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NPA-STD 12 (JAR-FSTD H). Comment Review Presentation to OST Bruno HALLER (DGAC France) 31 May 2006. NPA-STD 12. Background Comment Process Comment Response Document Harmonisation with NPA-STD 11 (FSTD A) Outstanding Work. Background to JAR-FSTD H (1/6).
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NPA-STD 12(JAR-FSTD H) Comment Review Presentation to OST Bruno HALLER (DGAC France) 31 May 2006
NPA-STD 12 • Background • Comment Process • Comment Response Document • Harmonisation with NPA-STD 11 (FSTD A) • Outstanding Work
Background to JAR-FSTD H (1/6) • JAR-STD 1H, 2H and 3H covering FFS, FTD, FNPT had been developed by different WG at different times. • This resulted in a number of inconsistencies between the technical standards, the processes and the presentation of the three documents.
Background to JAR-FSTD H (2/6) • JAR-STD 1H 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 FS (Flight Simulator) is replaced by FFS (Full Flight Simulator). • These new Terms are chosen to align with the FAA/JAA revised Terminology.
Background to JAR-FSTD H (3/6) • Appendix 1 to JAR-FSTD H.030 combines the Standards for all Types and Levels into a single table. • ACJ 1 to JAR-FSTD H.030 combines the Objective / Functions and Subjective Testing Requirements for all Types and Levels into two Tables.
Background to JAR-FSTD H (4/6) • Limited Changes ensure previous texts from JAR-STD 1H, 2H and 3H are now unified and consistent. • In parallel, the Standards for Aeroplane STDs have been combined in a JAR-FSTD A Document (NPA-STD 11).
Background to JAR-FSTD H (5/6) • 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.
Background to JAR-FSTD H (6/6) Regulatory Impact Assessment • No Impact on Safety • No Economic Impact • No environmental or social impact • A positive impact on Harmonisation
Comment Review (1/4) • Initial consultation with interested parties (Authorities and Industry) took place during development NPA. • NPA-STD 12 went out for a formal public comment period of two months from 1st October to 1 December 2005. • 232 comments were received against NPA-STD 12.
Comment Review (2/4) • Comments reviewed by a group with members from Authorities, simulator manufacturers, simulator operators. • Review included regularly consultation with JAR-FSTD A WG to ensure consistency between both documents.
Comment review(3/4) List of meetings attendees (Authorities) • Peter Barrack (UK CAA) • Frank Reimann (German LBA) • JM Sacazes (DGAC France) • Bruno Haller (DGAC France – Chairman)
Comment review (4/4) List of meetings attendees (Industry) • René Tassan / Eric Jansonnie : Eurocopter France • Bernard Josseaux / Michel Deparis : Helisim • Francesco Pasqualetto : Agusta / Rotorsim • Therje Thorrud : CHC Norway • Hubert Kinnel : Sogitec • Eric Merck : French Army • Bernard Delgingharo : Thales France (Secretary)
Comment Response Document (1/4) • Over 50% of comments (140) accepted : Accepted comments covered errors in translation from existing standards, typographical and formatting errors or sought clarification of existing standards. • Declined comments (41) included : • a large proportion that proposed a change in technical standards. • not relevant comments.
Comment Response Document (2/4) • Partially accepted comments (27) included by definition comments for which a part is relevant. • Noted comments (29) : 26 of them have been considered « reserved for future work ».
Comment Response Document (3/4) • WG members paid a particular attention that the incorporation of accepted comments not leaded to a change of the existing technical standards. • JAR-FSTD H is now : - a very consistent and a much more clear document - much less typographical and formatting errors.
Comment Response Document (4/4) Completed Comment Response Document and final revised version of JAR-FSTD H delivered to CJAA on 12 April 2006.
Harmonisation with NPA-STD 11 (1/2) • Prior to submission of revised JAR-FSTD H, a review of consistency with JAR-FSTD A was carried out (Gatwick meeting : 28 & 29 March 2006). • 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.
Harmonisation with NPA-STD 11 (2/2) • 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.
Outstanding Work (1/2) • Experience with current standards has identified a number of shortcomings. • Several comments submitted proposing a change often relevant in technical standards. • A number of comments considered valid.
Outstanding Work (2/2) • Document to be prepared, based on comments, identifying areas of JAR-FSTD H 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.
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