FAA is
not aware of any evidence that the addition of general UPRT maneuvers
will introduce significant maintenance issues that would affect the
overall reliability and availability of an FSTD beyond what is normally
seen in existing training. As with motion system tuning in general, the
FAA expects that FSTD sponsors will employ limits and protections
within their motion system hardware and software that will protect the
FSTD from dangerous excursions that could damage the FSTD's equipment
or injure its occupants. The exposure to stall buffet likely has the
greatest potential for affecting an FSTD's reliability and the FAA has
addressed this issue in the stall requirements sections.

C. Evaluation Requirements for Engine and Airframe Icing Training Tasks

    In the NPRM, the FAA proposed changes to the general requirements
for engine and airframe icing qualification as well as adding a new
objective demonstration test for ice accretion effects for newly
qualified FSTDs. The changes were based upon new icing requirements in
the ICAO 9625 document, as well as recommendations made by the SPAW
ARC, and were intended to improve upon the existing engine and airframe
icing requirements in part 60. The proposed changes focused on
requirements for improved ice accretion models that represent the
aerodynamic effects of icing rather than estimating icing effects
through gross weight increments.
1. Objective Demonstration Testing
a. Objective Demonstration Testing for Previously Qualified FSTDs
    In the proposal, the FAA introduced new objective testing
requirements for the demonstration of icing effects on Level C and
Level D FFSs. The objective tests are intended to demonstrate that the
aerodynamic effects of ice accretion are present in the simulation with
the icing model active as compared to the simulation where no ice is
present. Due to the potential cost impact for previously qualified
FSTDs, these tests were not retroactively required in FSTD Directive
No. 2.
    Boeing commented that the objective demonstration test for engine
and airframe icing is not required in FSTD Directive No. 2 (for
previously qualified FSTDs) and recommended that text should be added
to Table A2A (Entry No. 2.i.) to clarify that this test is not required
for previously qualified FSTDs.
    FAA agrees with Boeing in that this demonstration test for engine
and airframe icing is not required for previously qualified FSTDs and
has added clarifying language in FSTD Directive No. 2. As with comments
in previous sections concerning stall buffet testing, previously
qualified FSTDs will maintain grandfather rights and the modifications
to Table A2A will generally not be applicable to previously qualified
FSTDs unless specified in an FSTD Directive. As a result, FAA has not
added additional text in Table A2A concerning previously qualified
FSTDs because it will be adequately addressed in the FSTD Directive.
b. Icing Effects and Recognition Cues
    In the proposed icing effects objective demonstration test, the FAA
included specific icing effects that may be present and evaluated as
applicable to the particular airplane type. This list included both
aerodynamic effects of ice accretion as well as engine effects that may
also be present with the icing model activated in the simulation.
    Boeing commented that the objective demonstration test for icing
includes engine effects, but the general requirement for icing does not
specifically identify engine effects and this should be removed from
the objective testing requirement. An anonymous commenter stated that
it may be necessary to show engine effects and airframe effects of
icing separately because the test will not differentiate between thrust
losses and drag increases. Another anonymous commenter pointed out that
changes in control effectiveness and control forces are limited mainly
to reversible systems on certain airframe configurations and the FSTD
should only introduce these changes when they are representative of the
specific make and model of aircraft. Additionally, an anonymous
commenter stated that there is ``very little guidance on what engine
icing effects should be represented and most manufacturers state there
are little effects on engine indications for current turbofans. Based
upon the data we do have for engine inlet icing, the effects are often
very subtle, yet the requirements seem to ask for something more
dramatic. If we modify our icing models to favor dramatic effects, do
we risk training pilots to miss looking for the subtle indications?''
    Concerning Boeing's comment, the general requirement for engine and
airframe icing (Table A1A, Entry No. 2.j.) does include modeling the
effects of icing on the engine, where appropriate, as does the current
requirement in part 60. While the information section in the
demonstration test does state ``aerodynamic parameters,'' the intent of
the test is to demonstrate the effects of the icing model integrated
into the simulation. If the sponsor designated icing model used for the
demonstration test has an effect on relevant engine parameters (such as
thrust reduction or other effects), these effects should also be shown
as part of the test. FAA has amended the test details in the table to
clarify this. Other icing models that may be optionally developed by
the FSTD sponsor to train recognition of engine effects due to icing
will not require separate objective demonstration testing.
    The FAA agrees that icing effects should only be introduced where
representative of the specific make and model of aircraft and has
clarified this in Table A2A (test 2.i.) and Attachment 7 of the final
rule. The FAA does not intend for a simulator operator to artificially
insert dramatic icing effects that are not representative of the
aircraft. While the FAA is aware that the cues of ice accretion can
vary significantly depending upon the nature of the icing event and the
aircraft's characteristics, the icing models developed for simulation
and training purposes should support the general recognition of icing
cues that are typical for the aircraft being simulated.
2. Requirements for Lower Level FTDs
    In the NPRM, the FAA proposed general requirements and objective
demonstration testing for engine and airframe icing as part of the new
Level 7 FTD requirements in Appendix B.
    TRU Simulation commented that in the proposal for ICAO 9625,
Edition 4, only a Type VII is allowed for use in UPRT and this item
(icing) is identified as only being required on devices where UPRT will
be trained. TRU Simulation requested that the FAA confirm applicability
on a Level 7 FTD and

remove the requirement if not. TRU Simulation and A4A further commented
that the objective demonstration test for icing is not required for an
ICAO 9625 Type V device and should be removed from the Level 7 FTD
requirements. TRU Simulation and A4A additionally commented that a new
requirement for Level 6 FTD was introduced to have the anti-icing
system operate with appropriate effects upon ice formation on airframe,
engines, and instrument sensors.
    FAA reviewed ICAO 9625 Edition 4 and found that the general
requirement for the modeling of icing (Appendix A, Entry No. 2.1.S.e.)
is a minimum requirement for an ICAO 9625 Type V device and has
therefore maintained this requirement for the FAA Level 7 FTD. FAA
confirms that the objective demonstration testing for icing is not
required for an ICAO 9625 Type V device and therefore has removed this
requirement for the FAA Level 7 FTD in Table B2A to maintain
consistency with the ICAO document.
    Regarding the addition of anti-icing effects to a Level 6 FTD, FAA
has removed the ICAO numbering system in the general requirements table
that was published with the NPRM and restored the existing part 60
requirements for Level 6 FTDs. The FAA notes, however, that the
existing part 60 functions and subjective testing requirements for
Level 6 FTDs includes ``operations during icing conditions'' and
``effects of airframe/engine icing'' in Table B3A of Appendix B. The
FAA has not changed these requirements in the final rule.
3. Existing Engine and Airframe Icing Requirements in Part 60
    In the existing part 60, the subjective evaluation requirements in
Appendix A includes a table of special effects (Table A3F) that
contains additional requirements for the qualification of engine and
airframe icing. In the NPRM, the FAA maintained this table with no
changes to it.
    Boeing, A4A, and NTSB commented that the requirements for icing
evaluation in Table A3F (special effects) include the evaluation of
increased gross weight due to ice accumulation. The commenters noted
that the pilot has no means to recognize if the simulated aircraft's
weight has increased and an increased gross weight due to ice
accumulation is typically an insignificant effect of icing. Boeing
further commented that this test requires a ``nominal altitude and
cruise airspeed and is likely to result in a flight condition where
icing does not occur for large commercial transport category airplanes.
This flight condition will also likely result in trimming at a low AOA
where the effects of ice, even with the anti-ice system deactivated,
are small (a few tenths change in pitch attitude or a few percent
change in thrust to maintain level flight). In the lower AOA range, the
aerodynamic effects of ice are relatively small. For large commercial
transports one might expect to see a few tenths of a degree change in
pitch attitude or a few percent change in thrust to maintain level
flight with the addition of ice. This proposed new test will likely
result in generating unnecessary questions when the expected (larger)
results are not seen.''
    FAA agrees with the commenters and has removed references to
increased gross weight in the final rule as that table entry for icing
special effects (Table A3F, Entry No. 2) was inadvertently retained in
the proposal. Furthermore, the FAA has amended this table to remove the
``nominal altitude and cruise airspeed'' requirement and made
additional changes to better align this section with the general
requirements for engine and airframe icing in Table A1A, Entry No. 2.j.
4. Applicability in Training Programs
    In the NPRM, the proposed updated requirements for engine and
airframe icing were applied to all Level C and Level D FFSs, regardless
of the type of aircraft or operator. This is consistent with the engine
and airframe icing requirements in the existing part 60 and previous
FSTD evaluation standards. The FAA notes that ``engine and airframe
icing'' simulation is not a new FSTD qualification requirement that was
introduced by this rulemaking. In fact, the ``effects of airframe
icing'' has been a minimum FSTD qualification requirement for Level D
(Phase III) FFSs since the publication of AC 121-14C, Aircraft
Simulator and Visual System Evaluation and Approval, published in 1980.
Similarly, the ``effects of airframe and engine icing'' is currently an
FSTD qualification requirement in the existing part 60 rule (published
in 2008) for Level C and Level D FFSs.
    Delta commented that the de-icing and anti-icing systems are very
effective on turbojet airplanes. The accidents referenced in NTSB
reports are turboprops with significantly less performance available.
Delta added there are no useful training objectives to be taught to
pilots of commercial turbojet airplanes in icing conditions. A4A
commented that stall ice effects are not required by Public Law 111-216
or the Crewmember and Aircraft Dispatcher Training final rule and
should be deleted from this final rule. Delta, A4A, and FlightSafety
further questioned whether the FAA has a specific list of airframes
that are impacted by icing or are vulnerable to a specific type of ice
accretion.
    The FAA points out that Section 208(b)(1) of Public Law 111-216
addressed increasing the familiarity of flight crewmembers with, and
improving the response of flight crewmembers to icing conditions.
However, irrespective of statutory direction, the FAA believes the
understanding of the effects of icing on aircraft performance is
essential for professional crewmembers particularly as it relates to
stall AOA.
    The FAA agrees with Delta that de-icing and anti-icing systems are
generally very effective on turbojet airplanes. However, every airplane
is susceptible to icing to some extent and therefore, there are useful
training objectives to be taught to pilots of turbojet aircraft. While
the FAA recognizes that turboprop airplanes are generally more
susceptible to ice accretion, accidents and incidents on turbojet
aircraft have occurred in the past. In the case of the Circuit City
Cessna 560 (a turbojet aircraft) accident in Pueblo, Colorado on
February 16, 2005,\22\ the flight crew did not comply with de-icing
procedures during approach which led to an aerodynamic stall from which
they did not recover. While it is unknown if the crew recognized the
effects of icing before the aerodynamic stall occurred, enhanced
simulator training on de-icing and/or anti-icing procedures with
representative effects of ice accretion may have increased their
awareness that ice accretion was occurring.
---------------------------------------------------------------------------

    \22\ Crash During Approach to Landing; Circuit City Stores,
Inc.; Cessna Citation 560, Pueblo, Colorado, February 16, 2005.
Accident Report NTSB/AAR-07/02. National Transportation Safety
Board.
---------------------------------------------------------------------------

    With respect to engines, while turboprop and propeller aircraft
engines are generally more susceptible to the effects of ice accretion
than turbojet engines, power loss events due to core icing have been
known to occur on multiple models of aircraft and engines (including
large turbojet aircraft). In research conducted in 2009, it was found
that engine power loss events due to ice accretion were occurring at a
rate of about one event every 4 months.\23\ While these events often
occurred in conditions that pilots considered benign with no airframe
ice accreted, there were recognition cues present and it was noted that
each engine appeared to

have a different manifestation of the icing event. While this final
rule does not require specific engine icing models such as these,
providing flight crews with representative cues of engine icing, where
present during a typical in-flight ice accretion event, could aid in
its recognition during line operations.
---------------------------------------------------------------------------

    \23\ Mason, J., ``Current Perspectives on Jet Engine Power Loss
in Ice Crystal Conditions: Engine Icing,'' Presentation at 2008 AIAA
Atmospheric and Space Environments, June 23rd, 2009.
---------------------------------------------------------------------------

    The FAA has not prescribed specific types of ice accretion models
to be implemented in the final rule. The intent is to provide flight
crews with representative recognition cues of ice accretion for the
aircraft being simulated. Where the accident and incident record
indicates that a particular airframe may be susceptible to a particular
type of ice accretion, the simulation of the cues associated with that
type of icing should be considered when developing a representative
icing model. While the accident record has some general examples of
this (such as supercooled large droplet icing or tailplane icing on
some aircraft), the aircraft manufacturer will likely be the best
source of information as to a particular type of icing scenario that
may enhance training in recognizing and exiting icing conditions for
that aircraft.
5. Data Sources and Tuning of Ice Accretion Models
    In the proposal, the FAA introduced updated engine and airframe
icing requirements that included a requirement to use ``aircraft OEM
data or other acceptable analytical methods'' to develop ice accretion
models.
    An anonymous commenter stated that the cost of purchasing icing
data, if it exists, could be prohibitive. Due to the availability of
SME's who have flown the subject aircraft in icing conditions, the
requirement should allow SME pilot validation of icing models. Both A4A
and CAE made similar comments that some SME pilot tuning and validation
of icing models should be allowed in the requirements.
    Dassault further commented that flight test data obtained through
the aircraft certification process is limited with larger amounts of
ice accretion. Engineering tests might be conducted in those
conditions; however, Dassault claimed it would be unable to provide an
SOC because there is no flight test data to support it.
    The FAA maintains that icing models may be developed using
analytical or other engineering methods, incorporating flight test data
where available. This process may include supplemental SME pilot
assessment to tune and subjectively validate the models. Furthermore,
the objective demonstration test does not require the use of flight
test data or other data to validate the model. The demonstration test
is for the purpose of demonstrating that the expected icing recognition
cues are present as compared to the simulation with no ice present. The
FAA has added clarifying language in Table A1A and Attachment 7.
    The FAA agrees with Dassault that flight test data gathered during
the aircraft certification process will generally be limited to ice
shape testing conducted to demonstrate performance limits. Like the
current part 60 requirements for the simulation of airframe and engine
icing, engineering and analytical methods may be used to develop
representative icing models that support the intended training
objectives. While the use of flight test data would certainly assist in
developing such models, engineering analysis supported with subjective
assessment and tuning of the icing models for the expected recognition
cues will be acceptable in lieu of flight test developed models and
should not be as costly.

D. Evaluation Requirements for Takeoff and Landing in Gusting
Crosswinds

    In order to support the new gusting crosswind training requirements
in the Crewmember and Aircraft Dispatcher Training final rule, the FAA
proposed new minimum requirements for Levels A, B, C, and D FFSs to
include the programming of realistic gusting crosswind profiles. The
FAA notes that in the existing part 60 and previous FSTD evaluation
standards, there is no requirement for any FSTD to simulate gusting
crosswinds. These proposed requirements also included updated ground
handling characteristics to be evaluated with crosswinds and gusting
crosswinds up to the aircraft's maximum demonstrated crosswind
component. The FAA further included guidance material in the
information section of the proposal that recommended the use of the
Windshear Training Aid or other acceptable source data in the
development of the gusting crosswind profiles.
1. Applicability on Lower Level FSTDs
    In the proposal, FSTD evaluation requirements for gusting crosswind
profiles were made applicable for all FFS levels in Appendix A as well
as the Level 7 FTD defined in Appendix B.
    TRU Simulation and A4A commented that a new gusting crosswind
requirement was added for the Level 7 FTD and questioned whether this
was appropriate for a Level 7 FTD. Boeing additionally commented that
the requirement for gusting crosswinds are proposed for Levels A, B, C,
and D FFSs, but crosswind takeoff and landing tasks are not minimum
requirements for Level A simulators in Table A1B. Finally, A4A and
Delta commented that gusting crosswind requirements have been added for
both Level A and B simulators, but should be removed due to lack of
alignment with the ICAO 9625 FSTD device type categories.
    With regards to the Level 7 FTD, FAA has examined the ICAO 9625
requirements for the Type V device and found that instructor control of
``surface wind speed, direction, and gusts'' is a minimum requirement
for this device level (see ICAO 9625, Appendix A, section 11.4.R,G). In
order to maintain consistency and alignment with the similar ICAO
device, FAA has maintained this requirement in the general requirements
and functions and subjective testing tables for the Level 7 FTD, but
removed the more detailed requirement for realistic gusting crosswind
profiles and the associated SOC that was proposed in the NPRM.
    FAA agrees with Boeing's comment concerning the qualification of
the Level A simulator for takeoff and landing tasks and has removed
this requirement in the final rule. Additionally, due to the lack of
required side force motion cueing in a Level B simulator that would
enhance the simulation of a realistic and dynamic gusting crosswind
scenario, the FAA has also removed this minimum requirement for Level B
simulators in the final rule.
2. Gusting Crosswind Profile Data Sources
    In the NPRM, the FAA proposed requirements for FSTD sponsors to
develop a realistic gusting crosswind profile for use in training. The
FAA was not prescriptive in this requirement and only required that the
profile be ``realistic'' and ``tuned in intensity and variation to
require pilot intervention to avoid runway departure during takeoff or
landing roll.'' The FAA additionally provided guidance in the
information column of the proposal recommending the use of the
Windshear Training Aid or other acceptable data sources to develop the
gusting crosswind profiles.
    The FAA received several comments concerning the data sources
needed to develop realistic gusting crosswind profiles to meet the rule
requirements. American, JetBlue, and A4A commented that FAA should
provide an appropriate gusting crosswind model as recommended by the
NTSB in its safety recommendation. Boeing commented that the Windshear
Training Aid does not provide the necessary data to effectively model
gusting crosswinds. Delta and A4A further commented that

the FAA should define ``other acceptable source data'' to help sponsors
be consistent in programming the gusting crosswind scenarios.
Additionally, A4A commented that the FAA should permit carriers to use
crosswinds with gust data from multiple sources because doing so will
provide flexibility, more compliance options, and reduce compliance
burdens. Finally, an anonymous commenter stated that all references in
the NPRM to ``gusting crosswinds'' lack definition of what is
considered a ``gust''. ``Without a definition such as ``10 percent
increase over steady state wind speed for x seconds, repeated
randomly'', this is an entirely subjective condition and as such is
subject to every inspector's idea of what a wind gust should or could
be. If the FAA cannot provide subjective guidance similar to the
Windshear Training Aid, which does not provide adequate information for
this scenario, the gusting crosswind scenarios should be treated as
`demonstration only' and not for training credit.''
    While the FAA would generally agree that a defined wind gust model
could provide standardization for FSTD qualification purposes, such a
generic model may not be realistic unless tuned for the particular
aircraft and training scenario. Similar to the Windshear Training Aid's
windshear profiles, subjective tuning would be required to adjust the
model as a function of the aircraft type/configuration and ambient
conditions to provide the cues and aircraft performance needed to
accomplish the training objectives. In the proposal, the FAA required
that such wind gust models be ``realistic'' and have been ``tuned in
intensity and variation to require pilot intervention to avoid runway
departure.'' Like many other areas in the simulator qualification
standards, this allows for the FSTD sponsor to develop solutions that
meet the needs of their particular training program without the FAA
prescribing a specific solution. While realistic baseline wind gust
models may be derived from aircraft operational data, meteorological
data, or other data, a certain amount of subjective tuning will be
required in many cases to ensure the gusts are adequate enough to
require pilot intervention to avoid runway departure or otherwise do
not exceed the crosswind capabilities of the simulated aircraft and
supporting aerodynamic and ground model data. Due to the wide range of
aircraft and associated crosswind capabilities, the FAA has found that
specifying a certain gust characteristic for FSTD qualification would
not be practical and has maintained the requirements as proposed.
    In response to the NTSB safety recommendation \24\ and commenters'
requests for an FAA developed gusting crosswind model, the FAA
conducted an analysis of the extracted wind data from the Continental
(CO) 1404 accident \25\ and developed two wind gust models that may be
used by FSTD sponsors to meet the requirements for a realistic gusting
crosswind model. The first model was developed using the CO 1404
accident data to closely replicate the wind gust that was experienced
by the flight crew in that accident. While this model was tested by FAA
on a Boeing B737-800 simulator and was found to provide a subjectively
acceptable training scenario, it is expected that the model will need
to be tuned by the sponsor for different aircraft and operator specific
training scenarios.
---------------------------------------------------------------------------

    \24\ NTSB safety recommendation no. A-10-110.
    \25\ Runway Side Excursion During Attempted Takeoff in Strong
and Gusty Crosswind Conditions, Continental Flight 1404, December
20, 2008, NTSB Final Report, NTSB/AAR-10/04.
---------------------------------------------------------------------------

    A second model was developed using a simplified linear estimation
of the CO 1404 accident data using maximum wind rates of change as
referenced in the Windshear Training Aid and the Joint Airport Weather
Studies (JAWS) \26\. Similar to the continuous wind gust model, this
model may also require tuning by the sponsor for different aircraft and
operator specific training scenarios.
---------------------------------------------------------------------------

    \26\ The maximum wind rates published in the Windshear Training
Aid are based upon the Joint Airport Weather Studies (JAWS) and were
calculated from accident flight data recorder and Doppler radar
measurements of microburst events.
---------------------------------------------------------------------------

    FAA recognizes that sponsors may desire to implement their own wind
models that may be more suitable for their particular training programs
and has not mandated the above described wind gust models as a
condition of FSTD qualification. These models will be provided with the
final rule as guidance material in a National Simulator Program (NSP)
Guidance Bulletin and may be used as one method to develop realistic
gusting crosswind profiles to satisfy the requirements of the rule. As
suggested by A4A, this will provide operators with flexibility to
develop other wind gust models from multiple sources to meet the FSTD
qualification requirements.
3. Maximum Demonstrated Crosswind
    In the proposal, the FAA included general requirements for Level C
and Level D FFSs that included ground handling characteristics for
crosswinds and gusting crosswinds up to the aircraft's maximum
demonstrated crosswind component.
    Delta and A4A requested clarification if the maximum demonstrated
crosswind value includes the gusting component, or is the intent to
require the gusting component in addition to the maximum demonstrated
crosswind value.
    The FAA has not prescribed a specific wind magnitude and direction
to be implemented in the gusting crosswind model requirements. The wind
gust models that will be provided by the FAA in guidance material were
designed to allow for tuning of the gust characteristics as needed for
the particular training scenarios (such as steady state wind conditions
and runway direction) and aircraft type being simulated. The tuning of
gust models should be conducted in consideration of the maximum
crosswind capabilities of the aircraft in order to provide
operationally realistic scenarios that are survivable in training. The
specific aircraft crosswind capabilities, to include the addition of
gust factors, are determined by the aircraft OEM. If this information
is not clear in the aircraft flight manual, the FSTD sponsor should
consult with the aircraft OEM. Additionally, the FSTD sponsor should
coordinate with the data provider to ensure that gust models do not
exceed the capabilities of the simulator's aerodynamic and ground
models. The FAA has added information material in Table A1A (entry no.
2.d.3) to the final rule for clarification.
4. Requirements for Previously Qualified FSTDs
    In the proposal, the updated ground handling and ground reaction
requirements in Table A1A included information that stated ``tests
required'' for these particular sections. The FAA notes that this text
was derived from the similar sections in the ICAO 9625 document as part
of the alignment process.
    Delta and A4A pointed out that the general requirement for gusting
crosswind (Table A1A, Entry No. 3.1.S in the NPRM) states ``tests
required'' and requested clarification if additional objective testing
is required under the FSTD Directive for previously qualified FSTDs.
    In the final rule, since the FAA restored the existing part 60
format for the general requirements table as compared to the ICAO
format in the proposal (including sections for ground reaction and
ground handling

characteristics), the text for ``tests required'' was removed from the
ground handling requirements in Table A1A, Entry No. 2.d.3. in the
final rule. No additional objective testing for ground reaction and
ground handling characteristics was intended for previously qualified
FSTDs in FSTD Directive No. 2. The FAA further notes that all required
objective testing is fully described in Table A2A, making any such
``tests required'' notations in the information column redundant.

E. Evaluation Requirements for Bounced Landing Recovery Training Tasks

    In the proposal, the FAA included updated FSTD evaluation
requirements for ground reaction characteristics to support the bounced
landing recovery training task that is required in the Crewmember and
Aircraft Dispatcher Training final rule. The new requirements included
ground reaction modeling to simulate the effects of a bounced or
skipped landing as well as the indications of a tail strike or
nosewheel exceedances as appropriate for the simulated aircraft and
conditions.
1. Applicability to Lower Level FSTDs
    In the proposal, the new requirements for bounced landing recovery
evaluation were included for Level C and Level D FSTDs in Appendix A as
well as for the new Level 7 FTD in Appendix B.
    TRU Simulation and A4A commented that the bounced landing
requirements were added for the Level 7 FTD and questioned whether it
was appropriate for this device.
    Given the Crewmember and Aircraft Dispatcher Training final rule
requirement that a Level C or higher FSTD be used to conduct bounced
landing recovery training tasks, the FAA has removed the additional
FSTD evaluation requirements in the final rule for bounced landing
recovery from the Level 7 FTD minimum requirements in Appendix B.
2. Bounced Landing Modeling and Evaluation
a. Nosewheel Exceedences
    As part of the bounced landing recovery requirements in the
proposal, the FAA included requirements to include indications of a
tail strike and nosewheel exceedances.
    Boeing commented that the requirement for ``nosewheel exceedances''
needs to be more clearly defined (e.g., limit, yield, or ultimate
loads) and suggested changing the rule text to read ``effects and
indications of ground contact. . .''. An anonymous commenter further
stated that calculation of structural loads on the nose gear is not a
common feature in current FSTDs. Any nose first landing is considered
abnormal and could be flagged on the IOS.
    The FAA agrees with the commenters and has removed the nosewheel
exceedances requirement from the final rule as it is not necessary to
accomplish the training objectives for bounced landing recovery
training tasks. This language was replaced with ``the effects and
indications of ground contact due to landing in an abnormal aircraft
attitude . . .'' since information on aircraft attitude during the
landing and go-around sequence will be more useful to the instructor in
evaluating bounced landing recovery training tasks.
b. Use of Existing Ground Reaction Modeling
    In the NPRM, the FAA proposed that ground reaction modeling must
simulate ``. . . the effects of a bounced or skipped landing (to
include indications of a tail strike or nosewheel exceedances) as
appropriate for the simulated aircraft and conditions''.
    Delta and A4A commented that the existing part 60 requires
verification of ground reaction and ground effects by minimum unstick
speed, ground effects, and takeoff and landing performance objective
tests. An SOC from the data provider and an affirmation that the model
has been implemented correctly should be adequate. There is no need for
additional subjective verification by a qualified pilot. A4A further
commented that at least one data provider has implied that their
current data and model meets the proposed requirements. CAE commented
that the strut system simulation (damper/spring) and its geometry are
already properly modeled and should provide the appropriate forces and
moments during a bounce.
    As described in the proposal, the FAA agrees with the commenters
that much of the aerodynamic and ground reaction modeling is currently
required and validated in several required objective tests for FSTD
qualification. As such, the FAA has not required any additional
objective testing for the qualification of bounced landing recovery
training tasks in this final rule. In order to support bounced landing
recovery training, the FSTD must have the ability to provide the
instructor with the effects and indications of ground contact as a
result of the FSTD being landed or conducting a go-around at an
improper aircraft attitude. In addition to pitch attitude information,
other parameters such as indications of nosewheel contact and
indications of a tailstrike would provide useful information to the
instructor in evaluating a bounced landing recovery maneuver. FAA
agrees with the commenters that the use of a qualified SME pilot to
evaluate these indications may be of limited value because they may not
have any direct experience in the indications of a tailstrike in the
airplane to base such an evaluation on. The FAA does recognize,
however, that a tailstrike and other indications of ground contact can
be computed in software using the geometric dimensions of the airplane
and these indications will provide the instructor with additional
feedback to assist in determining whether the aircraft landed in or a
go-around was attempted in an unusual aircraft attitude. These
indications and the ability of the modified FSTD to perform the
intended training tasks are what should be evaluated by the sponsor's
designated pilot as described in the FSTD Directive and Sec.
60.16(a)(1).
    The FAA has reviewed the current part 60 ground reaction and ground
handling requirements along with associated objective testing that are
already required for Level B through Level D FFSs and has determined
that adequate requirements already exist in part 60 to evaluate and
validate the aircraft dynamics necessary to support bounced landing
recovery training tasks.\27\ In order to improve the instructor's
evaluation of an abnormal aircraft attitude during the bounced landing
recovery maneuver, the FAA has amended the current ground reaction
requirement for Level B through Level D FFSs to include appropriate
effects during bounced or skipped landings, including the effects and
indications of ground contact due to landing in an abnormal aircraft
attitude.
---------------------------------------------------------------------------

    \27\ In addition to objective testing requirements for maneuvers
such as takeoff, landing, minimum unstick speed, and ground effect,
the current part 60 ground reaction general requirements (Table A1A,
Entry No. 2.d.2.) already requires ground reaction modeling that
generally supports bounced landing recovery training.
---------------------------------------------------------------------------

3. Alignment With Training Requirements
    As noted in the NPRM, the FSTD evaluation requirements for bounced
landing recovery maneuvers were introduced both to support new
requirements in the Crewmember and Aircraft Dispatcher Training final
rule as well as to address comments concerning potential deficiencies
in FSTD fidelity in this flight regime.
    An anonymous commenter stated that ``there is no bounced landing
training task listed in Table A1B (Table of Tasks v. Simulator Level).
It is agreed that a

Level D simulation should produce a bounced landing if appropriate,
however that does not translate into a training requirement. There is
currently no approved pilot training program that includes bounced
landing. At most, it could be a required demonstration element, but it
should not be a required training maneuver.''
    A4A commented that Boeing has already addressed the bounced landing
recognition and recovery procedure in their operating manuals and in
recurrent simulator training and that the FAA should review simulator
data it currently receives to determine if recurrent training programs
implemented due to the NTSB recommendations were effective. A4A and
JetBlue further commented that ``the training final rule limits new
training requirements to recovery from bounced landing because carrier
training programs currently include bounced landing training as
recommended in FAA's InFO 08029 . . . simulator modeling for this final
rule should be limited to enhancement to train recovery methods; it
should avoid introducing elements that might induce negative training
associated with `teaching to bounce'.'' In addition, CAE made similar
comments concerning the potential of a transfer of negative training in
introducing a bounced condition during landing.
    The FAA notes that bounced landing recovery is a training
requirement for air carriers under Sec.  121.423. While the minimum
qualified task list in Table A1B does not specifically list bounced
landing tasks, the final rule will require an amendment to the FSTD's
SOQ that the FSTD has been evaluated for bounced landing recovery
training tasks. As addressed in the Crewmember and Aircraft Dispatcher
Training final rule, the FAA is aware of the incorporation of bounced
landing recovery training by operators in response to the FAA's InFO
and SAFO bulletins. To support the new training requirements in Sec.
121.423 for bounced landing recovery training, the FSTD qualification
standards were revised in this rule to ensure the FSTDs used to conduct
such training have been properly evaluated for the training tasks.
    The FAA agrees with commenters in that the purpose of bounced
landing recovery training is to train bounced landing recovery methods
and not to teach a pilot how to bounce the aircraft. While the
simulation should support the ability to reproduce a bounce where the
flight conditions dictate, the primary objective of training is to
train recovery techniques should the landing result in an inadvertent
bounce. The FAA agrees with the commenters in that these recovery
techniques can be taught without stimulating an actual bounce during
the landing sequence and rather ``calling a bounce'' to initiate the
recovery maneuver. The FAA has amended the final rule to emphasize that
the FSTD evaluation requirements are on the aircraft dynamics resulting
from the bounced landing recovery and not in stimulating a bounce
during the landing sequence.
    The FAA further emphasizes that the FSTD evaluation requirements in
the final rule that support bounced landing recovery training tasks are
essentially a consolidation of existing requirements within part 60
\28\ and will further support the instructor evaluation of other
landing training tasks where the simulator may be inadvertently landed
in an abnormal aircraft attitude.
---------------------------------------------------------------------------

    \28\ See 14 CFR part 60 (2008), Appendix A: Table A1A, Entry No.
2.d.2 (ground reaction modeling); and Table A3D (motion system
effects), Entry no. 7 (main and nose gear touchdown cues), and Entry
No. 13 (tail strikes and engine pod strikes).
---------------------------------------------------------------------------

4. Requirements for Previously Qualified FSTDs
    Delta, FlightSafety, and A4A pointed out that the general
requirement for ground reaction modeling (Table A1A, Entry No. 3.1.S in
the NPRM) states ``tests required'' and requested clarification if
additional objective testing is required under the FSTD Directive for
previously qualified FSTDs.
    In the final rule, since the FAA restored the existing part 60
format for the general requirements table as compared to the ICAO
format in the proposal (including sections for ground reaction and
ground handling characteristics), the text for ``tests required'' was
removed from the ground reaction requirements in Table A1A, Entry No.
2.d.2. No additional objective testing for ground reaction and ground
handling characteristics was intended for previously qualified FSTDs in
FSTD Directive No. 2. The FAA further notes that all required objective
testing is fully described in Table A2A, making any such ``tests
required'' notations in the information column redundant.

F. Alignment With the ICAO 9625 International FSTD Evaluation Document

    In order to promote harmonization of FSTD evaluation standards with
that of other national aviation authorities, the FAA proposed alignment
of the part 60 Qualification Performance Standards (QPS) with the
latest international FSTD evaluation guidance in the ICAO 9625, Edition
3, document. Unlike previous alignment efforts the FAA undertook with
earlier versions of the ICAO 9625 document that only contained one
level of FSTD, this alignment effort proved to be more complex because
the Edition 3 document contained many other FSTD levels that do not
share an equivalent fidelity level in part 60 and other FAA training
regulations and guidance material. Furthermore, since the main purpose
of this rulemaking was to define new FSTD evaluation standards for new
training tasks introduced by the Crewmember and Aircraft Dispatcher
Training final rule, practical time limits prevented the FAA from
conducting the significant updates to other regulations and guidance
material to support a complete change in the existing hierarchy of FSTD
levels. For these reasons, a full alignment with all of the FSTD levels
in the ICAO 9625 document was not proposed with this rulemaking and
only portions of the technical guidance material from ICAO were
incorporated where practical.
1. Partial Alignment With the ICAO 9625 Document
    For reasons cited above, the FAA did not propose complete alignment
with ICAO 9625, Edition 3. In lieu of conducting a full alignment, the
FAA proposed partial alignment with the ICAO document where significant
overlap existed between the FAA FSTD fidelity levels in the part 60 QPS
and the ICAO document. This included alignment of the part 60 Level C
and D FFS evaluation standards with that of the highest level of ICAO
device (the Type VII device) as well as adding a new Level 7 FTD to
align with the ICAO Type V device.
    FAA received several general comments concerning the proposed
partial alignment with the ICAO 9625 FSTD evaluation guidance document.
A4A commented that the ``incorporation of 9625 is not required to meet
Sec. Sec.  121.423 and 121.434. We are not opposed to harmonizing part
60 with the international standards but this piecemeal approach to
incorporating the ICAO STD does not provide additional benefits for
flight training''. A4A further stated that ``the FAA should consider
incorporating ICAO 9625 as the standard for flight training in its
entirety. Until this approach for part 121 training can be adopted,
incorporating pieces of the standard into part 60 is only providing
additional burden without benefit.'' American and Alaska Airlines made
similar comments that there is no training value in adopting the ICAO
standard as presented and recommended that the FAA should not adopt the
ICAO standard unless doing so in its entirety. ALPA generally

supported the incorporation of the ICAO 9625 guidance into part 60, but
expressed concern regarding the introduction of a fixed-base (non-
motion) FTD for flightcrew training. Also, ICAO generally supported the
incorporation of the ICAO 9625 document and further noted that the
fourth edition of the ICAO 9625 document was recently published on the
ICAO internet site for regulatory authorities.
    The FAA notes that the primary purpose of this rulemaking was to
update the FSTD evaluation standards to address the new extended
envelope training introduced by the Crewmember and Aircraft Dispatcher
Training final rule. Because the FAA and industry were integrally
involved in the development of the ICAO 9625 FSTD evaluation guidance
material, and much of the current part 60 and grandfathered FSTD
standards are based upon previous versions of the ICAO 9625 document,
the FAA proposed updating the current part 60 standard for certain FSTD
levels that overlapped with similar FSTD levels defined in the ICAO
9625 document. Unlike previous versions of the ICAO 9625 document, ICAO
9625, Edition 3, introduced several new FSTD levels that have no direct
equivalent in the part 60 rule. Because of the time critical nature of
the extended envelope training requirements, it was determined that
redefining all of the FAA FSTD levels to align with the ICAO document
would not be practical because of the numerous other training rules and
guidance material that would be affected if we made significant changes
to the part 60 qualification standards and FSTD level definitions.
    The benefits of general ICAO alignment are not readily quantifiable
since they primarily focus on improving the overall simulation
environment and not on specific safety issues. From an international
harmonization standpoint, FSTD manufacturers and data providers can
benefit from developing FSTDs and supporting data packages that meet a
single internationally recognized standard. Despite statements made by
one commenter concerning ``illusory benefits from internationally
aligned FSTD standards,'' the FAA believes there is anecdotal evidence
that supports the benefits of international harmonization. Based upon
past experience with the previous international alignment efforts, the
FAA points out that over 250 FSTDs (including FSTDs qualified by A4A
air carriers) were voluntarily qualified against the more stringent
ICAO 9625, Edition 2, JAR-STD 1A, Amendment 3,\29\ and Draft AC 120-40C
internationally harmonized standards during the 1995 to 2008 timeframe
before part 60 became effective in 2008.
---------------------------------------------------------------------------

    \29\ JAR-STD 1A was a publication by the Joint Aviation
Authorities that provided FSTD qualification standards for European
countries.
---------------------------------------------------------------------------

    Due to the time critical nature of the extended envelope training
requirements, complete alignment with the ICAO 9625 document was not
considered in this rulemaking. Most of the device levels defined in
ICAO are not within the scope of part 60 (all but two FSTD levels in
ICAO 9625 are for generic or representative devices that are not
defined in part 60) and would require significant rulemaking and policy
changes outside of part 60 to address a new hierarchy of device levels.
The FAA considers the ICAO alignment conducted in this rulemaking as a
significant step in maintaining harmonization with the international
FSTD evaluation standards and will continue to look for opportunities
to further expand the alignment with the ICAO 9625 document where
practical.
2. New Requirements Introduced by the Proposed ICAO Alignment
    Several commenters pointed out that some of the new requirements
introduced in the proposed ICAO 9625 alignment would add to the cost of
a new Level C or Level D FFS with no demonstrated value to training.
The FAA partially agrees with the commenters in that it is difficult to
quantify specific safety benefits from some of the new and updated
standards introduced as a result of the ICAO alignment. Most of these
changes in the ICAO alignment target the improvement of objective
testing tolerances, the incorporation of testing requirements for new
technology that is not currently addressed in the simulator standards,
and improvement of the overall simulation environment.
a. Visual System Field of View
    A4A, JetBlue, Delta, and an anonymous commenter stated that the
increased visual system field of view requirement from 180 degree x 40
degree in the existing part 60 general requirements to 200 degree x 40
degree in the proposal would introduce significant cost to a new
simulator and has no demonstrated benefit to crew training. In
addition, A4A and JetBlue further commented that the justification for
this proposal is harmonizing with ICAO standards; there is no statutory
or regulatory requirement or NTSB recommendation on this topic. The
increased field of view for newly qualified FSTDs does not demonstrate
any improved training value; the existing field of view has been used
successfully in training programs worldwide for well over a decade.
Increasing the field by 10 degrees on each side would add no value in
taxiing or on the circling approach and there is no data or industry
trend to indicate that pilots are experiencing difficulty performing
these maneuvers using the current systems. Most part 121 air carriers
train to Visual Flight Rules (VFR) minimums for a circling approach and
in fact most flight schools that offer Airline Transport Pilot
qualification courses now require only demonstration at a VFR level. A
simulator field of view expansion to 200 degrees would not change
practices at other facilities.
    Concerning the cost of this new requirement, A4A further commented
that the expense associated with this field of view expansion would add
an estimated 20 to 30 percent to the cost of a visual system for the
purchasing of a newly qualified FSTD, depending on the manufacturer. In
most cases this would require the addition of at least one and possibly
two image generators, very similar to helicopter simulators. In
addition, changing the field of view standard for newly qualified FSTDs
will prevent carriers from obtaining existing simulators that reside
outside the United States (U.S.) that have a 180 degree field of view,
and have not yet been qualified in the U.S. This would force carriers
to purchase new simulators instead of purchasing used simulators; it
will cost more and impose less efficient training options.
    The FAA concurs with the commenters in that little evidence
suggests that increasing the visual system field of view requirements
to 200 degrees (horizontal) will have a quantifiable safety benefit. In
order to avoid incurring significant additional cost as a result of the
ICAO 9625 alignment as identified by the commenters, the visual system
field of view requirements will remain at the existing part 60
requirement of 180 degrees x 40 degrees for Level C and Level D FFSs in
the final rule.
b. Visual System Lightpoint Brightness Testing
    In the NPRM, the FAA proposed the addition of a new objective
visual lightpoint brightness test as part of the ICAO 9625 alignment.
The addition of this test addresses inherent system limitations in
fixed matrix visual display systems (such as LCD systems) and their
ability to display lightpoints as compared to older calligraphic
display systems. American, A4A, and an

anonymous commenter stated that the tolerance for this test should be
reduced from the 8.8 foot-lamberts as proposed in the NPRM to 5.8 foot-
lamberts as proposed in the updated ICAO 9625, Edition 4, document
because it has no technical advantage and is not achievable with
current technology over long periods of time. CAE further stated that
this requirement cannot currently be met with light emitting diode
(LED) based visual projectors and this issue has been subsequently
addressed in ICAO 9625, Edition 4. Similar comments were made by TRU
Simulation. Frasca commented that, with regards to the surface
brightness test, a modern display system cannot boost the brightness
for light points only. If the system just meets the display brightness
requirement, it will not pass the light point brightness requirement.
This would only be possible using calligraphic projectors, which are no
longer in regular use for simulation.
    The FAA concurs with the commenters and has reviewed the updated
ICAO 9625, Edition 4, document as suggested. In that document, the
light point brightness test tolerance has been amended to be less
restrictive (5.8 foot-lamberts) as compared to the Edition 3 document
due to the inherent limitations of solid state illuminators (such as
LEDs). In these types of systems, the benefit of improved temporal
stability justifies the inherently lower brightness that an LED can
produce as compared to a standard lamp illuminator. To support the
alignment of the part 60 technical requirements with the ICAO document,
as well as to address the commenters concerns, the FAA has amended this
objective test (Table A2A and Table B2A, Entry No. 4.a.7.) in the final
rule as recommended by the commenters.
c. Transport Delay Testing
    In the NPRM, the FAA proposed to reduce the transport delay
tolerances from150 millisecond (ms) to a more restrictive 100 ms
tolerance for the purposes of aligning with ICAO 9625, Edition 3 as
well as improving the overall simulation environment with faster
simulation induced response times. The FAA received many comments on
this issue which generally recommended that the FAA should not adopt
these tighter tolerances. Boeing, FedEx, Delta, A4A, and American
commented that while ICAO 9625 Edition 3 recommends a more restrictive
tolerance than what is currently in part 60, there appears to be no
evidence that timing below 150 ms provides better crew training. Boeing
further commented that those values have been hard to achieve in
industry, costing substantial amounts of money to meet this
requirement. A4A further commented that ``the FAA should not change the
transport delay standard because there have been no reports of pilot
induced oscillation due to a throughput (transport) delay tolerance
being too high. The current transport delay tolerance of 150 ms has
proven to be adequate for all Level D FFSs with no known problems to
date. The tolerance has no impact on safety and is a technical
limitation of the software and hardware. Carriers have operated with
the 150 ms for decades with no measurable degradation in training. In
addition, the ICAO standard is being revised and will change in 2015;
an FAA change to 100 ms will result in misaligned U.S. and ICAO
standards starting next year. Therefore, to require adjustment of the
delay to 100 ms would provide no additional benefit to pilot training
and it is recommended that 150 ms tolerance be retained.'' Frasca,
American, Boeing, and CAE made similar comments concerning the less
restrictive 120 ms tolerance that has been amended in ICAO 9625,
Edition 4.
    While the FAA would concur that it is difficult to quantify
transfer of training benefits with transport delay tolerances reduced
to lower than 150 ms, it has been well established through multiple
research studies that transport delay in simulation can significantly
affect pilot performance. The FAA maintains that the proposed 100 ms
tolerance is not a significant technical limitation of simulators and
has, in fact, been a minimum FSTD qualification requirement for
helicopter simulators since 1994.\30\ Furthermore, the FAA conducted a
random sampling of currently qualified FSTDs that were initially
evaluated within the past 10 years and found that 44 percent of these
FSTDs would have met the ICAO 9625, Edition 3, tolerance of 100 ms and
83 percent of these FSTDs would have met the ICAO 9625, Edition 4,
tolerances (100 ms for motion/instrument and 120 ms for visual system
response) with no modification.\31\ These numbers generally support the
commenters' concerns that the 100 ms transport delay tolerance in the
NPRM may not be easily attainable with current technology that is
implemented on previously qualified fixed wing FSTDs.
---------------------------------------------------------------------------

    \30\ See Advisory Circular (AC) 120-63, ``Helicopter Simulator
Qualification'' (1994); Appendix 2, test 5.a.; and 14 CFR part 60
(2008), Appendix C, Table C2A, test 4.a.2.
    \31\ The FAA conducted a random sampling of transport delay test
results from the Master Qualification Test Guides (MQTGs) of 18
currently qualified FSTDs that were initially evaluated within the
past 10 years. Eight out the 18 FSTDs would have met the 100 ms
transport delay tolerance for all axes. Fifteen of the 18 FSTDs
would have met the 100/120 ms tolerance.
---------------------------------------------------------------------------

    To address these concerns and to maintain consistency with the
international guidance material, the FAA has amended the final rule to
incorporate the updated ICAO 9625, Edition 4, transport delay
tolerances of 100 ms for motion system/instrument response and 120 ms
for visual system response as recommended by many commenters.
d. Objective Motion Cueing Fidelity Test
    As part of the ICAO 9625 alignment proposed in the NPRM, the FAA
included objective motion cueing fidelity testing (OMCT) as a minimum
requirement for FSTD qualification.
    The FAA received several comments on the adoption of the ICAO 9625
OMCT test. American commented that the OMCT in the ICAO 9625 document
is still a work in progress with some testing details that are still
under consideration as more experience is gained with conducting the
test. American further questioned what source data was used to define
the motion fidelity tolerances that are associated with the test as
well as the lack of a time-domain test that was supposed to complement
the frequency-domain test in the ICAO document. Additionally, American
stated that the purpose of including an incomplete set of tests in the
ICAO standard is to collect data and that a final rule is not
appropriate vehicle to `gather data'. Finally, American recommended
against replacing the existing motion cueing signature (MCPS) tests
with the OMCT, however, if it were to be adopted in the final rule, it
should be limited to an SOC issued by the training device manufacturer
stating compliance. A4A and JetBlue made similar comments opposing the
adoption of the proposed OMCT.
    The FAA agrees that the proposed OMCT from ICAO 9625, Edition 3,
primarily consisted of a testing method with no specific fidelity
standard applied to the test results. The FAA further notes that the
recently published ICAO 9625, Edition 4, document has improved the OMCT
method and has added recommended tolerances to the test results that
were based upon ``. . . the statistical results of reliable OMCT
measurements of eight Level D or Type VII FSTDs.'' The FAA maintains
that a significant weakness in today's FSTD evaluation standards is the
lack of a consistent method to measure and apply motion cueing in crew
training

simulators. An industry-led group developed the objective motion cueing
test, and it represents a marked improvement over today's subjective-
only assessments. While the FAA concurs that a specific fidelity
requirement needs development, applying the OMCT and comparing the
results against representative responses will promote useful
standardization and improvement of overall motion cueing.
    To address the commenters concerns, the FAA has amended the final
rule so as to not require OMCT results in the MQTG for annual
continuing qualification evaluation purposes. Instead, OMCT results
will only be required once during the initial qualification of the FSTD
and included in an SOC from the FSTD manufacturer. Furthermore, the FAA
will not require a specific tolerance to be met for this test and only
require that the FSTD manufacturer use the OMCT to document the overall
performance of the motion system and use its results to aid in the
tuning of the motion cueing algorithms. Finally, because the technical
details of this testing method are multifaceted and not suitable for
inclusion in the final rule's text, the FAA will issue guidance
material with the final rule on how to apply the OMCT to meet the part
60 requirements.
e. Sound Directionality Requirement
    A4A commented that the directional sound requirements (incorporated
from the ICAO 9625 document) are not cost/benefit justified and are not
required to meet any existing or proposed training requirement.
    The FAA notes that the requirement for ``sound directionality'' was
introduced as part of the ICAO 9625 alignment proposed in the NPRM.\32\
After review of this requirement, the FAA will maintain the proposed
requirement in the final rule. FAA has found that it is essentially a
codification of existing practice where FSTDs are subjectively
evaluated for flight maneuvers, including engine failures and other
malfunctions, which would result in directionally representative sound
cueing in the FSTD. FAA further notes that the accident record has
documented instances where flight crews have inadvertently shut down
the wrong engine while diagnosing an engine malfunction in flight. This
additional sound cueing in the simulator may enhance training in
recognizing and verifying the cues of an actual engine failure in
flight.
---------------------------------------------------------------------------

    \32\ ICAO 9625 (Edition 3), Part II, Appendix A, section 6.5.R
requires that ``sound should be directionally representative.''
---------------------------------------------------------------------------

3. Alignment With the Recently Published ICAO 9625, Edition 4, Document
    Concurrent with the development of the part 60 NPRM, an
international working group was convened to review and update the ICAO
9625, Edition 3, document to incorporate FSTD evaluation requirements
to address full stall training, UPRT, and icing. This working group was
essentially operating in parallel with the part 60 rulemaking effort
and used a similar set of recommendations issued from the ICATEE
working group to incorporate FSTD evaluation standards into the ICAO
9625 document. In addition to the changes made to support UPRT and
stall evaluation, this working group also made general changes to the
ICAO 9625 document that addressed known issues with the Edition 3
document. These included changes that addressed technological
improvements, changes that updated various test tolerances which were
relieving in nature, as well as editorial changes to correct or clarify
the requirements in the Edition 3 document. Since the FAA proposed
alignment with ICAO 9625, Edition 3, many of the known issues
identified with that document were also present in the NPRM.
    The FAA received several comments, including various comments from
A4A, Boeing, CAE, Frasca, ICAO, and TRU Simulation that recommended the
use of the draft ICAO 9625, Edition 4, document in order to correct
specific problems introduced from ICAO 9625, Edition 3, into the NPRM.
Several commenters also recommended aligning the FAA requirements for
the extended envelope training tasks with that of the updated ICAO
document. Many of these comments have been discussed in previous
sections of this document.
    Since the publication of the NPRM and subsequent close of the
comment period, ICAO has published the final version of the ICAO 9625,
Edition 4, document. The FAA has reviewed its contents for potential
incorporation of the changes into the final rule as recommended by
several commenters and has found that the changes made to the ICAO
document in the Edition 4 release were relatively limited in scope and
have some overlap with the requirements published in the NPRM in the
following areas:
    1. Introduced ``extended envelope'' FSTD evaluation requirements
for full stall, UPRT, and airframe icing.
    2. Changes to testing requirements and tolerances to improve and
correct issues in ICAO 9625, Edition 3, including transport delay
testing tolerances, visual lightpoint brightness tolerances, objective
motion cueing testing tolerances, and other changes that were generally
less restrictive.
    3. Other editorial and technical changes to improve the document
and clarify existing requirements.
    The FAA agrees with the commenters that alignment with the latest
edition of the ICAO 9625 document would be desirable, particularly with
evaluation requirements that have been found to be problematic in ICAO
9625, Edition 3. The FAA has incorporated many of these changes into
the final rule; however, some differences were maintained to address
public comments to the NPRM, as well as to address FAA specific
training requirements and FSTD grandfathering rights. Where the more
restrictive requirements were introduced in ICAO 9625, Edition 4, that
were not included in the NPRM for public comment, the FAA included
these in the final rule within non-regulatory ``information'' sections
as recommended practices. The following table summarizes the sections
that were modified in the final rule to incorporate changes made in
ICAO 9625, Edition 4:

----------------------------------------------------------------------------------------------------------------
                Change                    ICAO 9625  Section     Final rule  entry No.           Comments
----------------------------------------------------------------------------------------------------------------
                                              General Requirements
----------------------------------------------------------------------------------------------------------------
                                           Appendix A (ICAO)/Table A1A
----------------------------------------------------------------------------------------------------------------
Icing effects........................  2.1.S.e................  2.j....................  Alignment of language
                                                                                with the equivalent
                                                                                ICAO section.

High Angle of Attack Modeling........  2.1.S.f................  2.m....................  Alignment of language
                                       2.1.S.g................                            with the equivalent
                                                                                ICAO section.
Stick Pusher Systems.................  5.1.S.b................  3.f....................  Alignment of language
                                                                                with the equivalent
                                                                                ICAO section.
Stall Buffet Sounds..................  6.1.R..................  7.c....................  Added to information
                                                                                column as recommended
                                                                                practice.
Stall Buffet Motion Effects..........  8.3.R(8)...............  5.e.1..................  Added to information
(Buffet as first indication of stall                                                      column as recommended
 or lack of stall buffet).                                                                practice.
Stall Buffet Amplitude and Frequency   8.4.R(5)...............  8. (Table A3D).........  Added to information
 Content.                                                                                column as recommended
                                                                                practice.
UPRT.................................  13.2.1.S...............  2.n....................  Alignment of language
                                       13.2.2.S...............                            with the equivalent
                                                                                ICAO section.
Transport Delay......................  13.8.S.................  2.g.2..................  Updates transport delay
                                                                                tolerance to less
                                                                                restrictive values.
----------------------------------------------------------------------------------------------------------------
                                                Objective Testing
----------------------------------------------------------------------------------------------------------------
                                           Appendix B (ICAO)/Table A2A
----------------------------------------------------------------------------------------------------------------
Static Flight Control Checks.........  2.a....................  2.a....................  Moved test description
                                                                                text to ensure it is
                                                                                not improperly applied
                                                                                to dynamic control
                                                                                checks.
Stick Pusher Calibration.............  2.a.10.................  2.a.10.................  Alignment with
                                                                                equivalent ICAO test.
Stall Characteristics................  2.c.8.a................  2.c.8.a................  Alignment with
                                                                                equivalent ICAO test.
Approach to Stall Characteristics....  2.c.8.b................  2.c.8.b................  Alignment with
                                                                                equivalent ICAO test.
Engine and Airframe icing effects      2.i....................  2.i....................  Alignment with
 demonstrations.                                                                          equivalent ICAO test.
Stall Buffet.........................  3.f.5..................  3.f.5..................  Alignment with
                                                                                equivalent ICAO test.
                                                                                (FAA retained three
                                                                                test conditions).
Visual Lightpoint Brightness.........  4.a.7..................  4.a.7..................  Updates tolerance to
                                                                                less restrictive
                                                                                value.
Transport Delay......................  6.a.1..................  6.a.1..................  Updates tolerance to
                                                                                less restrictive
                                                                                value.
----------------------------------------------------------------------------------------------------------------
                                                      Other
----------------------------------------------------------------------------------------------------------------
Visual Model--Airport Clutter........  2.a.12.c (Appendix C)..  2.a.12.c (Table A3B)...  Specific ``gate
                                                                                clutter'' requirement
                                                                                changed to ``airport
                                                                                clutter''.
Additional FSTD Evaluations            Attachment P...........  Attachment 7 (Appendix   Alignment with
 Requirements for Stall, Upset                                   A).                      equivalent ICAO
 Recovery, and Icing.                                                                     language.
----------------------------------------------------------------------------------------------------------------

4. Integration of ICAO Requirements With the Part 60 Table Structure
    The FAA received several comments concerning the integration of the
ICAO requirements within the tables of the part 60 QPS appendices.
Several commenters pointed out that while there were requirements
introduced into the tables for the purpose of aligning with the ICAO
equivalent FSTD levels, many of these requirements were carried over to
lower level FSTDs that were not specifically targeted in the alignment
(e.g., Level A and Level B FFSs that do not have an ICAO equivalent
device). These differences were most apparent in the general
requirements tables (Table A1A and Table B1A) where the ICAO format,
language, and numbering system significantly differs from the existing
part 60 format. Additionally, A4A commented that the incorporation of
the ICAO format extends the overall structure of the document, is not
value added, and creates repeated requirements.
    The FAA agrees with the commenters in that the integration of the
ICAO numbering system into some of the part 60 tables resulted in some
overlapping requirements with FSTD levels that were not subject to the
alignment. The main reason for this overlap was to avoid the addition
of redundant table entries for the aligned Level C and Level D devices
and the non-aligned Level A and Level B devices in cases where they
substantially share the same requirement. Other changes were carried
over to the Level A and Level B requirements simply because the
requirements represented existing practice, and the FAA found it
unlikely that a new FSTD would be initially qualified that could not
meet these requirements. For example, one commenter noted that the
requirement in Table A3B for taxiway edge lights to be of a correct
color was a new requirement introduced for a Level A and Level B FFS.
While this is a new requirement as compared to the current part 60, the
FAA finds it very unlikely that any new FSTD would be initially
qualified with a visual display system that could not produce taxiway
edge lights of the correct color.
    To address the commenters concerns as well as to reduce the overall
complexity of the general requirements tables, the FAA has reverted
back to the existing part 60 structure and format in the final rule for
the general requirements tables in Appendix A and Appendix B (Tables
A1A and A1B). Where specific changes were proposed in the ICAO
alignment process, corresponding changes were made to the existing
sections within the current part 60 general requirements tables for the
appropriate FSTD levels. This will eliminate unintentional carryover of
requirements into the other FSTD levels that were not subject to the
proposed ICAO alignment.
    Additionally, the FAA has examined other tables impacted by the
ICAO alignment and has corrected other specific testing requirements as
identified by the commenters that were unintentionally carried over to
FSTD levels not subject to the ICAO alignment.
    Finally, to address comments concerning the integration of the
functions and subjective testing tables for all FTD levels in Appendix
B, the FAA has separated the Level 7 FTD requirements into different
tables and

restored the functions and subjective testing tables for Levels 4, 5,
and 6 FTDs back to their original format and contents in the final
rule. This change will address commenters concerns and provide a clear
distinction between the new Level 7 FTD requirements and the other FTD
levels. The reorganized tables will be renumbered as follows in the
final rule:
Tables of Functions and Subjective Testing
Table B3A (Level 6 FTD)
Table B3B (Level 5 FTD)
Table B3C (Level 4 FTD)
Table B3D (Level 7 FTD)
Level 7 FTD Specific Tables
Table B3E (Airport Modeling Requirements)
Table B3F (Sound System)
Table B3G (IOS Requirements)
5. Deviation From the Part 60 QPS Using the ICAO 9625 Document
    CAE commented that the FAA should ``consider the adoption of the
ICAO 9625 document technical standards through Incorporation by
Reference as allowed by statute and in accordance with 1 CFR part 51,
and allow for the qualification of devices using the ICAO technical
standard as an Alternate Means of Compliance (AMOC).'' An individual
commenter recommended that since the ``fast track'' process for part 60
QPS revisions has never come to fruition, the FAA should conduct
separate rulemaking to remove the part 60 QPS appendices and replace
them with an industry consensus standard.
    The FAA notes that due to the high level of interest in this
rulemaking with regards to supporting other significant rulemaking work
and Public Law, it was determined that it would not be appropriate for
the FAA to use the streamlined process as described by the commenter
\33\ and this particular part 60 rulemaking would have to proceed in
accordance with the agency's normal rulemaking procedures. While the
FAA agrees with the commenter that using a voluntary consensus standard
may allow for faster changes to the FSTD evaluation standards, the
incorporation of a consensus standard would be outside of the scope of
this rulemaking. The FAA will consider this topic for future rulemaking
as suggested by the commenter.
---------------------------------------------------------------------------

    \33\ This streamlined process delegates the authority for final
review and issuance of the part 60 QPS documents from the FAA
Administrator to the Director of the Flight Standards Service (see
71 FR 63392).
---------------------------------------------------------------------------

    Regarding CAE's comment concerning the use of the ICAO 9625
document as an AMOC to the part 60 standards, the FAA agrees that
allowing the use of other technical FSTD evaluation standards (such as
ICAO 9625 or other FSTD evaluation standards issued by a national
aviation authority) to initially qualify a new FSTD may allow for a
more refined approach to incorporating future changes to the FSTD
technical standards. The FAA agrees that where updated internationally
recognized FSTD evaluation standards have been published and have been
determined to provide an equivalent or higher level of safety (e.g.
does not adversely impact the fidelity of the device) as compared to
the part 60 standards, the voluntary use of these standards to
initially qualify new FSTDs should be considered. Particularly with
updates to the ICAO 9625 document, deliberations on changes to this
document are conducted through international working groups with
representation from many sectors of the training and simulation
industry, including FSTD manufacturers, air carriers, training
providers, aircraft manufacturers, government agencies, and other
organizations. In addition to making changes to the FSTD evaluation
standards that address safety related issues, other changes are made to
improve the overall FSTD evaluation process, as well as addressing new
simulation and aircraft technology that has not been adequately
addressed in the existing standards.
    Furthermore, the ability for the FAA to recognize equivalent FSTD
evaluation standards issued by ICAO and national aviation authorities
will support the qualification of FSTDs located in other countries and
promote existing bilateral agreements which may result in cost savings
for FSTD sponsors, manufacturers, and data providers. Particularly with
FSTDs that are qualified by multiple national aviation authorities, the
ability to recognize an equivalent international standard can reduce
redundant testing requirements and documentation that would otherwise
be needed to demonstrate compliance with multiple international
standards. The FAA additionally points out that a similar process was
successfully used prior to the initial publication of part 60 in 2008
where over 250 FSTDs were initially qualified on a voluntary basis
using updated international FSTD evaluation standards (including ICAO
and European FSTD evaluation standards) in lieu of the then current FAA
evaluation standards in Advisory Circular (AC) 120-40B.
    Where such new and updated standards are available, potential
safety benefits, as well as cost savings, can be quickly realized
through the recognition of new standards ahead of the formal rulemaking
process. As with most of the past updates to the international
standards, there are significant delays of months and even years in
integrating updated ICAO standards into regulation. This results in a
continuous lag between advances in simulation technology and the
regulatory standards.
    In order for the agency to be more responsive to changes in the
international FSTD evaluation criteria as well as to provide additional
options to sponsors of FSTDs that are qualified by multiple national
aviation authorities, the FAA has included deviation authority in Sec.
60.15(c) of the final rule to accept FSTD evaluation standards (such as
ICAO 9625 or other FSTD evaluation standards issued by a national
aviation authority). Such deviations must demonstrate that there will
be no adverse impact to the fidelity or the capabilities of the FSTD as
compared to the part 60 QPS. Deviations may be granted to an FSTD
sponsor or to an FSTD manufacturer for application on multiple FSTDs.
Where an FSTD has been initially qualified under the deviation
authority, the evaluation standard will become a part of the FSTD's
permanent qualification basis and recorded in the FSTD's MQTG and SOQ.
The FAA will issue guidance material with this final rule in the form
of an NSP guidance bulletin that explains the process for submitting
and reviewing deviation requests under Sec.  60.15(c).
6. Level 7 FTD Requirements and Usage in Training
    As part of the ICAO 9625 alignment process, the FAA introduced a
new FSTD level to the fixed wing FSTD evaluation standards in the NPRM.
This FSTD level was based upon the ICAO 9625 Type V device and was
intended to define requirements for a high fidelity, fixed-base FTD
that could be used to conduct additional introductory training tasks
beyond what the Level 6 FTD is currently qualified to do. Furthermore,
the addition of this FTD level to the fixed wing standards in part 60
Appendix B would align with the current Level 7 helicopter FTD
evaluation requirements that are already in Appendix D of part 60.
    Boeing commented that the Level 7 FTD requirements exceed those for
Level A and Level B FFSs. The Level 7 FTD will offer no additional
training credit and appears to have no additional benefit to the
industry. CAE further commented that while the Level 7 FTD is
introduced and is based upon the ICAO Type V device, the applicable

flight crew licensing regulations should include provisions for
training credits for this device.
    The FAA notes that the corresponding ``Tasks vs. Simulator/FTD
Level'' tables (Tables A1A and B1B) define the particular tasks that a
particular FSTD level is qualified to conduct. Table B1B was updated in
the NPRM to include the Level 7 FTD and adds several tasks that Level A
and Level B FFSs are not currently qualified to conduct. The addition
of this FSTD level was based upon the ICAO recommendations to create a
high fidelity, fixed-base FTD in which introductory training could be
conducted in lieu of a higher cost FFS. The part 60 FSTD qualification
standards do not currently define such a high fidelity FTD \34\ and the
addition of the Level 7 FTD fills this gap. The FAA agrees with Boeing
and CAE in that the FSTD qualification standards do not fully address
the allowable training credit for this new FTD level and the FAA is
currently reviewing supporting training guidance material to make
corresponding updates to address this new FSTD level.
---------------------------------------------------------------------------

    \34\ The current Level 6 FTD as defined in part 60 is not
validated for most ground maneuvers (including takeoff and landing
tasks) and does not require a visual system.
---------------------------------------------------------------------------

    Furthermore, the FAA notes that a similar device level was
introduced for helicopter training (a helicopter Level 7 FTD) with the
initial publication of part 60 in 2008. The FAA has qualified several
of these Level 7 helicopter FTDs since the initial publication of part
60 and these devices continue to be used within operator's training
programs.
    ALPA commented that while they support the incorporation of the
ICAO 9625, Edition 3, guidance, they are concerned with the intention
to increase use of non-motion devices at the expense of more realistic
training in higher fidelity devices with motion. In addition, ALPA
stated that they are ``concerned with the stated rationale for adopting
the ICAO Doc 9625, Edition 3 Type V simulator guidance. The NPRM
indicates this guidance will be used to introduce a new Level VII
simulator for the purposes of increasing the opportunities to utilize
fixed base, non-motion simulators. Some use of fixed based simulators
is appropriate. However, the higher the simulator fidelity is, and the
more realistic the training environment is, the better the transfer of
learning to actual flight will be.''
    ALPA went on to state that the ``highest-level flight simulators
need to be used to the maximum extent possible. It is imperative that
all end-level evaluations be conducted in full flight simulators (FFS)
with six degree of freedom motion cues. Maneuver-based validation
points required by airline-specific AQP documentation must be conducted
in a FFS with six degree of freedom motion cues also. In addition,
these FFSs should be used extensively in advance of evaluations and
validation points to provide significant opportunity to prepare.''
    The FAA notes that the concept of the Level 7 FTD was based
primarily upon the recommendations made in the ICAO 9625 document. In
this document, through the work of an industry and government working
group, it was determined that the introduction of many training tasks
could be conducted in a high fidelity, fixed-base FTD where the
continuation and completion of that training task (training to
proficiency) is conducted in a FFS with motion cueing. The FAA shares
the commenter's concerns regarding the use of FFSs for end-level
evaluations and in advance of evaluations and validations points. In
the proposal, the FAA attempted to capture this ICAO concept in the
``Table of Tasks v. FTD Level'' (Table B1B), which defines the minimum
qualified tasks for a specific FSTD level. The FAA has made additional
amendments in the final rule to better define the differences in
``training'' and ``training to proficiency'' in Table B1B to maintain
consistency with ICAO 9625.
    Finally, the FAA notes that the part 60 FSTD qualification
standards only define what training tasks an FSTD is qualified to
conduct and does not define how the FSTD will be approved for use in a
training program. The FAA is currently reviewing supporting training
guidance material and will take these comments into consideration when
making corresponding updates to address this new FSTD level.

G. General Comments

1. Compliance Period for Previously Qualified FSTDs
    In the proposal, the FAA requested comment on the proposed three
year compliance period for previously qualified FSTDs as described in
the FSTD Directive. This request was to determine if the three year
compliance period was adequate to conduct the necessary modifications
to FSTDs in consideration of the March 2019 compliance date for the
extended envelope provisions in the Crewmember and Aircraft Dispatcher
Training final rule.
    Delta, American, and A4A commented that the three year compliance
date proposed in FSTD Directive No. 2 should be aligned with the air
carrier training rule's compliance date of March 12, 2019, for the
extended envelope training provisions. Delta and A4A additionally
commented that there would not be enough lead time to develop
supplemental data for legacy aircraft within the proposed three year
compliance period and recommended that the compliance period be changed
to a firm date of March 12, 2019, to align with the air carrier
training rule. American and A4A also recommended that the due date of
the FSTD Directive be 90 days prior to March 12, 2019, for
incorporation and review by the local training authority.
    The FAA agrees with the commenters in that the compliance period of
the FSTD Directive should be changed to a firm date that aligns to the
Crewmember and Aircraft Dispatcher Training final rule compliance date
of March 12, 2019, and has made this change in the final rule. The FAA
is aware that some aircraft manufacturers and third party data
providers have already made substantial progress in the development of
simulator data packages to meet the requirements of the proposed FSTD
Directive and additional data packages will likely become available for
many FSTD sponsors soon after the publication date of this final rule.
Finally, it was not the intent of the FAA that all FSTDs must be
modified and evaluated by the compliance dates proposed in this rule.
As described in the proposal, only those FSTDs that will be used to
conduct certain training tasks will require compliance with the FSTD
Directive. This should provide FSTD sponsors with some flexibility in
determining which FSTDs to modify as well as determining a timeline for
the FSTD modifications that meets their training requirements.
2. Alternative Data Sources for Level 5 FTDs
    TRU Simulation and A4A commented that the authorized performance
range tables for Level 5 FTDs in Appendix B (Table B2B, B2C, B2D, and
B2E) are incorrect for the change force maneuvers. For each maneuver,
the stick force directions are reversed from the direction as needed to
maintain airspeed as described. This error exists in the current part
60 and exists for all sets of aircraft. TRU Simulation and A4A further
commented that the alternative data source tables for Level 5 FTDs are
invaluable, especially when flight test data is difficult to come by.
However, there are no data tables published in the current part 60 for
turbofan/turbojet aircraft. These are the aircraft where such tables
would have

the biggest positive impact, since the flight test data gathering is
the most expensive for those aircraft. Following the release of Change
1 (of part 60), there was a statement made that the only reason they
were not included in Change 1 was that there was no time to prepare
them.
    The FAA concurs with the commenters and has amended the authorized
performance range tables in Appendix B in the final rule to correct the
stated errors in Tables B2B, B2C, B2D, and B2E. While the FAA agrees
with the commenters that such additional alternative source data for
turbofan/turbojet aircraft could provide for less expensive data
collection and validation of Level 5 FTDs, the FAA did not propose
modifications to these tables and making significant additions and
modifications to these tables would be out of scope for this
rulemaking.
3. Objective Testing for Continuing Qualification
    CAE commented that the requirement for the objective test sequence
that is part of the quarterly inspections requires that all of the
objective tests as defined in the applicable QPS are included in the
content of the complete annual evaluation. There are certain tests,
however, such as visual geometry and motion frequency domain tests,
that primarily serve to confirm or baseline the system performance at
the initial evaluation. These tests are significantly time consuming to
run and require special resources and equipment and do not necessarily
provide value or benefit as part of the quarterly test sequence.
    The FAA agrees with the commenter in that some tests specified in
the table of objective tests may be time consuming and require special
equipment to run on an annual basis as part of the quarterly test
sequence. Concerning the objective motion cueing test as stated by the
commenter, the FAA concurs that it would not be reasonable to conduct
this test on an annual basis and has amended the final rule to only
require this test be run at the initial evaluation.
    With regards to the visual geometry test, the FAA has found that
there is some benefit to verifying that the FSTD's visual system
geometry has not been changed over time. As with the currently accepted
practice for visual geometry testing, the FAA has not required FSTD
sponsors to verify the visual system geometry on an annual basis using
a theodolite since this requires special equipment and resources that
most sponsors do not have. In lieu of conducting such detailed visual
geometry testing on continuing qualification evaluations, provisions
were added in the NPRM (Attachment 2, paragraph 18) that were
consistent with the ICAO requirements allowing for the use of a ``hand-
held optical checking device'' to check that the relative positioning
is maintained. Due to this comment and other comments concerning the
complexity of the visual system geometry test as well as the fact that
the ICAO visual system geometry test was specified assuming a 200 x 40
degree field of view system, the FAA has maintained the existing part
60 existing visual geometry test in the final rule. The FAA has further
added clarifying language in the test requirement (Table A2A, test
4.a.2) that allows for methods to quickly check the visual system
geometry for continuing qualification evaluations.
4. Windshear Qualification Requirements
    In the proposal, the FAA amended the windshear qualification
requirements as a result of recommendations received from the SPAW ARC
concerning improvements to windshear training. These proposed changes
included requirements for complex windshear models to be available on
the FSTD, the addition of realistic levels of turbulence associated
with windshear, and requiring that all IOS selectable windshear
profiles have a method to ensure the FSTD is properly configured for
the selected windshear profile.
    With regards to the updated windshear qualification requirements,
A4A, Boeing, and an anonymous commenter stated that the proposal
requires all required windshear models to be selectable and clearly
labeled on the IOS. Additionally, they pointed out that all IOS
selectable windshear models must employ a method, such as a simulator
preset, to ensure that the FFS is properly configured for use in
training. This method must address variables such as windshear
intensity, aircraft configurations (weights, flap settings, etc.), and
ambient conditions to ensure that the proper windshear recognition cues
and training objectives are present as originally qualified. The
commenters went on to state that this implies that all windshear
training scenarios will have to be evaluated for some specific
condition that is not specified and that this is a far reaching
requirement and should be removed. The commenters suggested that a more
definitive requirement to have a method to repeatedly establish a
survivable and a non-survivable windshear scenario would make more
sense and meet the desired requirement.
    The FAA notes that this particular proposed change to the windshear
qualification requirements was made to ensure that the windshear models
which are available on the IOS are properly set up for use in training
as recommended by the SPAW ARC. Specifically, the SPAW ARC recommended
that all required windshear models should be selectable and clearly
labeled on the IOS. The SPAW ARC determined that the labeling of
available windshear models is not standardized in many FSTDs and
instructors may lack the necessary information to ensure that the
windshear recognition cues in a particular training scenario will occur
as desired.
    While the FAA agrees that the use of presets in the simulator
should be at the discretion of the sponsor, there should be a method
employed by the operator to ensure repeatability of the windshear
training profiles if the instructor has the ability to change basic
parameters of the aircraft or conditions that would affect the outcome
of the windshear maneuver (e.g. aircraft gross weight, ambient
conditions, etc.). As described in the Windshear Training Aid, most
windshear profiles are tuned to produce specific recognition cues and
performance characteristics for consistent training scenarios. If the
basic aircraft configuration and ambient conditions are changed, the
instructor cannot be guaranteed that the windshear recognition cues and
performance during the escape maneuver will be present as originally
evaluated and qualified. Since this rulemaking was originally proposed,
the FAA has issued guidance material \35\ to operators recommending the
use of simulator presets or providing instructor guidance to ensure
that windshear profiles are set up correctly in training. The FAA
believes that the publication of this guidance material will
sufficiently address this issue and has amended this section in the
final rule, as suggested by the commenters, to recommend that a method
to ensure the repeatability of the windshear required survivable and
non-survivable scenarios be employed in the FSTD.
---------------------------------------------------------------------------

    \35\ Information for Operators (InFO) Number 15004, ``Use of
Windshear Models in FAA Qualified Flight Simulation Training
Devices'', published March 13, 2015.
---------------------------------------------------------------------------

5. Miscellaneous Comments
a. Approved Location for Objective and Subjective Testing
    With regards to the changes proposed for Sec.  60.15(e), Delta,
A4A, and an anonymous commenter noted that while

the NPRM states that the subjective tests that form the basis for the
statements described in paragraph (b) of this section and the objective
tests referenced in paragraph (f) of this section must be accomplished
at the FSTD's permanent location, except as provided for in the
applicable QPS, we recommend changing FSTD's ``permanent location'' to
FSTD's ``sponsor designated facility'' as an FSTD may be moved from one
location to another over time. Frasca further commented that current
FAA guidance allows for objective testing to be run at the FSTD
manufacturer's facility as an option for submitting the required
qualification test guide (QTG) prior to the initial evaluation.
    The FAA concurs with the commenters and has amended the final rule
to state that this testing ``must be accomplished at the sponsor's
training facility or other sponsor designated location where training
will take place, except as provided for in the applicable QPS.'' With
regards to Frasca's comment, the ability to submit QTG test results
conducted at the manufacturer's facility is defined in the applicable
QPS (see Appendix A, paragraph 11.h.) and has not changed in this
rulemaking. The submission of QTG test results in this manner will
remain acceptable as described in the applicable QPS.
b. Increasing the Credit for Time in a Simulator
    An individual commented that general aviation needs more extensive
use of simulators rather than less. Reducing the number of hours a
simulator can be used towards a private or instrument rating is bad for
aviation and the flying community. Letters of authorization should
increase the usage of simulator training allowed.
    The FAA notes that this rulemaking has not reduced the number of
hours that a FSTD can be used for a private pilot or instrument rating.
The FAA believes the commenter is referring to training devices not
covered under part 60. Those devices are referred to as aviation
training devices. An approved aviation training device, if determined
to meet the standards in AC 61-136A,\36\ will receive a letter of
authorization from the FAA, which specifies the amount of credit a
pilot may take for training time in that specific device towards a
pilot certificate or rating. Revising the amount of credit a pilot can
take for training in any aviation training device or FSTD is outside
the scope of this rulemaking.
---------------------------------------------------------------------------

    \36\ Advisory Circular (AC) 61-136A, FAA Approval of Aviation
Training Devices and Their Use for Training and Experience (2014).
---------------------------------------------------------------------------

H. Economic Evaluation

    In July 2014, the FAA conducted a preliminary regulatory evaluation
to estimate the costs and benefits of the provisions proposed in the
NPRM. This regulatory evaluation was posted on the public docket with
the NPRM. The agency received several comments on the NPRM from air
carriers, FSTD manufacturers, and trade associations.
1. Cost of Aerodynamic Modeling and Implementation
    An individual commenter questioned whether the FAA factored in the
costs associated with the acquisition of OEM data needed to comply with
the new requirements; the costs associated with obtaining licenses for
third party implementation of data; and the costs associated with the
loss of FFS utilization/revenue for the changes, design,
implementation, installation, validation and actual FAA qualification
activities. American, Delta, JetBlue, and A4A made similar comments on
the basis of the simulator modification costs and how the FAA can
provide an estimate if data licensing pricing and implementation costs
are unknown. American and A4A additionally commented that the FAA needs
to provide their assumptions used for the cost analysis. In addition,
A4A further commented that the cost estimate for implementation of UPRT
is not realistic, is understated, and will depend upon the host and
software architecture of the device being updated. A4A also stated that
once more definitive data is developed the FAA should prepare a
supplemental regulatory impact analysis (RIA) to update the cost
estimate for upgrading FSTDs and provide more detail on the assumptions
used in the analysis.
    The FAA notes that in the preliminary RIA, the estimated cost of
aerodynamic model development included all modifications needed to meet
the standards proposed for full stall, UPRT, and icing evaluation. This
cost was estimated on a per model basis for grandfathered FSTDs and was
further broken down into ``complex'' and ``simple'' projects that were
based upon the likelihood that existing data was available to support
the necessary modifications. This cost was estimated based upon
feedback from an industry questionnaire which estimated the cost of a
``complex'' model development at $100,000 and a ``simple'' model
development at $60,000. Since many FSTDs share a common aerodynamic
model developed by a common source, it was assumed that the costs of
aerodynamic model development would be distributed amongst the
purchasers of the model. Section II.d. of the RIA that was published
with the NPRM, fully explained the agency's assumptions and rationale
used to develop the cost estimates.
    With regards to implementation costs, the FAA calculated this
separately from the aerodynamic model development costs on a per unit
basis since implementation costs would impact individual FSTDs and not
be distributed amongst several FSTDs. The FAA estimated the per unit
costs as $77,307 per FSTD to include implementation costs, lost
productivity/revenue, SME pilot testing, and hardware modifications.
This estimate includes 45 hours of lost training time at $500 per hour
to conduct these activities. This estimate was based upon the responses
from an industry questionnaire and is fully explained in the RIA that
was placed on the public docket with the NPRM. The FAA did not receive
any cost estimates in the public comments concerning additional
licensing fees for the implementation of data by a third party.
    An individual commenter further questioned the cost basis for the
icing modifications and that the summary is not based on any factual,
verifiable analysis. The commenter further stated that assumptions are
made that icing upgrades can be accomplished at the same time as non-
icing upgrades and that there is no basis in fact for this statement
and because of that, the costs are artificially low. A4A and American
made similar comments concerning the cost of the required modifications
for icing.
    The FAA notes that the costs for the aerodynamic modeling
development necessary for both the full stall requirements and the
icing requirements were estimated based upon the responses from an
industry questionnaire. Since most simulators for transport category
aircraft currently use icing models that are supplied by a common
source as that of the aerodynamic model, the FAA assumed the updated
models for both full stall and icing would likely be developed
concurrently by the data provider and subsequently installed by the
FSTD sponsors as a package in most cases. The agency's rationale for
the breakdown of aerodynamic modeling costs for both stall and icing
are described in the regulatory evaluation that was published with the
NPRM.
    In response to these comments, the FAA has revised its cost
estimates for the final rule to include additional

information gathered from air carriers, FSTD manufacturers, and data
providers to better estimate the cost of this rule. One aircraft OEM
simulator data provider has indicated that the estimated cost of an
enhanced stall model would be in the area of $25,000 per FSTD.
Furthermore, this data provider stated that in order to support the
installation of an enhanced stall model, FSTDs running certain versions
of their data package would need to be brought up to the latest
revision or blockpoint before this installation can take place. The FAA
also obtained a cost estimate from a third party provider to implement
its model on FSTDs.
    As a result of this additional information as well as further
analysis conducted on FAA FSTD qualification records, the FAA was able
to group the FSTDs into seven different categories. The groups were
based upon the estimated cost components to implement the modifications
needed to meet the requirements of FSTD Directive No. 2. The estimated
costs are separated by various factors such as the anticipated source
of the aerodynamic data, whether the FSTD will need a standard data
revision before further modifications can occur, whether the FSTD could
potentially need a significant hardware update, and other factors that
might affect the overall cost to meet the requirements of this final
rule. This refined granularity for categorizing the FSTDs as well as
the estimated cost for each category of FSTD is fully explained in the
final RIA that is published with this final rule.
2. Cost of Instructor Operation Station (IOS) Replacement
    American commented that the cost to bring an FSTD into compliance
with FSTD Directive No. 2 is low by many orders of magnitude. Older
simulators will need new IOSs since many FSTDs cannot support the
required graphics capabilities and would have to be replaced. American
further commented that they have a rough estimate from one vendor that
it will cost $250,000 alone for IOS update/replacement. A4A made
similar comments that older simulators would need IOS replacement at an
estimated cost of $250,000 in order to meet the instructor feedback
mechanism requirements for UPRT. A4A further commented that this
underestimated cost is a concern because there is no benefit to this
element of the proposal as there are other methods available to provide
instructors with the information necessary to evaluate a pilot's skills
during simulator sessions that are used successfully today. The record
and playback function should be left as an option available to FSTD
customers, but it should be removed from this proposed rule.
    The FAA notes that the requirements for UPRT in the proposal and in
the final rule do not specifically require the use of graphical
displays to provide the necessary feedback. The FAA provided some
example displays in Attachment 7 of Appendix A, but these examples are
within an ``information'' section as recommendations, but are not
regulatory. The FAA acknowledges that the instructor feedback that is
necessary for UPRT could potentially be accomplished using methods
other than graphical displays (such as numerical or discrete feedback
at the IOS) and the agency has not been overly prescriptive in the
final rule that requires a single solution. The FAA further notes that
the requirement for video and audio recording and playback has been
removed in the final rule as discussed in previous sections and this
should provide some cost relief in meeting the requirements for UPRT.
Finally, the FAA agrees with American and A4A in that there are a small
number of older simulators still in operation which may have IOS
display systems that cannot meet the requirements for UPRT without
extensive modification or replacement. The FAA has made adjustments to
the final RIA to account for the additional cost of replacing old IOS
display systems for some older FSTDs.
3. Affected FSTDs and Sponsors
    American commented that ``. . . the FAA indicates cost savings by
Sponsors not modifying all FSTDs, just part of the fleet. This is not
an option for [American] and we believe all sponsors. This would impose
scheduling complexity. Cost and other factors should be reviewed in the
context of modifying all part 121 flight simulators. It is not feasible
to only modify part of a simulator fleet and efficiently schedule
crews. Our plan is to modify all FSTDs in our fleet. This will drive
the costs higher with increase data licenses, implementation costs, and
training impact. This does not provide additional cost relief for the
sponsors.'' Similar comments were made by A4A. An individual commenter
stated that it appears that the effect on the industry could include a
larger number of Level C and Level D FFSs than the 322 cited in the RIA
and asked if the FAA calculated total costs if all currently FAA
qualified Level C and Level D devices were to comply with FSTD
Directive No. 2. This commenter further questioned whether the FAA
calculated the cost to a sponsor if an FFS were to not comply with FSTD
Directive No. 2.
    The FAA notes that the cost estimates for FSTD Directive No. 2
included the cost to update and evaluate all Level C and Level D FFSs
that could potentially be used to meet the part 121 extended envelope
training requirements. The FAA assumed that all part 121 Level C and
Level D FFSs would require updating and did not include any cost
reductions in the RIA. These assumptions and the associated rationale
were fully described in the RIA that was published with the NPRM.
    The FAA further notes that the costs for previously qualified FSTDs
were derived solely from the proposed FSTD Directive for full stall,
upset recovery, icing, bounced landing recovery, and gusting crosswind
FSTD evaluation requirements in the NPRM. Compliance with this
Directive is only required for sponsors of FSTDs that will be used to
deliver such training. The only operators required to conduct such
training are air carriers operating under part 121. The estimated 322
FSTDs were derived from those currently qualified FSTDs that simulate
an aircraft that is likely to be used in a U.S. part 121 air carrier's
training program. Since the NPRM was published, the number of FSTDs
that could be impacted by the air carrier training requirements has
increased from 322 to 335 FSTDs. We assumed that the cost of modifying
the previously qualified FSTDs that are not used in part 121 training
are not a cost of this rule because these operators are not required to
conduct such training for these particular tasks. If a sponsor chooses
not to offer the training defined in the FSTD Directive, there are no
additional requirements or costs imposed by this rule for previously
qualified FSTDs.
    American and A4A commented that the provisions included in the NPRM
for Level A and Level B FFSs have no applied cost savings for sponsors
since there are no Level A or Level B FFSs for part 121 sponsors.
    The FAA notes that as of the close of the comment period of the
NPRM, one Level A and one Level B FFS are still in operation and
actively sponsored by part 121 operators. No cost savings were applied
in the RIA for Level A and Level B FFSs as stated by the commenters.
    Frasca commented that the NPRM stated that only sponsors are
affected by this rule and FSTD sponsors are air carriers who own
simulators to train their pilots or training centers that own
simulators and sell simulator training time. Frasca went on to state
that this statement assumes only part 119 and part 142 organizations,
implying part

141 sponsors were not considered in the analysis. The FAA should
consider reevaluating the analysis of small entities taking into
consideration part 141 organizations that sponsor FSTDs. CAE further
commented that FSTD manufacturers, aircraft OEMs and other data
providers are also affected by these requirements.
    The FAA acknowledges CAE's comment in that other entities beyond
the FSTD sponsor may be indirectly affected by this rule; however, the
part 60 requirements apply to FSTD sponsors and not directly to the
FSTD manufacturers and data providers. The FAA concurs with Frasca's
comment in that all affected FSTD sponsors should be considered in the
cost analysis of the rule. The FAA points out that the cost estimates
in the RIA considered all FSTDs and sponsors that may be affected by
this rulemaking, regardless of the certificate held by the sponsor.\37\
For previously qualified FSTDs that will have to meet the requirements
of FSTD Directive No. 2 to conduct extended envelope training tasks,
these estimates were based upon an analysis of FSTDs that could
potentially be used in part 121 training programs to meet the air
carrier training requirements, regardless of the sponsor's operating
certificate. For newly qualified Level C and Level D FFSs that will be
required to meet the updated requirements that were aligned with the
ICAO 9625 document, this estimate was conducted using historical data
on all new Level C and Level D FFSs that the FAA has initially
qualified within the last 10 years. The specific impact on small
entities was fully explained and accounted for in the RIA.
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    \37\ Sec.  60.7(a) requires that an FSTD sponsors holds or is an
applicant for a certificate under part 119, 141, or 142.
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4. Costs and Benefits of ICAO Alignment
    A4A commented that, in the NPRM, the FAA states that
``Internationally aligned FSTD standards facilitate cost savings for
FSTD operators because they effectively reduce the number of different
FSTD designs that are required.'' A4A further stated that ``We can find
no simulator manufacturer information in the docket to substantiate
this statement. The FAA should explain and provide the basis for this
statement. Based on past experience, the A4A believes that simulator
manufacturers will continue to differentiate their product features
instead of adopting one design due to aligned standards. Unless
simulator manufacturers can provide product pricing information that
proves otherwise, there will be no savings for purchasers of FSTDs as a
result of the alignment proposed in this rule. A final or supplemental
RIA must therefore eliminate reference to or quantification of illusory
benefits from internationally-aligned FSTD standards.''
    The FAA notes that while the NPRM and RIA references qualitative
benefits and potential cost savings due to internationally aligned FSTD
evaluation standards, there were no quantified benefits included in the
preliminary or final RIA. The FAA acknowledges that there will be a
small cost associated with updating the part 60 FSTD evaluation
standards to the latest ICAO 9625 document. In the RIA that was
published with the NPRM, the FAA estimated the cost of compliance to
initially qualify a new FSTD under the proposed standards that were
aligned with ICAO 9625, Edition 3. Based upon the responses to a