Proposed Part 60 MOS amendments – Upset prevention and recovery training - (CD 2102FS)

Closed 7 Jul 2021

Opened 3 Jun 2021

Feedback updated 2 Aug 2021

We asked

This consultation asked industry and stakeholders to identify any effects from implementing the proposed changes to the Part 60 Manual of Standards (MOS). The consultation has now closed, and a summary of the feedback is provided below.

About this consultation

Prior to the consultation, CASA had informal feedback from industry stakeholders indicating that the changes were appropriate and are welcome. CASA noted this feedback when developing the policy for the changes and, to gain perspective from the widest possible audience, undertook formal consultation.

The consultation asked respondents if the proposed changes provided sufficient time to make upgrades to upset prevention and recovery training (UPRT) capable devices and if it would present any safety issues. Further, the consultation asked if the addition of a CASA qualification system as a standard would lead to inadequate devices becoming qualified.

Respondents were also asked to provide input on any additional issues they would like considered by the post implementation review.

You said

There was 1 response to the discussion paper. The respondent represented a flight crew training and checking organisation and requested their submission be confidential.

Summary of feedback

The respondent indicated they supported the change providing additional time to make the upgrades to UPRT capabilities. Of note, the respondent indicated that without the proposed change, operators would likely bear significant costs and would face other operational impacts. For example, the respondent highlighted that without the proposed changes, UPRT would not be able to be integrated into recurrent training (which is undesirable for both CASA and operators) and mandatory training would be outsourced to other countries.

Regarding the proposed addition of FSD-1 as a qualification standard, the respondent was also supportive. The respondent noted the significant costs required to meet the latest alternative qualification standard, which for an older device would be prohibitive, and would deliver additional training activities for UPRT.

We did

Next steps

Overall, through the formal consultation survey and from informal feedback, industry stakeholders have strongly supported the proposed changes. As a result, CASA will now undertake to implement the changes for the Part 60 MOS to reflect the proposals.

Overview

Current Part 60 Standards allow certain simulators to qualify for upset prevention and recovery training (UPRT) through a relatively simple process. This simplified process is achieved by upgrading the simulators with a less onerous software before 24 March 2021. From 25 March 2021, older simulators used for UPRT will incur a greater cost burden to upgrade to the latest standards, with little additional practical benefit.  

Separately, a device qualified under FSD-1 could not be modified and certified for UPRT, as access to stall data supporting the software upgrade was not possible. A recent release by Boeing of previously unavailable data now makes the upgrade technologically possible. However, the current drafting of the Part 60 Manual of Standards (MOS) does not contain a provision that recognises FSD-1 as a transitional qualification standard for these devices. This will mean the device would not be permitted to undertake UPRT, even with the necessary technological upgrades.

The proposed change would make two amendments to the Part 60 MOS to address these issues. These amendments would:

  • allow further time for operators to upgrade UPRT capabilities for older devices by amending the transitional deadline (currently 24 March 2021) to 24 March 2023
  • make available FSD-1 as a qualification standard for the re-evaluation of legacy aeroplane flight simulators that may be upgraded for UPRT.

Why we are consulting

CASA recognises the valuable contribution community and industry consultations make to the policy decision-making process and future regulatory change. We are consulting to ensure that the proposed new rules are clearly articulated and will work in practice and as they are intended.

Comments are sought from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.

Documents for review

All documents related to this consultation are attached in the ‘related’ section at the bottom of the page. They are:

  • Summary of proposed change (SPC) on Part 60 MOS amendments – Upset prevention and recovery training (UPRT), which provides background on the proposed standards
  • Consultation draft - Part 60 Manual of Standards Amendment Instrument 2021 (No. 1)
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation. 

Note: The MS Word document is not to be used as an emailed submission, unless there are extenuating circumstances and this form of submission has been agreed to by the consultation project lead.

It is important that you read the Summary of proposed change on CD 2012OS, before providing your feedback in the online survey.

The survey has been designed to give you the option to provide feedback on the survey in its entirety or to provide feedback on the policy topics which are of interest to you.

What happens next

At the end of the response period for public comment, we will review each comment and submission received. We will make all submissions publicly available on the CASA website, unless you request your submission remain confidential. We will also publish a Summary of Consultation which summarises the feedback received, outlines any intended changes and details our plans for the regulation.

All comments on the draft Part 60 MOS consultation will be considered. Relevant feedback that improves upon the proposed regulations and is consistent with the regulations and other CASA policy, will be incorporated into the final ruling.

CASA has set a tentative date of 1 August 2021 for the rules to come into effect. The feedback we receive from this consultation will also assist CASA in developing adequate implementation and transition timeframes.

Post-implementation review

CASA's monitoring and review of the new rules during the transition phase and beyond will be ongoing.  We will also continue work on proposed further changes to the Part 60 regulations to better support flight simulator training device operations.

Audiences

  • CASA Staff
  • Air operators
  • Instructors and flight examiners
  • Flight training organisations
  • School/Education/Aviation Theory Provider
  • Part 142 operators
  • Part 141 operators

Interests

  • Aircraft certification and design
  • Flight training
  • Airworthiness/maintenance (CAR 30 and CASR Part 145 maintenance orgs)
  • Training and checking systems