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NPA-STD 12 (JAR-FSTD H) Comment Review Presentation to OST Bruno HALLER (DGAC France) 31 May 2006
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NPA-STD 12 1. Background 2. Comment Process 3. Comment Response Document 4. Harmonisation with NPA-STD 11 (FSTD A) 5. Outstanding Work
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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.
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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.
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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.
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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).
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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.
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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
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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.
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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.
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Comment review (3/4) List of meetings attendees (Authorities) List of meetings attendees (Authorities) - Peter Barrack (UK CAA) - Frank Reimann (German LBA) - JM Sacazes (DGAC France) - Bruno Haller (DGAC France – Chairman)
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Comment review (4/4) List of meetings attendees (Industry) 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)
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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. 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.
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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 ».
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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.
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Comment Response Document (4/4) Completed Comment Response Document and final revised version of JAR-FSTD H delivered to CJAA on 12 April 2006.
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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.
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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.
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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.
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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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THANK YOU ANY QUESTION ? ANY QUESTION ?
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