Prescribed Qualification Standards for FSTD (MCC Training — Helicopter) Instrument 2019 (Edition 1)

The central concept is the FSTD (flight simulation training device), defined in the instrument to have the same meaning as in Part 61 of CASR. The standards apply only when the device is used for MCC training , an approved course of training in multi‑crew cooperation. The target aircraft is a multi‑crew helicopter, defined in s 3 as a turbine‑powered multi‑engine helicopter meeting three cumulative requirements: (a) equipped for multi‑crew operations under the IFR; (b) capable of simulating an engine failure during take‑off, en route, and landing phases in a way identifiable by a flight crew member (FCM); and (c) having appropriate checklists and procedures for managing such an engine failure. This definition is critical: a device that cannot simulate an engine failure as specified, or that is not turbine‑powered or multi‑engine, falls outside the scope of this instrument, and an operator cannot rely on these standards to gain approval for MCC training. The instrument emphasises that the standards are generic, not type‑specific , the device must simulate a representative multi‑crew helicopter, not a particular make and model. Simulate is defined as reproducing, at least in all essential respects, the generic actions and reactions of a multi‑crew helicopter, its systems and equipment, on the ground or in flight, including associated noise and external environmental effects. Latency is defined as the additional time for an FSTD to respond to a control input beyond the basic perceivable time for an actual helicopter to respond to the same input. This is relevant to clause 4.5, which requires instrument indications to respond with no discernible latency. Quantization (stepping) is defined in the note to clause 1.3 , the restriction or limitation of values that would normally be found in a real instrument , and must be avoided for electronically displayed instruments with physical overlay. Model means a particular simulation functionality, for example the flight dynamics model. The note to the definition of multi‑crew helicopter explains that the device must be capable of simulating engine failure and crew responses in a range of circumstances. These definitions are tightly interlinked: the device must be a generic representation, but the generic representation must still meet specific technical thresholds. The concept of reserved for motion cues (clause 8) is noteworthy , it signals that CASA has consciously decided not to require motion, possibly because MCC training can be effectively conducted in a fixed‑base device at lower cost. This is a rare explicit cost‑saving choice in aviation regulation.

The instrument directly affects any person or organisation that owns, operates, or intends to use a helicopter FSTD for MCC training in Australia. This includes flight training organisations, helicopter operators with in‑house training programs, and specialist simulation centres. It also affects manufacturers and suppliers of FSTDs who wish to sell devices for MCC training in the Australian market , they must design and build devices that comply with Schedule 1. Flight crew members (FCMs) receiving MCC training are indirectly affected: the standards are intended to ensure the training device provides a realistic and functionally accurate environment, so the quality of training depends on compliance. CASA is affected as the regulator responsible for assessing devices against these standards and for making decisions under CASR about approval of training courses. The instrument also affects instructors who conduct MCC training in the device: they must be able to operate the instructor station, observe the simulated external environment and each FCM’s actions (clause 13.2), and introduce system variables, time freezes, and environmental changes (clause 13.1). The compliance burden falls most heavily on smaller operators. Meeting the visual display requirements (110° horizontal by 40° vertical field of view, full colour, brightness for daylight, twilight, and night, contrast ratio sufficient to display terrain and runway surfaces, scenery for at least three real‑world aerodromes visible from 10 NM in daylight) is expensive. The navigation database must include instrument approach procedures at no fewer than five different real‑world locations (clause 10.4) and correct terrain modelling and runway orientation (clause 12.1). These are not trivial; they require ongoing data subscription and updates. The maintenance requirements (clause 13.4) impose recurring cost: the device must be maintained in accordance with the manufacturer’s instructions and any other maintenance necessary to ensure compliance. The operations manual (clause 13.5) must describe emergency procedures, checks for serviceability and compliance, and instructor operating procedures , creating an administrative burden. While larger operators may spread these costs across many trainees, a small independent training provider may find the standards prohibitively expensive, potentially reducing competition in the helicopter MCC training market. The instrument does not discriminate by operator size; every device must meet the same prescriptive benchmarks.

The instrument imposes duties on the operator of the FSTD. The primary duty is to ensure the device meets all the qualification standards in Schedule 1 when used for MCC training. This is not a one‑off obligation: the device must be supported by maintenance and inspections in accordance with the manufacturer’s instructions and recommendations, and any other maintenance and inspections necessary to ensure ongoing compliance (clause 13.4). The operator must maintain relevant documents demonstrating satisfactory completion of those activities. The operator must also produce and maintain an operations manual that describes emergency procedures, the tests and checks used to determine serviceability and compliance, and the device’s operating procedures for an instructor conducting training (clause 13.5). The instructor has a duty to be able to observe the simulated external environment and the actions of each FCM (clause 13.2) and must have access to the instructor station to introduce system variables, time freezes, and environmental changes (clause 13.1). The device must have sufficient computer capacity to support its overall fidelity at all times when used for MCC training (clause 13.3). There are also duties relating to the design and configuration of the device. For example, the flight deck or cockpit lighting must represent that of a multi‑crew helicopter (clause 1.6); flight control forces must simulate those of a multi‑crew helicopter (clause 5.1); and the flight dynamics model must simulate various combinations of airspeed and power that give rise to changes in attitude, forces, temperature, altitude, and mass (clause 2). Certain features are mandatory: the device must include a cyclic control trim system operable in pitch and roll axis by each FCM (clause 5.2); a simulated automatic flight control system (clause 4.10); a noise‑attenuating headset communications system for each FCM (clause 4.8(a)); and the ability to generate at least one simulated ATIS broadcast (clause 9). The device must also be able to simulate the effects of operation of the anti‑ice system when selected (clause 4.9). The instrument grants no explicit rights to operators, but the existence of prescribed standards creates a right to have a device assessed against those standards. If a device meets all clauses, CASA should, in principle, accept it as suitable for MCC training. However, the instrument does not create a private right of action; enforcement is through CASA’s powers under CASR. The instructor has the right to adjust the visual display to produce changes to cloud base and visibility (clause 11.2) and to control the simulated environment. The FCM receiving training has no duties under this instrument, but benefits from the assurance that the device meets minimum fidelity requirements.

The instrument itself does not create penalties. It prescribes qualification standards under regulation 61.045 of CASR. Enforcement flows from the parent regulations. If an operator uses an FSTD for MCC training that does not meet these prescribed standards, that use may be a contravention of CASR , likely a breach of the conditions under which the device or the training course is approved. The Civil Aviation Act 1988 and CASR contain civil penalty provisions for operating training devices without approval or in a manner that does not comply with prescribed standards. Civil penalties for corporate operators can be substantial (up to $1.1 million or more for serious breaches, depending on the provision). Individual directors and accountable persons may also face personal liability under Part 13 of the Act. CASA can also issue infringement notices (on‑the‑spot fines) for less serious breaches, suspend or cancel approvals, or issue directions to cease use of a device. The instrument’s technical specificity means that enforcement often involves expert assessment. For example, a device with a visual display field of view less than 110° horizontally would be non‑compliant (clause 7.2), regardless of whether the operator believes the training is effective. The note to clause 8 states there is no requirement for motion cues, so an operator cannot be penalised for lacking motion; but an operator who adds motion must still ensure that the motion system does not cause non‑compliance with other clauses (e.g., introducing latency). The maintenance and documentation requirements (clauses 13.4-13.5) create ongoing record‑keeping obligations. Failure to maintain records could itself be a breach, even if the device is technically compliant. CASA may conduct audits of FSTD operators. The instrument provides a clear checklist for inspectors. Because the instrument is prescriptive rather than performance‑based, there is limited room for an operator to argue that a non‑compliant feature is acceptable because the training outcome is still achieved. This reduces enforcement discretion but also raises the stakes for operators who inadvertently fail a technical requirement. The penalty regime therefore serves as a strong deterrent against cost‑cutting that would sacrifice fidelity. However, the absence of a grandfathering clause means existing devices that do not meet the new 2019 standards would need retrofit or replacement, imposing capital costs that could drive marginal operators out of the market.

This instrument is made under regulation 61.045 of CASR 1998. It sits within the broader CASR framework for flight crew licensing (Part 61) and training and checking (Part 142). The definition of flight simulation training device in CASR 61.010 includes, at paragraph (d), a device used for MCC training that meets prescribed qualification standards. This instrument supplies those standards. If a device is used for other types of training (e.g., type‑specific endorsement, instrument rating renewal), different qualification standards may apply under other instruments made under CASR , this instrument does not cover non‑MCC training. The instrument also interacts with the Civil Aviation Regulations 1988 (CAR) through definitions: s 3(1) says words and phrases have the same meaning as in Part 61 of CASR, but s 3(2) adopts the meaning from CAR for the term CAR. In practice, CAR definitions may affect interpretation of concepts like helicopter landing site (HLS) used in the schedule. The instrument does not override the Civil Aviation Act 1988 or the Occupational Health and Safety laws that may apply to FSTD operation. If a device is used in a workplace, state and territory WHS laws impose duties on the operator to ensure a safe system of work, which may include ergonomic seating, electrical safety, and fire protection , matters not addressed in this instrument. The instrument also does not affect intellectual property rights in simulation software or hardware. The requirement that the device have an operations manual (clause 13.5) may interact with the operator’s exposition or manuals required under Part 142 of CASR for approved training organisations. Duplication should be avoided but the instrument imposes a specific requirement separate from the Part 142 manual. The instrument does not address data retention or privacy; operators must look elsewhere for obligations regarding recording of training sessions. There is no conflict with international standards such as ICAO Doc 9625 or FAA AC 120‑63, but CASA has chosen its own prescriptive standards rather than adopting those international benchmarks. This can increase compliance costs for operators who wish to use the same device for overseas training or who import devices certified to foreign standards. They may need to modify the device or demonstrate equivalence , a process not addressed in this instrument.

The instrument as provided is Edition 1, made on 13 September 2019 by the Acting Director of Aviation Safety, Graeme M. Crawford, and it commenced on the day after registration. The text does not indicate any subsequent amendments; it is the original version. Because the instrument is delegated legislation registered on the Federal Register of Legislation, it may have been amended by later instruments (such as amending instruments made under the same regulation), but those amendments are not reflected in the source provided. An operator relying on this instrument should check the current version on the Federal Register of Legislation. As of the date of this writing, no amending instruments are listed in the source. The instrument does not contain a sunset clause or review date, so it remains in force indefinitely unless repealed or replaced. The note style and the presence of a “Reserved” clause for motion cues suggest the drafters anticipated future amendment to add motion standards if needed. The instrument may be updated as technology evolves or as CASA’s policy on FSTD fidelity changes. Given that it is 2019 edition and helicopter simulation technology is advancing, it is plausible that an Edition 2 may have been issued or is in development, but this instrument as provided remains the operative standard for the purposes of this analysis. Operators should be aware that relying on an outdated edition could lead to non‑compliance if a later edition imposes stricter requirements. The definition of multi‑crew helicopter may also be affected by changes to Part 61 of CASR, since the instrument incorporates the meaning from that Part. Any amendment to Part 61 could indirectly alter the scope of this instrument without a direct amendment to it. This is a source of regulatory risk: the operator must track amendments to the parent legislation as well.

The source text contains no references to court proceedings, judgments, or administrative reviews concerning this instrument. Because the instrument is a legislative instrument made by CASA, it is subject to judicial review under the Administrative Decisions (Judicial Review) Act 1977 and to merits review by the Administrative Appeals Tribunal (now the Administrative Review Tribunal) if a person is aggrieved by a decision made under it , for example, a refusal by CASA to accept a device as meeting the prescribed standards. No reported decisions specifically on this instrument have been found in the source. However, the broader area of FSTD qualification in Australia has seen some litigation over CASA’s exercise of discretion under CASR, particularly regarding approval of training devices and courses. The prescriptive nature of this instrument may reduce the scope for challenge: if a device meets the black‑letter requirements, CASA has limited basis to refuse; if a device fails any single requirement, the operator has limited grounds to argue it should still be accepted. This could make litigation rare. Conversely, disputes may arise over interpretation of terms such as “discernible latency”, “functionally correct”, or “simulate” , these are qualitative and may be contested. No case law interpreting these specific clauses has been cited. The instrument’s note to clause 8 (no motion requirement) could be litigated if an operator claims that a device without motion cannot realistically simulate a multi‑crew helicopter, but the instrument makes that a conscious policy choice, so such a challenge would likely fail. The absence of litigation history to date may indicate that operators accept the standards and that CASA’s enforcement has been consistent, or that the instrument is relatively new and disputes have not yet reached the courts. It may also be that the high cost of challenging CASA decisions deters litigation. For compliance professionals, the lack of case law means that uncertain interpretations remain unresolved, increasing legal risk. Practitioners should advise clients to seek written CASA guidance where any clause is ambiguous, rather than rely on a private interpretation.

Several provisions create traps for the unwary. First, the definition of multi‑crew helicopter is narrower than a casual reading suggests. The device must simulate a turbine‑powered multi‑engine helicopter equipped for multi‑crew IFR operations, capable of simulating an engine failure in a way identifiable by an FCM, and with appropriate checklists and procedures. A device that simulates a single‑engine turbine helicopter or a multi‑engine piston helicopter does not qualify, even if it is used for multi‑crew type operations. The note to the definition clarifies that the device must be able to simulate engine failure and FCM inputs to manage it. An operator who purchases a device simulating a light twin piston helicopter for MCC training would find it does not meet the standard; the device would be useless for that purpose. Second, the device must represent a generic multi‑crew helicopter, not a specific type. This means an operator cannot use a device that is type‑specific for a particular model (e.g., a Bell 429 or Airbus H145) unless it also meets the generic standard for the non‑type‑specific aspects. The generic requirement may conflict with the desire for type‑specific training. Third, the visual display field of view is a hard minimum: 110° horizontal and 40° vertical (clause 7.2). Devices with a narrower field of view, even if otherwise excellent, are non‑compliant. Fourth, the navigation database must include instrument approach procedures at no fewer than five different, real‑world locations that support instrument approach operations (clause 10.4). This is an ongoing cost: the database must be maintained and updated. An operator with only one base location cannot rely on simulated approaches at that single area; they must purchase data for at least five locations. Fifth, the device must include representative scenery for at least three specific, real‑world aerodromes as they appear in daylight, twilight, and night (clause 12.3). This requires high‑quality visual database content for multiple aerodromes, not just generic out‑the‑window views. Sixth, the instructor must be able to observe the simulated external environment and the actions of each FCM (clause 13.2). This may require remote viewing stations or internal cameras, adding cost. Seventh, motion cues are reserved , no requirement , but if an operator chooses to install motion, they must ensure it does not introduce latency or other non‑compliance. Many operators might assume motion is necessary; it is not, and the reserved clause is a deliberate cost‑saving. Eighth, the maintenance requirements (clause 13.4) refer to the manufacturer’s instructions and any other maintenance necessary to ensure compliance. This may impose obligations beyond the manufacturer’s recommended schedule if the device develops issues that affect fidelity. Ninth, the operations manual must describe tests and checks to determine serviceability and compliance , a self‑audit requirement that is often overlooked until an audit reveals its absence. Tenth, the device must have sufficient computer capacity to support its overall fidelity at all times (clause 13.3). An operator who upgrades software without upgrading hardware may find performance degraded and the device non‑compliant. Finally, the definition of latency uses “discernible” , a subjective term that could be contested. An operator should aim for zero perceivable latency, not just within some tolerance.

To comply with this instrument, an operator must first ensure the FSTD meets every requirement in Schedule 1. This is a comprehensive technical audit. The operator should create a compliance matrix mapping each clause to a specific feature of the device, with evidence of conformity. For example, clause 1.1 requires the flight deck layout to represent that of a multi‑crew helicopter and to be enclosed or perceived as enclosed. The operator should photograph or document the cockpit configuration and demonstrate it matches a typical multi‑crew helicopter design. Clause 1.2 requires control manipulation characteristics (technique, effort, travel, direction) to simulate those of a multi‑crew helicopter; this may require engineering validation reports from the manufacturer or independent testing. Clause 1.3 prohibits quantization in electronically displayed instruments , the operator must verify the display system has continuous, not stepped, values. Clause 1.4 requires seating that enables each FCM to achieve the optimal eye‑point position; ergonomic assessment may be needed. For the flight dynamics model (clause 2), the operator must be able to simulate the full range of airspeed and power combinations giving rise to changes in attitude, forces, temperature, altitude, and mass. This typically requires a validated mathematical model. The operator should hold documentation from the manufacturer showing the model has been verified against flight test data of a representative helicopter. For ground reaction (clause 3.1), the device must allow the FCM to determine when the simulated helicopter has landed. A simple binary indication is not enough; the ground reaction model must produce realistic cues. If the device simulates ground taxi, the ground handling model must simulate taxiing (clause 3.2). Systems simulation (clause 4) requires functionally correct normal, non‑normal, and emergency procedures, including interdependencies. Circuit breakers operated during training must be functionally accurate (clause 4.4). Instrument indications must respond automatically to control inputs and atmospheric disturbance with no discernible latency (clause 4.5). This can be tested by timing the response to a step input. The operator must verify all mandatory systems listed in clauses 4.7-4.12 are present, including communications, navigation, caution/warning, headsets, push‑to‑transmit switches, frequency selection, anti‑ice effects, autopilot, and TCAS/TAWS if fitted. The visual display must meet the field of view (clause 7.2), distance requirement (clause 7.3), perspective changes during approach, hover, and lift‑off (clause 7.4), contrast ratio (clause 7.5), brightness for daylight, twilight, and night (clause 7.6). The operator should have calibration reports showing these parameters are met. The visual system must provide correct horizon depiction (clause 12.2), scenery for at least three aerodromes with full colour and daylight visibility from 10 NM (clause 12.3-12.4), moving objects (clause 12.6), self‑illuminated objects for night and twilight (clause 12.8), and synchronised horizon (clause 12.9). The navigation database must include instrument approaches at five real‑world locations (clause 10.4), accurate terrain and runway orientation (clause 12.1), and be useable without restrictions within range/line‑of‑sight (clause 10.3). The device must generate at least one ATIS broadcast (clause 9). The atmosphere simulation must include temperature, IMC, icing, surface wind speed/direction, and turbulence (clause 11.1), with instructor‑adjustable cloud base and visibility (clause 11.2). The instructor station must allow introduction of system variables, time freezes, and environmental changes (clause 13.1), and the instructor must be able to observe the simulated external environment and each FCM’s actions (clause 13.2). The device must have sufficient computer capacity (clause 13.3) and be supported by documented maintenance and inspections (clause 13.4). An operations manual must be created covering emergency procedures, serviceability checks, compliance checks, and instructor operating procedures (clause 13.5). The operator should keep records of initial qualification testing, periodic re‑qualification, maintenance logs, and any software/hardware changes that could affect compliance. It is advisable to create a compliance binder for CASA inspection. The operator should also engage a CASA‑approved FSTD evaluator to conduct an initial assessment and periodic re‑assessments, as CASA may require independent validation. Costs will include software licenses, visual database acquisition and updates, engineering time, and potential hardware upgrades. The most efficient path is to purchase a device that already holds a CASA qualification against these standards; however, even then the operator must ensure ongoing compliance through maintenance and documentation.