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NPA-STD 11 (JAR-FSTD A). Comment Review Presentation to OST May 2006. NPA-STD 11. Background Comment Process Comment Response Document Harmonisation with NPA-STD 12 (FSTD H) Outstanding Work. Background to FSTD A.
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NPA-STD 11(JAR-FSTD A) Comment Review Presentation to OST May 2006 NPA-STD 11, Comment Review JAA HQ, 30 May 06 1
NPA-STD 11 • Background • Comment Process • Comment Response Document • Harmonisation with NPA-STD 12 (FSTD H) • Outstanding Work NPA-STD 11, Comment Review JAA HQ, 30 May 06 2
Background to FSTD A • JAR-STD 1A, 2A, 3A and 4A covering FFS, FTD, FNPT and BITD had been developed by different groups at different times • This resulted in a number of inconsistencies between the technical standards, the processes and the presentation of the four documents. NPA-STD 11, Comment Review JAA HQ, 30 May 06 3
Background to FSTD A • JAR-STD 1A was most fully developed and was, therefore, used as the basis for the new requirement. • The collective Term STD is replaced by FSTD, Flight Simulation Training Device • The Term Flight Simulator is replaced by FFS, Full Flight Simulator • These new Terms are chosen to align with the FAA/JAA revised Terminology NPA-STD 11, Comment Review JAA HQ, 30 May 06 4
Background to FSTD A • Appendix 1 to JAR-FSTD A.030 combines the Standards for all Types and Levels into a single table • ACJ 1 to JAR-FSTD A.030 combines the Objective / Functions and Subjective Testing Requirements for all Types and Levels into two Tables NPA-STD 11, Comment Review JAA HQ, 30 May 06 5
Background to FSTD A • Limited Changes ensure previous Texts from JAR-STD 1A, 2A, 3A and 4A are now unified • In parallel, the Standards for Helicopter STDs have been combined in a JAR-FSTD H Document (NPA-STD 12) NPA-STD 11, Comment Review JAA HQ, 30 May 06 6
Background to FSTD A • The Standards for all types of Device remain unchanged • The STD Standards were reviewed to ensure compliance with JAR 11 • Regulatory Process for Qualifying STDs was aligned with current best practice NPA-STD 11, Comment Review JAA HQ, 30 May 06 7
Background to FSTD A Regulatory Impact Assessment • No Impact on Safety • No Economic Impact • No environmental or social impact • A positive impact on Harmonisation NPA-STD 11, Comment Review JAA HQ, 30 May 06 8
Comment Review • Initial consultation with interested parties took place during development NPA. • NPA-STD 11 went out for a formal public comment period of two months in October 2005. • 347 comments were received against NPA-STD 11. NPA-STD 11, Comment Review JAA HQ, 30 May 06 9
Comment Review • Comments reviewed by a group with members from Authorities, simulator manufacturers, simulator operators and specialist consultants. • Review included consultation with FSTD H group to ensure consistency. NPA-STD 11, Comment Review JAA HQ, 30 May 06 10
Comment Response Document • Over 50% of comments accepted • Accepted comments covered errors in translation from existing standards, typographical and formatting errors or sought clarification of existing standards • Declined comments included a large proportion that proposed a change in technical standards NPA-STD 11, Comment Review JAA HQ, 30 May 06 11
Comment Response Document Completed Comment Response Document and final revised version of FSTD A delivered to CJAA on 11 April 2006 NPA-STD 11, Comment Review JAA HQ, 30 May 06 12
Harmonisation with NPA-STD 12 • Prior to submission of revised FSTD A, a review of consistency with FSTD H was carried out. • Section 1 of the two requirements are identical with exception of different dates for implementation of Grandfather Rights. • Section 2, Terminology, Process and Quality System material identical. NPA-STD 11, Comment Review JAA HQ, 30 May 06 13
Harmonisation with NPA-STD 12 • Technical standards consistent, as far as possible, within the constraints of the different operational and training needs of aeroplanes and helicopters. • Guidance and interpretative material standardised as far as possible. NPA-STD 11, Comment Review JAA HQ, 30 May 06 14
Outstanding Work • Experience with current standards has identified a number of shortcomings. • Several comments submitted proposing a change in technical standard. • A number of comments considered valid. NPA-STD 11, Comment Review JAA HQ, 30 May 06 15
Outstanding Work • Document to be prepared, based on comments, identifying areas of FSTD A where future revision to the requirements may be justified. • Document to provide justification for change. • Document to be submitted through JAR-STD StG at June meeting, for future rulemaking activity by JAA/EASA. NPA-STD 11, Comment Review JAA HQ, 30 May 06 16