Prescribed qualification standards for FSTD (MCC training – aeroplane) Instrument 2015 (Edition 1)

The instrument revolves around several key concepts that define what an FSTD must be and do for MCC training.

First, “device” or “FSTD” - a flight simulation training device. The instrument does not define this term substantively but adopts the meaning from CASR 1998 regulation 61.010, which in turn refers to a device that meets prescribed qualification standards. So the instrument is the vehicle for setting those standards. The device is not necessarily a full flight simulator; it may be a less capable device, but must satisfy the detailed Schedule 1 requirements.

Second, “MCC training” - an approved course of training in multi‑crew cooperation. The instrument does not define the content of MCC training; that is left to other approvals. What it does is prescribe the hardware and software environment in which that training must be conducted. The standards are concerned with the fidelity of simulation needed to enable realistic crew coordination scenarios.

Third, “simulate” - the instrument defines this as reproducing “at least in all essential respects” the actions and reactions of a multi‑crew aeroplane, including associated noise, attitude, motion, and external environmental effects. This is a high threshold, but qualified by “essential respects”. Not every minor feature must be reproduced; the test is functional equivalence for training purposes.

Fourth, “no discernible latency” - a critical concept for visual systems. The visual horizon must be synchronised with the artificial horizon on the instrument panel with no observable delay greater than what would occur in the actual aeroplane (clause 12.12). Similarly, “transport delay” is defined as total computer processing time for a simulated system to respond to a control input, and must not exceed 300 milliseconds (clause 13.3). These concepts are about ensuring that the simulation does not introduce artificial lag that could mislead trainees or impair the training value.

Fifth, “multi‑crew aeroplane” - the instrument defines this in detail in clause 3(2). It is a turbine‑powered, multi‑engine aeroplane with specific equipment (pressurisation, oxygen, retractable gear, engine fire detection/extinguishment, weather radar) and equipped for multi‑crew IFR operations. This definition limits the scope of the instrument: the device must simulate an aeroplane of that description. A device that simulates a single‑engine or non‑pressurised aeroplane cannot be qualified under this instrument for MCC training.

Sixth, “model” - a particular simulation functionality of the device, such as the flight dynamics model that simulates the behaviour of the aeroplane in various flight conditions. The standards require the flight dynamics model to be able to simulate various combinations of drag and thrust that give rise to changes in attitude, thrust, drag, altitude, and configuration (clause 2). This is about the mathematical representation of aeroplane performance.

Seventh, “quantization” - the note to clause 1.3 explains this as restraint or limitation on the range of values that would normally be found in an instrument. Electronic displays with physical overlays must be free of quantization, meaning they must not artificially restrict the resolution of displayed data.

Eighth, “correct sense” - used in clause 1.4 for angle of attack indicators; the indication must increase as the aeroplane approaches stall, consistent with real‑world behaviour.

The instrument also contains a notable reservation: motion cues are reserved (clause 8). There is no requirement for the device to provide motion (e.g., a hexapod platform). This is a significant cost‑saving concession. While full flight simulators often require motion, this instrument allows a static device for MCC training, provided all other standards are met.

Finally, the concept of “air traffic control environment simulation” is minimal: the device need only generate at least one automated ATIS broadcast (clause 9). This is a low bar, indicating that the instrument does not require full ATC simulation.

The instrument directly affects several groups. First, manufacturers of flight simulation training devices who wish to supply devices for MCC training in Australia. They must design, build, and test their devices to meet the Schedule 1 standards. This imposes engineering costs, especially in areas like flight dynamics modelling, visual system resolution, and transport delay verification. Manufacturers must also provide an operations manual and support maintenance inspections (clause 13.5, 13.6). The instrument does not mandate a specific certification process; it leaves verification to the manufacturer’s systems test or a statement of compliance supported by technical data (clause 13.3). This gives manufacturers some flexibility but also places the onus on them to demonstrate compliance.

Second, training organisations - typically Part 142 flight training operators or similar - who provide MCC training as part of a pilot licence or type rating course. They must ensure that any FSTD they use for MCC training is qualified under this instrument. If they use an unqualified device, the training may not be recognised by CASA for the grant of a pilot licence or rating. Training organisations therefore face a choice: invest in a compliant device (new or upgraded), purchase training time on an existing compliant device, or seek an alternative means of compliance (if any) under the CASR framework. The standards are detailed and prescriptive, so the cost of compliance is not trivial. Small training providers may find it harder to compete if they cannot afford a compliant FSTD.

Third, pilots (trainees) - they are the end users. The instrument aims to ensure that the training they receive on an FSTD provides a realistic environment for developing MCC skills. A compliant device should, in theory, produce better‑trained pilots. But the cost of compliance may be passed on to trainees in higher course fees. Pilots also have a right to expect that training on a qualified device counts toward their licence requirements; if a device is not qualified, their training time may be wasted.

Fourth, CASA - the regulator must oversee compliance. CASA does not issue approvals under this instrument directly; rather, the instrument is a legislative instrument that automatically prescribes the standards. CASA’s role is to enforce the broader CASR framework, including auditing training organisations and potentially inspecting FSTDs. CASA also must keep the instrument current; it can amend the instrument if technology changes or operational experience reveals deficiencies.

Fifth, maintenance organisations and personnel - clause 13.5 requires maintenance and inspections in accordance with the manufacturer’s instructions and any other maintenance needed to ensure continued compliance. This affects engineering staff who service the device. They must keep records and perform periodic checks.

Sixth, device instructors - clause 13.6 requires an operations manual that describes emergency procedures, serviceability checks, and operating procedures for both trainees and instructors. Instructors must be familiar with the device’s capabilities and limitations. The instructor station must be positioned to allow observation of the visual scene and assessment of trainee performance (clause 13.1), and must have within reach controls for system variables, time freezes, and environmental conditions (clause 13.2). This imposes ergonomic design obligations.

Seventh, suppliers of navigation databases and visual scenery - the instrument requires navigation data to be accurate and support scenario‑based training at specific real‑world locations (clause 10). Visual scenery must include at least three different aerodromes in daylight, twilight, and night conditions (clause 12.6). Providers of these databases must ensure they meet the specificity and accuracy requirements, which may increase development costs.

The instrument does not directly affect passengers or the general public, but indirectly, safer pilots benefit everyone.

The instrument creates no private rights of action. It is a regulatory instrument that imposes duties on persons who use or supply an FSTD for MCC training.

Duty to ensure the device meets the qualification standards. This falls on the training organisation that uses the device for MCC training. The duty is not stated explicitly in the instrument, but arises from the operation of regulation 61.045 of CASR 1998: if the device does not meet prescribed standards, it is not a qualified FSTD. A training organisation that uses an unqualified device for MCC training may breach the CASR requirements for the conduct of approved training.

Duty to maintain compliance. Clause 13.5 requires that the device be supported by maintenance and inspections in accordance with the manufacturer’s instructions and any other maintenance necessary to ensure continued compliance. The person responsible for the device (likely the operator) must also maintain documents demonstrating satisfactory completion of those maintenance and inspections. This is an ongoing duty, not a one‑off certification.

Duty to provide an operations manual. Clause 13.6 requires the device to have an operations manual describing emergency procedures, serviceability tests or checks, and operating procedures for trainees and instructors. The responsible party must produce and keep this manual current.

Duty to provide manufacturer’s evidence of transport delay compliance. Clause 13.3 requires verification that transport delay does not exceed 300 milliseconds. This must be done via the manufacturer’s systems test, or if none is available, a manufacturer’s statement supported by technical data. The person seeking to use the device must obtain and keep this evidence.

Duty to ensure instructor station meets specifications. The device must be configured so that the instructor can observe the visual scene through forward windows and assess trainee performance (clause 13.1), and the instructor station must have reachable controls for key variables (clause 13.2). This duty is on the device designer or modifier.

Rights of trainees. While the instrument does not explicitly confer rights on trainees, a trainee has a legitimate expectation that training on a qualified device will be accepted by CASA for licensing purposes. If a training organisation uses an unqualified device and represents it as qualified, the trainee may have a contractual or consumer law claim, but that is outside this instrument.

Rights of manufacturers. Manufacturers have the right to rely on the prescribed standards as the benchmark. If they meet the standards, their device should be accepted as qualified. There is no discretion for CASA to add extra requirements beyond what the instrument sets, unless another provision of CASR permits it. This gives manufacturers regulatory certainty, albeit within a prescriptive framework.

No duty to provide motion cues. Clause 8 reserves motion cues; there is no requirement. This is a notable concession that reduces compliance burden.

No duty to provide specific flight deck features beyond those listed. Clause 1.1(c) lists structural elements that must be included “where applicable”. If an element is not applicable to the multi‑crew aeroplane being simulated, it need not be present. This allows some flexibility.

Right to use alternate verification methods for transport delay. If no manufacturer’s systems test exists, a statement of compliance supported by technical data may be used (clause 13.3). This prevents a deadlock when a test procedure is not available.

The instrument itself does not create any penalties. It is a legislative instrument that prescribes standards; enforcement occurs through the parent regulations (CASR 1998) and the Civil Aviation Act 1988. However, the instrument is essential context for understanding the legal consequences of non‑compliance.

Under CASR Part 61, an FSTD used for MCC training must meet prescribed qualification standards. If a device does not meet the standards in this instrument, it is not a qualified FSTD. Using an unqualified device for MCC training could constitute a breach of the conditions of an approval to conduct training, or a breach of the regulations that require MCC training to be conducted on a qualified device. The Civil Aviation Act 1988 provides for civil penalties (up to a certain number of penalty units) for contraventions of regulations. CASA can also issue infringement notices (on‑the‑spot fines) for less serious breaches, or seek injunctions to prevent continued use of non‑compliant devices.

Additionally, if a training organisation knowingly uses a non‑compliant device and issues certificates or logbook endorsements for MCC training, that could amount to making false or misleading statements to CASA, which carries higher penalties under the Civil Aviation Act.

The instrument provides for verification of compliance through manufacturer’s tests or statements (clause 13.3). This means CASA may rely on those documents as evidence of compliance. If a manufacturer provides a false statement, they could be liable for an offence under the Criminal Code or the Civil Aviation Act for providing false information to a Commonwealth official.

Enforcement actions can include suspension or cancellation of approvals for training organisations, or directions to cease using a particular device. CASA may also audit devices and require re‑demonstration of compliance.

The instrument also implies a duty to maintain compliance over time (clause 13.5). If maintenance lapses and the device falls out of compliance, the operator may be in breach even if the device was originally qualified. The requirement to keep documents of maintenance and inspections means CASA can verify that compliance is ongoing.

There is no provision in the instrument for appeal or review of a decision that a device does not meet the standards. However, if CASA makes an administrative decision (e.g., refusing to recognise training conducted on a particular device), that decision may be reviewable under the Administrative Appeals Tribunal Act 1975 or via judicial review.

The practical enforcement lever is economic: if CASA determines that a device does not comply, all MCC training conducted on that device could be rendered invalid, forcing trainees to repeat training at their own cost. That puts pressure on training organisations to maintain compliance.

Because the instrument does not itself prescribe penalties, the maximum penalties depend on the specific regulation breached. For example, a breach of a condition of an approval could attract a civil penalty of up to 500 penalty units (currently about $156,000 for an individual, more for a body corporate under the Crimes Act). Criminal offences may carry higher penalties, but typically require proof of fault.

In summary, enforcement relies on the broader CASR framework. The instrument supplies the technical reference point for assessing compliance.

This instrument does not operate in isolation. It sits within a web of Australian aviation legislation.

Civil Aviation Safety Regulations 1998 (CASR 1998). The instrument is made under regulation 61.045, which is part of Part 61 (Flight Crew Licensing). Part 61 defines the types of flight crew licences and ratings, including the requirement for MCC training. The definition of “flight simulation training device” in regulation 61.010 refers to a device that meets prescribed qualification standards; this instrument provides those standards for MCC training for aeroplanes. Other parts of CASR may prescribe qualification standards for different purposes (e.g., for type rating training, or for helicopter devices). This instrument is specific to aeroplane MCC training only.

Civil Aviation Safety Regulations 1998 - Part 142. Part 142 of CASR regulates flying training organisations that conduct approved training. Those organisations must have an approval from CASA, and the approval may specify the training that can be conducted and the equipment that must be used. A Part 142 operator who uses an FSTD for MCC training must ensure it meets these standards; if not, they are not complying with their approval conditions.

Civil Aviation Regulations 1988 (CAR 1988). While CASR is replacing CAR, some provisions remain. The instrument defines IFR by reference to Part 12 of CAR 1988. That interaction means any changes to IFR rules in CAR may affect the definition of “multi‑crew aeroplane” in this instrument, because the aeroplane must be “equipped for multi‑crew operations under the IFR”. This is a static reference - it picks up the IFR as prescribed from time to time.

Other CASA instruments. CASA has issued various instruments under regulation 61.045 for different types of FSTDs (e.g., for helicopter MCC training, or for single‑pilot type ratings). This instrument is one of many. Users must ensure they are using the correct instrument for their specific training activity. The instrument also interacts with CASA’s advisory publications, such as Advisory Circulars that provide guidance on acceptable means of compliance.

International standards and foreign regulations. The instrument is Australian domestic law. It does not adopt international standards (e.g., ICAO Doc 9625) by reference, though some requirements may reflect international practice. For overseas‑manufactured devices, manufacturers may need to meet both Australian standards and their home country’s standards. This can lead to duplication or conflict. For example, if a device meets FAA or EASA standards for MCC training, it may not automatically meet all Australian requirements (e.g., the specific transport delay test or the requirement for at least five aerodromes with 2D and 3D approach procedures - clause 10.4). Training organisations that import devices must conduct a gap analysis.

Work health and safety laws. While not directly referenced, the instrument’s requirements for flight deck layout, seating, and exclusion of distractions (clause 1.1(b), 1.5, 1.6) may have implications under state or territory work health and safety legislation for instructor and trainee safety.

Competition and consumer law. Representations that a device is compliant when it is not may breach the Australian Consumer Law. Training organisations that advertise “MCC training on a qualified FSTD” must ensure the device actually meets this instrument.

Privacy laws. Not directly relevant.

The interaction that matters most to practitioners is the interplay with Part 61 licensing. For example, if a pilot completes MCC training on a device that meets these standards, CASA will accept that training for the grant of a Multi‑crew Pilot Licence (MPL) or for the MCC requirement for an Air Transport Pilot Licence (ATPL). If the device does not meet the standards, the training will not be credited.

The instrument is titled “Edition 1” and is dated 8 September 2015. It commenced on the day after registration. Based on the source text provided, there are no amendments recorded. The instrument appears to have been made in its original form and remains as made. There is no notation of subsequent amendments, replacement instruments, or sunsetting action within the source. The instrument was issued under the Legislative Instruments Act 2003 (now the Legislation Act 2003) and is registered on the Federal Register of Legislation.

Because the source does not include any amendment history, the analyst must treat the instrument as unamended. However, it is possible that later editions or amending instruments exist outside the source. The instrument itself states “Edition 1”, suggesting that later editions may be published. The user of this analysis should check the current version on the Federal Register of Legislation to confirm whether any amendments have been made since 2015.

The instrument was made by Mark Skidmore, then Director of Aviation Safety. The signatory is relevant for understanding the legal validity of the instrument. Executive instruments must be made by the proper delegate.

There is no sunsetting date mentioned in the source. Under the Legislation Act 2003, legislative instruments generally sunset after 10 years unless exempted. This instrument would sunset in 2025 unless remade or exempted. The analyst should verify current status.

The instrument has not been repealed or superseded by a newer instrument within the source.

The source text does not mention any litigation concerning this instrument. No court or tribunal decisions are cited. It is a technical standards instrument, and challenges to such instruments are rare in Australian aviation law. Litigation is more likely to arise from enforcement actions under the parent regulations rather than direct challenges to the instrument itself.

Possible avenues of challenge include an application for judicial review of CASA’s decision to refuse qualification of a device, or a challenge to the validity of the instrument on the grounds that it exceeds the regulation‑making power. No such cases were identified in the source.

The instrument’s detailed technical nature means that disputes are likely to be factual: whether a particular device meets a particular clause. Such disputes would be resolved through administrative review or expert evidence rather than by statutory interpretation of the instrument itself.

The lack of litigation history is not surprising. Most compliance with technical standards is achieved through negotiation and testing, not court proceedings.

Several aspects of this instrument could catch out an unwary practitioner.

1. No motion cue requirement (clause 8). The instrument reserves motion cues, meaning there is no requirement for a motion platform. A training organisation that invests in a full flight simulator with motion may think it automatically meets the standards, but it must still satisfy all other clauses. Conversely, a device without motion is acceptable if it meets the other requirements. This may be underappreciated by those accustomed to traditional simulator standards.

2. The definition of “multi‑crew aeroplane” is narrow and prescriptive. The device must simulate a turbine‑powered, multi‑engine aeroplane with pressurisation, oxygen, retractable undercarriage, engine fire detection/extinguishment, and weather radar. A device that simulates a turboprop without pressurisation, or a jet without weather radar, would not qualify. This restricts the types of aeroplanes that can be simulated for MCC training. Training organisations that simulate a specific aeroplane type must ensure it meets this definition; if it doesn’t, they cannot use this instrument.

3. Transport delay limit is 300 milliseconds (clause 13.3). This is a specific numerical standard. The verification method is either a manufacturer’s systems test or a statement of compliance supported by technical data. The note calls this a “statement of compliance”. If a manufacturer cannot produce a systems test, the statement must still be supported by technical data. A bare statement without data would not satisfy the clause. The 300 ms limit is relatively generous compared to some high‑end simulators, but must be measurable.

4. Visual display field of view minimum: 45° horizontal, 30° vertical per FCM (clause 7.2). This is a relatively low requirement compared to, say, a Level D full flight simulator which often requires 180° horizontal. A device that meets only this minimum may not provide an immersive enough environment for effective MCC training, but it is legally compliant. Trainees may not get adequate peripheral vision cues, which could affect training quality.

5. Only three aerodromes required for visual scenery (clause 12.6). The device must have representative scenery for at least three different real‑world aerodromes in daylight, twilight, and night. This is a minimal requirement. Training organisations that want to train for specific airports may need more scenery, but the instrument does not require it. Also, the daylight visibility requirements (clause 12.7) require the aerodrome to be visible from 10 NM on a straight‑in approach and the runway from 5 NM. That may be challenging for some visual systems.

6. No requirement for motion cues is stated as “Reserved” - but that does not mean “optional”. It means CASA has not yet prescribed a standard; for now, there is no requirement. Future editions may impose motion requirements. Users should not assume that motion will never be required, but currently it is not.

7. The instrument applies to “MCC training for a multi‑crew aeroplane” only. It does not cover MCC training for helicopters, single‑pilot aeroplanes, or other types. Separate instruments may apply. Using this instrument for a non‑qualifying device would be a mistake.

8. Circuit breakers - clause 1.2 note allows scale or photographic representations for circuit breaker panels not required to be operated. This is a concession, but it may create confusion about which circuit breakers are “required to be operated”. The instrument does not define that, leaving it to the training provider to decide. If a circuit breaker is operated during MCC training, it must be functionally accurate per clause 4.4.

9. “No discernible latency” for visual horizon synchronisation (clause 12.12). This is a subjective test. What is “discernible” to one trainee may not be to another. This could be a source of dispute. The note to clause 3.2 defines “no discernible latency” in terms of observable delay compared to the actual aeroplane, but observable by whom? The provision does not specify a measurement method, unlike the transport delay clause. This is a potential gap.

10. The operations manual requirement (clause 13.6) includes “emergency procedures” for the device. This is not about the simulated aeroplane’s emergencies, but about the device itself (e.g., what to do if the visual system fails). This may be overlooked.

11. Maintenance and inspections must be in accordance with manufacturer’s instructions “and any other maintenance and inspections necessary to ensure compliance” (clause 13.5(b)). This imposes a duty to go beyond manufacturer recommendations if needed. If the device drifts out of compliance between scheduled inspections, the operator must take corrective action. This is a strict obligation.

12. The device must have sufficient computer capacity to support its overall fidelity at all times when used for MCC training (clause 13.4). This is a performance requirement, not a design specification. If the computer slows down during a training session, the device could be non‑compliant even if it met the standard at the start.

Compliance with this instrument is a matter of design, verification, documentation, and ongoing maintenance. Here is a practical pathway for a training organisation or manufacturer.

Step 1: Determine the scope. Confirm that the device is intended for MCC training for a multi‑crew aeroplane as defined (turbine‑powered, multi‑engine, with specific equipment). If the aeroplane being simulated does not meet that definition, this instrument is not the correct one.

Step 2: Design or select a device that meets all Schedule 1 requirements. This is primarily a manufacturer responsibility. The device must include a flight deck that represents a multi‑crew aeroplane (clause 1.1), with spatially correct controls that simulate the technique, effort, travel, and direction of the actual aeroplane (clause 1.2). The flight dynamics model must simulate drag‑thrust combinations (clause 2). Ground reaction and handling models must simulate touchdown effects and dry runway stopping forces (clause 3). Aeroplane systems must simulate normal, non‑normal, and emergency procedures (clause 4), with particular attention to communication, navigation, caution/warning, TCAS, TAWS, and anti‑icing (clause 4.7-4.11). Control forces and travel must simulate the actual aeroplane (clause 5). Sound cues must correspond to engine locations (clause 6). Visual display must meet field of view, contrast, brightness, and horizon synchronisation requirements (clause 7). No motion cues needed (clause 8). At least one ATIS broadcast must be simulated (clause 9). Navigation data must support training at real‑world locations, with at least five aerodromes having 2D and 3D instrument approaches (clause 10). Atmosphere and weather simulation must include ISA, IMC, icing, wind, and turbulence (clause 11). The navigation database must have correct terrain and runway orientation, with at least three aerodromes modelled in all three lighting conditions, with full colour and textural cues (clause 12). The instructor station must be positioned to allow observation of the visual scene and have reachable controls for system variables, time freeze, and environment (clause 13.1, 13.2).

Step 3: Verify transport delay. Ensure total transport delay does not exceed 300 milliseconds (clause 13.3). Use the manufacturer’s systems test, or if none exists, obtain a statement of compliance from the manufacturer supported by technical data. Keep this documentation.

Step 4: Ensure adequate computer capacity. Confirm that the computer system can maintain fidelity throughout training sessions (clause 13.4). This may require benchmarking under load.

Step 5: Establish maintenance and inspection regime. Implement a program that follows the manufacturer’s instructions and includes any additional inspections needed to ensure continued compliance (clause 13.5). Keep records of all maintenance and inspections.

Step 6: Develop an operations manual. The manual must describe emergency procedures for the device (e.g., system failures), serviceability tests or checks, and operating procedures for trainees and instructors (clause 13.6). Distribute this manual to instructors and make it available to users.

Step 7: Conduct initial and periodic compliance checks. Before using the device for MCC training, perform a comprehensive check against each clause in Schedule 1. Use a checklist. Re‑check after any significant software or hardware change. CASA may audit, so records must be complete.

Step 8: Engage with CASA if uncertain. The instrument does not require CASA approval of the device before use, but if there is any doubt about compliance, seek guidance. CASA may issue an advisory letter or conduct a voluntary assessment.

Step 9: Keep up with amendments. Monitor the Federal Register of Legislation for any new editions or amending instruments. Edition 1 may be superseded.

Step 10: Consider economic trade‑offs. Meeting the minimum standard may not be commercially optimal. A device that meets only the minimum visual field of view or only three aerodromes may not attract customers who want immersive training. Organisations should decide whether to exceed the standards to gain a competitive edge. However, exceeding the standards does not relieve them of meeting the minimum; it merely adds cost.

Compliance is not a one‑time event. The ongoing maintenance and documentation requirements mean that the duty persists as long as the device is used for MCC training. Failure to maintain compliance can result in training being invalidated and enforcement action.