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U.S. Department of Transportation

FEDERAL AVIATION

ADMINISTRATION

FINAL REGULATORY IMPACT ANALYSIS

FINAL RULE

Flight Simulation Training Device Qualification Standards for

Extended Envelope and Adverse Weather Event Training Tasks

(14 CFR 60)

OFFICE OF AVIATION POLICY AND PLANS

ECONOMIC ANALYSIS DIVISION

APO-300

November 20, 2015

Carole L. Gaelick
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Table of Contents

List of Abbreviations and Definitions............................................................................................. 3

Executive Summary ........................................................................................................................ 4

I. Background .................................................................................................................... 10

A. Discussion of the Problem ............................................................................................. 10

B. Background on Flight Simulation Training Devices...................................................... 10

C. Discussion of the Final Rule .......................................................................................... 11

II. Final Rule Changes with Minimal Cost Impact............................................................. 14

III. Costs............................................................................................................................... 15

A. Cost Estimate Updated Due to Industry Input ............................................................... 15

i. Differences between cost estimates in the NPRM and the final rule.............................. 17

ii. General Assumptions.............................................................................................................17

iii. Estimate of the Cost of Modifying FSTDs to Support the New Training Rule....................19

iv. Estimate of the Cost of Icing Modifications.........................................................................36

v. Cost of the Flight Simulator Training Device Directive ........................................................36

vi. Licensing Fees......................................................................................................................39

vii. Estimate of the Cost of Aligning With ICAO......................................................................40

IV. Benefits........................................................................................................................... 44

A. Benefit of Modifying FSTDs to Support the Crewmember and Aircraft Dispatcher 

Training final rule........................................................................................................... 44

B. Benefit of Icing Modifications....................................................................................... 46

C. Benefits of Aligning with ICAO..................................................................................... 46

V. Conclusion...................................................................................................................... 47

Appendix A - FSTDs Potentially Affected by the Proposed FSTD Directive............................... 50

Appendix B Full Definitions ........................................................................................................ 60

Appendix C Definitions of FSTD Levels...................................................................................... 62

Appendix D Changes between the Final Rule and the NPRM ..................................................... 64

Appendix E Cost Estimates of Standard Data Updates (Pre-updates) to FSTDs.......................... 69
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List of Abbreviations and Definitions

AC – Advisory Circular

AOA – Angle of Attack

ARC – Aviation Rulemaking Committee

AURTA – Airplane Upset Recovery Training Aid

FFS – Full Flight Simulator

FTD – Flight Training Device

FSTD – Flight Simulation Training Device

ICAO – International Civil Aviation Organization

ICATEE – International Committee on Aviation Training in Extended Envelopes

LOCART – Loss of Control Avoidance and Recovery Training Working Group

NPRM – Notice of Proposed Rulemaking

OEM – Original Equipment Manufacturer

QPS – Qualification Performance Standards

RIA – Regulatory Impact Analysis

SPAW ARC – Stick Pusher and Adverse Weather Event Training Aviation Rulemaking Committee

STIG - Simulator Technical Issues Group

UPRT – Upset Prevention and Recovery Training
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Executive Summary

The FAA is issuing this final rule to define simulator fidelity requirements for several new and 

modified training tasks mandated for air carrier training programs by the Airline Safety and 

Federal Aviation Administration Extension Act of 2010 (Public Law 111-216) and now required 

by the Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers final rule (to be 

referred to as the Crewmember and Aircraft Dispatcher Training final rule) [78 FR 67800 (Nov.

12, 2013)]. In response to this rule, the FAA published a Notice of Proposed Rulemaking entitled 

” Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse 

Weather Event Training Tasks” on July 10, 2014, to amend the part 60 Qualification Performance

Standards (QPS) for flight simulation training devices (FSTDs). 

The Crewmember and Aircraft Dispatcher Training final rule added training requirements for 

pilots in part 121 operations that target the prevention of and recovery from stall and upset 

conditions, recovery from bounced landings, enhanced runway safety training, and enhanced 

training on crosswind takeoffs and landings with gusts. Stall and upset prevention requires pilot 

skill in manual handling, maneuvers, and procedures. Therefore, the manual handling maneuvers 

most critical to stall and upset prevention are included as part of the agency’s overall stall and 

upset mitigation strategy. These maneuvers are identified in the Crewmember and Aircraft 

Dispatcher Training final rule within the “extended envelope” training provision, which further

requires that these maneuvers be completed in an FSTD. In order to avoid training in FSTDs that 

may lack the fidelity needed to effectively accomplish the training, revisions to part 60 are
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required to fully implement the extended envelope flight training tasks as well as the bounced 

landing, and gusty crosswinds flight training tasks required by the Crewmember and Aircraft 

Dispatcher Training final rule.

To meet these new training requirements, the final rule seeks to establish new or updated FSTD

technical evaluation standards for

• full stall and stick pusher maneuvers,

• upset recovery maneuvers,

• maneuvers conducted in airborne icing conditions,

• bounced landing recovery training, and

• training in gusting crosswinds.
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These new and improved technical standards also address National Transportation Safety Board 

(NTSB) safety recommendations and Aviation Rulemaking Committee (ARC) recommendations.

The final rule also updates the FSTD technical standards to better align with current international 

FSTD evaluation guidance. It further introduces a new FSTD level that expands the number of 

qualified flight training tasks that can take place in a fixed-base flight training device (FTD). The 

changes should ensure that the training and testing environment is accurate and realistic, will 

codify existing practice, and will provide greater alignment with international guidance for

simulation. 

In general, amendments to the part 60 qualification performance standards (QPS) do not directly

apply to previously qualified FSTDs, as these FSTDs are grandfathered. However, an FSTD 

Directive that is finalized with this rule codifies new FSTD technical standards for specific 

training tasks which extends the requirements of this rule to previously qualified FSTDs that will 

be used to train those specific tasks. The costs of the FSTD directive are considered costs of the 

final rule.

In this analysis, the FAA derives an updated cost estimate to the NPRM estimate. This cost 

estimate uses additional information gathered from air carriers, FSTD manufacturers, and data 

providers to better estimate the cost of this rule. In the summary table below we compare this

estimate to that derived for the NPRM Regulatory Impact Analysis (RIA).
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For the NPRM estimate and the updated cost estimate we calculate three separate sets of costs.

The first set of costs will be incurred to make the necessary modifications to the FSTDs to enable

training required by the new Crewmember and Aircraft Dispatcher Training final rule. The

training cost for the Crewmember and Aircraft Dispatcher Training final rule provides rental 

revenue to simulator sponsors, which will fully compensate them for their FSTD modification

expenses. These simulator revenues were accounted for as costs of the additional training and 

were fully justified by the benefits in that rule. 

The second set of costs will be incurred for the evaluation and modification of engine and airframe

icing models, which will enhance existing training requirements for operations using anti-icing/deicing equipment to satisfy NTSB safety recommendations. Avoiding one severe injury provides 

sufficient benefits to justify the estimated cost of evaluating and modifying engine and airframe 

icing models to comply with this final rule.

Lastly there is a set of changes to part 60 QPS appendices that will align the simulator standards 

for some FSTD levels with those of the latest International Civil Aviation Organization (ICAO)

simulator evaluation guidance. This last set of changes will only apply to FSTDs that are initially 

qualified after this rule becomes effective. The FAA expects unquantified safety improvements to 

result from these changes through more realistic training. The changes are expected to improve 

overall simulator fidelity by enhancing the evaluation standards for visual display resolution, 

system transport delay, sound direction, and motion cueing. The FAA also expects a reduction in 
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burden due to redundant evaluation and documentation requirements that are necessary to meet 

multiple national regulations and standards. 

The table below summarizes the estimated costs and benefits of this final rule. For comparison the

table shows the estimated costs derived for the NPRM, and provides an updated cost estimate for 

the final rule. The table indicates the three separate sets of costs described above and incurred over 

a ten-year period.
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NPRM 

Estimate

Final Rule 

Cost 

Estimate

Final Rule 

Cost 

Estimate 

Present 

Value at a 

7% Rate

Final Rule 

Cost 

Estimate 

Present 

Value at a 

3% Rate

FSTD Modifications for New Training 

Requirements

Cost $45,215,480 $72,716,590 $63,610,049 $68,562,049

Benefits Rational simulator owner will choose to comply

Icing provisions

 Cost $468,000 $1,256,250 $1,098,926 $1,184,476

 Benefits

Only one prevented severe injury valued at $2.5 

million makes the icing benefits exceed the costs.

Aligning Standards with ICAO

 Cost $6,695,000 $6,875,000 $5,356,979 $6,132,690 

 Benefits Improved safety and cost savings.

Total Cost $52,378,480 $80,847,840 $70,065,954 $75,879,215

Totals may not add due to rounding.
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I. Background 

A. Discussion of the Problem

A potential lack of simulator fidelity could contribute to inaccurate or incomplete training on new 

training tasks that are required by the Crewmember and Aircraft Dispatcher Training final rule, as 

well as existing training requirements for operations using anti-icing/de-icing equipment. This 

potential lack of fidelity could lead to a safety risk. This rule seeks to address those issues and better 

align FSTD standards with the International Civil Aviation Organization (ICAO) standards to solve 

the problem of inconsistency between U.S. requirements and ICAO guidance for not yet qualified 

FSTDs. 

B. Background on Flight Simulation Training Devices

FSTDs are used to provide flight training to pilots and are located at flight training centers and at 

air carriers. A pilot can receive all flight training for an aircraft type rating in FSTDs. It is 

important that these FSTDs reproduce as accurately as possible the flight environment that the

pilot will actually encounter in the flight deck.

FSTD includes flight training devices (FTD) and full flight simulators (FFS). The main difference

between an FTD and a FFS is that an FTD does not require a motion cueing system. The current 

FTDs for fixed wing aircraft are not qualified for some training tasks that require ground effect 
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and ground reaction modeling such as take-off, landing or taxiing.

1 The final rule defines a new

level fixed wing FTD (Level 7 FTD) which would be qualified for these training tasks.

C. Discussion of the Final Rule

This final rule establishes new and updated FSTD technical evaluation standards for full stall and 

stick pusher maneuvers, upset recovery maneuvers, flight in airborne icing conditions, takeoff and 

landing maneuvers in gusting crosswinds, and bounced landing recovery maneuvers. This final rule 

also partially aligns the technical standards for Level C and D (fixed wing) FSTDs that are defined 

in 14 CFR part 60 with the current international FSTD evaluation guidelines published in the 

International Civil Aviation Organization (ICAO) document 9625, Edition 4, Manual of Criteria for 

the Qualification of Flight Simulation Training Devices.

The modification requirements will apply differently to newly qualified 2 FSTDs than to 

previously qualified FSTDs. All requirements in the Qualification Performance Standards (QPS)

appendices will apply directly to applicable newly qualified FSTDs with the exception of full stall 

training tasks, which will be evaluated and qualified by the FAA when requested by the FSTD 

sponsor. Only the requirements to meet the new FSTD technical standards for the first five training

tasks listed in the section below will apply to previously qualified FSTDs through an FSTD 

Directive. Compliance with the FSTD Directive will be optional in that only those FSTDs that will 

be used to conduct the affected training tasks will require evaluation in accordance with the

Directive. The rule cannot generally apply directly to previously qualified FSTDs because Part 60 

 1 The highest level of FTD in part 60 (a Level 6 FTD) does not require modeling or validation testing for ground 

reaction and ground handling maneuvers. Furthermore, no part 60 defined fixed wing FTD requires motion or visual 

display cueing systems. 

2 FSTDs that are initially qualified or upgraded in qualification level after the final rule becomes effective.
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contains grandfather rights for previously qualified FSTDs. However, the FAA has the ability to 

invoke an FSTD Directive 3 to require modification of previously qualified FSTDs, if there is a

safety of flight issue. FSTD Directives are maintained in the QPS appendices of part 60.

Improving fidelity of FSTDs used in training tasks

The rule will require FSTDs be evaluated and modified to improve fidelity so they more

accurately replicate the actual environment when being used in training tasks. Listed below are 

the fidelity improvements (requirements):

1. Stall training maneuvers that are conducted at angles of attack higher than the activation 

of the stall warning system. This does not include approach-to-stall maneuvers where 

recovery is initiated at the activation of the stall warning system.

2. Upset recovery training maneuvers that may result in exceeding the parameters of an 

aircraft upset: pitch attitude greater than 25 degrees nose up; pitch attitude greater than 10 

degrees nose down; bank angle greater than 45 degrees; or flight at airspeeds 

inappropriate for conditions.

3. Takeoff and landing training tasks with realistic gusting crosswind scenarios.

4. Bounced landing recovery training tasks.

5. Training maneuvers that demonstrate the aircraft specific effects of engine and 

airframe ice accretion.

 3 The FSTD Directive process has provisions for mandating modifications to FSTDs retroactively for safety of flight 

reasons. See 14 CFR Part 60, § 60.23(b)
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The first four fidelity improvements are necessary to support the new Crewmember and Aircraft 

Dispatcher Training final rule ensuring that the training occurs in FSTDs that more accurately 

reflect the actual flight environment. The fifth fidelity improvement will support training that is 

currently required by Part 121 Appendix E (Flight Training Requirements), Section III(f)(8) - antiicing and deicing, also ensuring the FSTDs are more representative of the actual flight 

environment. This improvement is based on NTSB safety recommendations, as well as 

recommendations from ICATEE and the SPAW ARC and aligns with the updated ICAO 9625.

FSTD sponsors of previously qualified FSTDs will be required to evaluate and modify only 

those FSTDs used for these specific training tasks, which are listed as the first five fidelity 

improvements above. All newly qualified FTSDs will be required to be evaluated against all the

new standards except for the full stall evaluation requirements, regardless of whether they are

used in the specified training. The qualification of full stall training tasks will be optional as 

requested by the sponsor to support FAA approved training being conducted in the FSTD. 

Alignment with ICAO guidance

The rule also introduces changes intended to align the part 60 technical standards with the latest 

ICAO FSTD evaluation guidance document. These standards will address new aircraft and 

simulation technology introduced since the original issuance of part 60, incorporate general 

improvements to the part 60 standards, and provide air carriers and flight training providers with 

additional options for conducting approved training tasks in a fixed base FTD.

 The rule will require alignment of the part 60 technical standards for Levels C and D
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fixed wing FFSs with those of the current international guidance for Type VII FSTDs, as 

published in the ICAO 9625 Edition 4, Manual of Criteria for the Qualification of Flight 

Simulation Training Devices. All newly qualified Level C and Level D FFSs after the 

part 60 change becomes effective, will require evaluation under the aligned standards.

 Level 7 FTD – This rule will also introduce a fixed-base FTD similar to that of a Type

V FSTD as defined in the ICAO 9625 Edition 4, Manual of Criteria for the 

Qualification of Flight Simulation Training Devices.

II. Final Rule Changes with Minimal Cost Impact

There are 29 major changes in the final rule relative to the NPRM, which are listed along with the 

rationale for the change and the cost impact in Appendix D. These changes are in the general areas 

of: Full Stall Evaluation, Upset Prevention and Recovery Training (UPRT) Evaluation, Engine and 

Airframe Icing Evaluation, Gusting Crosswind Evaluation, Bounced Landing Recovery Evaluation, 

and ICAO 9625 Alignment. None of those changes result in cost increases. 

For example, one change in response to comments to the NPRM is that the FAA decided not to 

increase the visual system field of view requirements to 200 degrees (horizontal). A commenter 4

said that the cost of the proposed field of view expansion would add an estimated 20 to 30% to the 

cost of a visual system for the purchasing of a newly qualified FSTD depending on the 

manufacturer. 

 4 Airlines for America, FAA-2014-0391-0115
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III. Costs

Commenters asked how an estimate can be provided if costs were unknown. The FAA now has 

better cost data from industry and to respond to comments is using this data to update the estimates 

in this regulatory evaluation. The methodology is generally the same as in the initial regulatory 

evaluation but has a greater level of granularity. First we determine what changes to FSTDs are 

required, estimate the cost of these changes and multiply cost/unit by affected units. In this final 

regulatory evaluation we have included these final compliance costs: cost to evaluate and modify 

the FSTDs to comply with the rule so the new training tasks can occur in the FSTD, cost for 

technicians to travel to the FSTD site, cost of additional icing modifications and the cost of aligning 

newly qualified FSTDs with ICAO.

A. Cost Estimate Updated Due to Industry Input

The FAA has updated its cost estimate in this final rule with additional information gathered from 

air carriers, FSTD manufacturers, and data providers to better estimate the cost of this rule. Due to 

industry provided information, as well as further analysis conducted on FAA FSTD qualification 

records, the FAA adjusted the classifications used to estimate costs in this final rule from those in 

the NPRM. This adjustment provides greater granularity in the cost analysis and captures more 

components of the cost necessary to modify FSTDs.

The FAA now divides FSTDs into those that will likely use an aircraft Original Equipment 

Manufacturer (OEM) solution and those that will likely use third party provided solutions. Within 

those using OEM solutions, there are some that can be modified without significant updates to the 

existing aerodynamic models/data packages and others that will need to be “pre-updated” to the 
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latest data revision or blockpoint of their current data package before modifications to meet this 

final rule requirements can occur. The FAA has parsed these FSTDs into seven separate categories 

with different costs. 

One aircraft OEM simulator data provider has indicated that the estimated cost of an enhanced stall 

model would be in the area of $25,000 per FSTD. Furthermore, this data provider stated that in 

order to support the installation of an enhanced stall model, FSTDs running certain versions of their 

data package would need to be brought up to the latest revision or blockpoint before this installation 

can take place. The term “pre-update” will be used to refer to this action. These data packages 

included older versions that have undergone several revisions over the past several years.

For the final rule cost estimate, the FAA reviewed details on FSTDs to categorize them into 

groupings requiring different complexity levels of pre-update. The FAA reached out to industry to 

obtain estimates of these pre-update costs. These updates add costs to the model that were 

unanticipated when the NPRM was released. More explanation on how the FSTDs needing preupdate were categorized and the estimated costs for the pre-updates are presented later in this 

document.

Additionally, since it is apparent that some FSTD data packages will not be supported with updates 

provided by the aircraft OEM or original data provider to meet the requirements of this rule, the 

FAA investigated the costs associated with contracting a third party data provider to conduct such 

modifications on existing FSTDs. The FAA obtained an estimate of $88,000 per FSTD from a third 

party provider for the cost of developing and installing a third party stall model/UPRT solution. 
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The FAA has revised the estimate using the new data and information to calculate an alternative 

cost estimate for the final rule. This methodology is described in subsequent sections.

i. Differences between cost estimates in the NPRM and the final rule

In the original RIA, FSTDs were divided into “complex” and “simple” projects and the cost of 

aerodynamic model development was distributed amongst FSTDs that shared the same aerodynamic 

model. Because the new data on the cost of aerodynamic development have been given on a per 

FSTD basis, no such cost distribution was necessary in the final rule estimate. In the final rule 

estimate, FSTDs are separated into those that will likely use “aircraft OEM” solutions and those that 

will likely need “third party” solutions that are not provided by an aircraft OEM. Within those that 

will likely use “aircraft OEM” solutions, FSTDs are further divided into subsets that require varying 

amounts of updates (referred to as pre-updates) to bring them to the latest revision or blockpoint of 

their existing data packages where required by the original data provider before installation of the 

enhanced stall model. Some FSTDs that will have an OEM solution available may not need preupdates and these loosely align with the “simple” projects in the original RIA. The other FSTDs 

align with the “complex” projects of the original RIA.

ii. General Assumptions

• Given the normal regulatory cycle we estimate the final rule will be published and 

become effective in March 2016. After March 12, 2019, previously qualified FSTDs 

that will be used to accomplish the specific training tasks defined in FSTD Directive 

No. 2 must meet the evaluation and qualification requirements defined in the Directive. 
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Newly qualified FSTDs will have to be evaluated in accordance with the new QPS 

requirements 60 days after the publication of the final rule, subject to up to a two-year

grace period as defined in 60.15(c).

• Estimates are in 2012 $. Where estimates have been provided in 2015 $ the FAA 

converted to 2012 $ using the Gross Domestic Product chained price index. 5 

Estimates taken from the NPRM (RIA) were based on data received by the FAA in 

March 2013. The FAA assumes these costs were close enough to 2012 costs, so as to 

be considered generated in 2012 $.

• The estimated number of previously qualified FSTDs that will potentially be affected by

the rule (335) includes all FSTDs that are capable of providing training to 121 operations 

and as such are likely to be an overestimate of the number of FSTDs that will be affected 

by this rule. For instance, some of these FSTDs are sponsored by training centers. 6

which may not offer training that is subject to the FSTD Directive.

• One third of the applicable previously qualified FSTDs will be evaluated starting in the 

year of final rule publication and during each of the following two years.

• As in the NPRM RIA analysis for newly qualified FSTDs, we expect minimal 

incremental cost to meet the standards for the new tasks in the Crewmember and Aircraft 

Dispatcher Training final rule and the standards for icing. The estimated number of 

newly qualified FSTDs each year increases by one from 22 to 23, based on new data. 

Other than that there are no changes to the cost estimates for newly qualified FSTDs to 

be brought into compliance with the rule.

 5 Office of Management and Budget, Historical Tables - Table 10.1 6 There are training centers that are not owned or operated by part 121 air carriers and may not choose to offer training for

those tasks defined in the FSTD Directive however we assume all part 121 FSTDs will be modified.
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• Development costs 7 for newly qualified FSTDs to comply with ICAO guidance will 

be incurred the year the rule publishes.

iii. Estimate of the Cost of Modifying FSTDs to Support the New Training Rule

The following paragraphs describe the derivation of costs that will be incurred to support 

the new training rule. To comply with this final rule, FSTD sponsors will incur cost for:

• Where required by the FSTD’s original data provider, updating (pre-update) those FSTDs 

that are not at the latest revision or blockpoint before the installation of an enhanced stall 

model can occur. 

• Evaluation and modification of the FSTD to meet the requirements of the final rule 

including development of the aerodynamic math model, implementation of the model 

including installation and associated validation data, meeting requirements for gusting 

crosswinds and bounced landing and taking the FSTD offline during model implementation

(lost productivity).

• Purchasing a new Instructor Operating System (IOS) for a few FSTDs.

• Travel for technicians to go to a site for implementation of the models;

 7 Development costs include non-recurring costs the manufacturer would incur to develop a standard qualification test

guide (QTG) template and testing methods to meet the new ICAO standard and recurring costs the manufacturer would

incur to develop an aircraft specific QTG template that can be used by FSTDs of the same aircraft type
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The costs to meet the requirements for gusting crosswinds, bounced landing, implementation and 

lost productivity are taken from the NPRM estimates, as we did not receive comments during the 

comment period offering better estimates. 

New cost estimates were derived for this final rule that were not included in the NPRM. These new 

estimates include the cost of pre-updating FSTDs that are not at the latest revision or blockpoint, 

development of the aerodynamic math model, and travel costs.

FSTD Cost Estimates

To estimate costs of modifying FSTDs to support the new training rule, we group FSTDs into 

several categories depending on the specific costs that will have to be incurred. The FSTDs will

either use a third party solution or an OEM provided solution. FSTDs that use an OEM solution are

those in which the original data provider will likely develop and sell an aerodynamic model update 

to meet the requirements of the FSTD Directive for previously qualified FSTDs. We assume for all 

FSTDs for which an aircraft OEM solution will likely be available, the sponsor will choose this 

option even in cases where a third party provided solution may be less costly. 

The selection in this analysis of FSTDs that will likely have an OEM supplied solution available is 

based on information provided by one major aircraft OEM data provider concerning data packages 

they plan to support with an enhanced stall model solution. The FAA assumed other manufacturers 

will likely provide a similar OEM solution for data packages of a similar age that they still support. 
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Where OEM solutions are not anticipated to be available, the FSTD sponsor may contract a third 

party data provider to conduct the modifications and evaluations to the FSTD. 

The following table reflects the likely data source (OEM solution or third party solution) by FSTD 

data package based upon currently known information and assumptions made by the FAA 

concerning the likely data source to be used for the FSTD modifications required in FSTD Directive 

#2. 

Aircraft Make, Model, and Series Likely Data Source

A300-B4 Aircraft OEM

A310-200, -300 Aircraft OEM

A320-200 (series) Aircraft OEM

A330-200, -300 (series) Aircraft OEM

ATR-42-300, -500 Third Party Data Provider

ATR-72-212A Third Party Data Provider

B717-200 Aircraft OEM

B727-200 Third Party Data Provider

B737-200, -300, -400 Third Party Data Provider

B737-700, -800, -900 Aircraft OEM

B747-200 Third Party Data Provider

B747-400, -400F Aircraft OEM

B747-8 Aircraft OEM

B757-200 Aircraft OEM

B767-200 Third Party Data Provider

B767-300(ER) Aircraft OEM

B767-400 Aircraft OEM

B777-200(LR) Aircraft OEM

B777-300(ER) Aircraft OEM

B777-FS2 Aircraft OEM

B787-8 Aircraft OEM

BE-1900-D Third Party Data Provider

CL-600-2B19 Third Party Data Provider

CL-600-2C10 Aircraft OEM

CL-600-2D24 Aircraft OEM

DC-9-30, DC-9-82 Third Party Data Provider

DHC-8-100, -200, -300 Third Party Data Provider

DHC-8-400 Aircraft OEM

EMB-120-120 Third Party Data Provider
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EMB-145-145 Third Party Data Provider

ERJ-170, -190 Aircraft OEM

MD-10-30F Third Party Data Provider

MD-11-11, -11F Aircraft OEM

MD-88-88, -90 Third Party Data Provider

SD-3-60 Third Party Data Provider

SF-340-340A, -340B Third Party Data Provider

. 

Within the group of those using an OEM solution some will need a simple update (termed simple 

OEM solution) and some will require a pre-update to be brought up to the latest revision or 

blockpoint of their data package before the installation of an enhanced stall model can occur

(termed a pre-update).

The paragraphs below describe these general groups and the categories within and the costs that will 

be incurred in each. In total there are seven categories, one within third party data provider solution 

and six within OEM provider solutions. Under the OEM provider solutions two categories are 

considered simple OEM solutions that will only require modification to meet the final requirements 

and four categories will require varying levels of pre-update before the FSTDs can be modified to 

comply with the requirements of the Directive. 
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Third Party Data Provider Solution

Category A - Non-Aircraft Original Equipment Manufacturer/Third Party Solution

FSTDs using third party solutions will generally not require pre-updates according to a third party 

solution provider. The third party solution cost of $88,000 per FSTD includes installation 

(implementation) costs and a display system that will meet the IOS requirements as well as icing 

costs. Installation costs of $23,000 – that are included in the standard cost of $88,000 – may be 

distributed over several FSTDs, if the installation is occurring at the same location and on the same

model. The FAA uses a cost of $88,000 per device modified to avoid subjective allocations, 

thereby likely overestimating these costs. The estimate of the third party solution cost does not 

include the cost of simulator modifications to meet the bounced landing recovery or gusting 

crosswind requirements. The costs of wind gust models and bounced landings were estimated 

during the NPRM phase and as we received no better data, the costs estimated for the NPRM are 

used here. These costs of $21,100 for wind gust models and costs of $28,933 for bounced landing 

models will be added to the cost of third party solutions as will the cost of lost productivity 

($22,500 as estimated during the NPRM phase) as the FSTD is taken offline for the modifications. 

Total cost per FSTD in this category is $156,597, and the total number of FSTDs is 106 resulting in 

a total cost for this category of $16.6 million.
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Aircraft Original Equipment Manufacturer Solution

Simple Aircraft Original Equipment Manufacturer Solution –

FSTDs in the two categories (B and C) within simple aircraft OEM solution will not likely require 

significant updates to the existing aerodynamic model before implementing an enhanced stall model 

to meet the requirements of this rule. The difference is the FSTDs in one category will already meet 

bounced landing requirements without additional costs being incurred, and those in the second 

category will not.

These FSTDs in these two categories include the following:

• FSTDs utilizing data packages that will not likely require a full update to the current data 

package revision or blockpoint before implementing an enhanced stall model solution. 

These include FSTDs using newer data packages that the FAA expects will not need an 

update to the latest revision or blockpoint as well as those older data packages that FAA 

records indicate have likely already been updated to a recent data package revision.

• FSTDs owned by sponsors who have a long term service agreement with the manufacturer 

to keep the devices updated. 

It is expected that some existing OEM provided aerodynamic and ground models may already meet 

the bounced landing recovery requirements in the final rule. This is based upon the cost 

information provided by one major aircraft OEM data provider which indicated that many of their 

current data packages will meet the requirements in the NPRM as well as assumptions made by the 

FAA on other OEM provided data packages of a similar age. We assume the other FSTDs under
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this heading will require modifications to meet the bounced landing recovery requirements. These 

two categories are described in detail below.

Category B - Simple Original Equipment Manufacturer Solutions That Already Meet 

Bounced Landing requirements

These FSTDs will likely be able to incorporate an OEM provided solution with no pre-update to the 

existing data package required. This category uses the estimate of $25,000 per model discussed 

above which assumes the current icing models in their current data packages will meet the 

requirements of the final rule. The FAA assumes that other OEM data providers will likely offer a 

similar solution at a comparable cost for newer data packages. None of these FSTDs in this 

category are expected to need an IOS replacement since they are all relatively newer devices that 

likely have an IOS that can be modified with software changes to meet the rule requirements. Also 

included in this group are some FSTDs owned by sponsors who have a long term service agreement

with the manufacturer to keep the devices updated to the latest data package revision or blockpoint. 

The OEM solutions for the FSTDs in this group are not expected to need updates to the existing 

ground reaction models to meet the bounced landing requirements. 8

 The OEM solution estimate of 

$25,000 does not include implementation costs so the FAA adds the implementation cost estimate 

($54,807) derived during the NPRM phase to the estimate. The estimate does not include wind gust 

models so the FAA adds the NPRM cost estimate ($21,100) for wind gust models to the total. The 

 8 FSTDs in this category are currently operating OEM data packages and associated ground reaction models that are 

expected to meet the bounced landing recovery requirements with no modification. 
26

FAA also adds lost productivity costs as estimated during the NPRM phase at $22,500 to account 

for possible lost revenues when the FSTD is taken offline for the updates. 

The total cost per FSTD in is $122,289 for each of the 132 FSTDs in this category and the total cost 

for all the FSTDs in this category is $16.1 million.

Category C - Simple Original Equipment Manufacturer Solutions That Do Not Already Meet 

Bounced Landing requirements

These FSTDs are identical to the FSTDs described in the previous subset with the exception of the 

additional cost needed to implement potential changes to meet the bounced landing recovery 

requirement in the final rule. Since the FAA has not determined if the current data packages on 

these FSTDs will meet the bounced landing recovery requirements in the final rule, it has been 

assumed that they will require updates to the existing ground reaction models. As a result, the FAA 

has added the bounced landing cost estimate ($28,933) derived during the NPRM phase to these 

FSTDs in addition to the costs that were added to category B. 

The total cost per FSTD is $151,222 for each of the 34 FSTDs in this category and the total cost for 

the category is $5.1 million.
27

Original Equipment Manufacturer Solutions Requiring Pre-updates

The FAA recognizes there are many older FSTDs currently in operation that could require 

significant updates to existing data packages before implementing an enhanced stall model solution 

to meet the requirements of this rule, such as the need to update data packages to their latest 

revision or blockpoint before further modifications can occur. In some cases, significant hardware 

improvements/modifications could be required for older FSTDs to run later versions of simulator 

aerodynamic data packages. In an effort to develop a more accurate cost estimate for many of these 

older FSTDs that may be subject to the rule requirements, the FAA conducted an analysis of the 

current fleet of FSTDs that could be used in an air carrier training program to meet the requirements 

of the Crewmember and Dispatcher Training final rule. This analysis was conducted to determine 

which FSTDs may need a revision or blockpoint update to the existing data package before 

modifications can be conducted to meet the requirements of this final rule as well as to determine 

the extent of these modifications for the purpose of estimating the cost impact. These pre-update

costs were not included in the NPRM cost estimates. As a result of this analysis, the FAA 

established the following D - G categories of FSTDs requiring varying extents of pre-updates before 

implementing the OEM provided data solutions.

Category D - Aircraft Original Equipment Manufacturer Solution with Standard Data 

Package Update 

These FSTDs include those that will likely require an update to the existing data package before an 

enhanced stall model can be implemented. Because these FSTDs are relatively newer in age or 

have been extensively updated in recent years, they are assumed not to require major simulator 
28

hardware modifications, such as a host computer replacement, to implement the latest standard data 

package revision. 9

 These FSTDs include the following:

• FSTDs of aircraft running older data packages that have undergone many revisions over the 

past several years. These data packages include the B757-200, B767-300, B747-400, MD11, A320, A330 aircraft models, and other data packages of a similar age range in which 

FAA records do not indicate are at a recent data package revision. Older FSTDs that may 

need extensive hardware modifications are addressed in later categories.

• Older FSTDs that have been identified to FAA which are already scheduled for extensive 

hardware modifications but will still need pre-update software modifications.

• According to FAA records, the average age of the FSTDs in this category is 14 years old.

• FSTDs in this category will incur an additional $200,000 (as described in more detail in 

Appendix E) standard data update charge in addition to the costs necessary to acquire and 

install an enhanced stall model.

The estimated cost for the OEM solution for the FSTDs in this category does not include wind gust 

models and implementation costs so the FAA adds the cost estimates derived during the NPRM 

phase of $21,100 and $54,807 respectively, to the cost for each FSTD to meet the rule requirements. 

In addition, the FAA doubles the $22,500 cost of lost productivity from the NPRM, as it is possible 

the FSTD will be taken offline for a more extended period of time to conduct these pre-update

modifications. 

 9 The FAA conducted a review of the National Simulator Program’s FSTD qualification records to determine the age of 

the FSTD, whether it had undergone major updates in recent years, and the current data package revisions where 

available. 
29

The total cost per FSTD in this category is $335,842 for each of the 39 FSTDs in this category and 

the total cost for the category is $13.1 million.

Category E - Aircraft Original Equipment Manufacturer Solution with Standard Data 

Package and Hardware Update No IOS Replacement

These FSTDs include those where FAA records indicate the FSTD is currently running a host 

computer that will likely require a replacement before a required standard data package update can 

be accomplished. These are typically older FSTDs running on older host computers such as a 

MultiSEL, VAX, etc. These FSTDs include the following:

• FSTDs of Boeing aircraft running older data packages that have undergone many revisions 

over the past several years. These data packages include the B757-200, B767-300, B747-

400, and MD-11 models in which FAA records do not indicate are at the latest data package 

revision. Note that because of the integrated nature of FSTD data packages of fly-by-wire 

aircraft, they are assumed to require more extensive hardware updates and are addressed in a 

separate cost category.

• FAA records indicate that these FSTDs have not been extensively modified in recent years 

and are likely to be still operating their original computer hardware.

• According to FAA records, the average age of the FSTDs in this category is 24 years old.

• FSTDs in this category will incur an additional $500k cost (as described in more detail in 

Appendix E) to conduct a host computer replacement as well as a standard data update in 

addition to the costs to acquire and install an enhanced stall model.
30

The OEM estimated cost solution for the FSTDs in this category does not include wind gust models 

and implementation costs so the FAA adds the cost estimates derived during the NPRM phase of 

$21,100 and $54,807, respectively to the cost for each FSTD to meet the rule requirements. In 

addition, the FAA triples the $22,500 cost of lost productivity that was estimated in the NPRM RIA 

as it is possible the FSTD will be taken offline for a more extended period of time to conduct these 

pre-update modifications. 

In order to address public comments concerning the potential cost of replacing an instructor 

operating station (IOS) to meet the UPRT requirements, the FAA made clarifications in the final 

rule that extensive graphics capabilities on the IOS should not be necessary to meet the UPRT IOS 

feedback requirements and the examples provided in the rule were intended as guidance material in 

an information section. The examples provide one method the sponsor could use to meet the IOS 

feedback requirements, however, digital or discrete methods may be acceptable if the required 

parameters are provided as described in the final rule.

The FAA agreed with the commenters in that some very old FSTDs may not have the capability to 

provide the necessary IOS functionality for UPRT and that a small number of FSTDs may require a 

complete IOS replacement. The FAA estimated that, in general, any FSTD that was initially 

qualified under AC 120-40B simulator qualification standards or later (published in 1991) should 

already be equipped with an IOS with minimal graphical capabilities that can be modified with 

software to meet the UPRT requirements without having to conduct a full replacement. For FSTDs 

that were initially qualified using standards before AC 120-40B, the FAA further conducted FSTD 

qualification records checks to determine if any of these older FSTDs had reported major IOS 
31

replacements in recent years. Those that reported IOS replacements were included in this category.

Those that had not reported replacements are included in the following category, which incorporates 

additional cost for an IOS replacement. 

The total cost per FSTD in this category is $644,922 for each of 10 FSTDs in this category and the 

total cost for the category is $6.4 million.

Category F - Aircraft OEM Solution with Standard Data Package and Hardware Update

Needs IOS Replacement

The characteristics of these FSTDs are identical to the FSTDs described in Category E with the 

exception that these FSTDs will also likely need a complete Instructor Operation Station (IOS) 

replacement to meet the UPRT requirements in the final rule. 

The cost of IOS replacement ($250,000) is added to the cost of modifying these FSTDs 10. All 

other costs are the same as used in Category E.

The total cost per FSTD $894,922 for each of 6 FSTDs in this category and the total cost for the 

category is $5.4 million.

 10 The $250,000 estimate for an IOS replacement was provided in the public comments.
32

Category G - Aircraft OEM Solution with Standard Data Package and Hardware Update 

(Fly-By-Wire Aircraft) No New IOS

Because of the integrated nature of the data packages delivered for fly-by-wire aircraft such as the 

Airbus A320 and A330, the FAA acknowledges that conducting an update from older standard data 

package revisions may be costly since they typically involve major updates to the simulated aircraft 

avionics and flight control systems. These FSTDs are older in age and are assumed to require 

extensive modifications to bring them up to more recent data package revisions. These FSTDs 

include the following:

• Airbus A320 FSTDs that are currently running a standard data package revision prior to 

STD 1.7.

• Airbus A330 FSTDs that are currently running a standard data package revision prior to 

STD 2.4.

• According to FAA records, the average age of the FSTDs in this category is 18 years old.

FSTDs in this category will incur an additional $1 million cost to conduct a host computer 

replacement as well as a standard data and avionics systems update in addition to the costs to 

acquire and install an enhanced stall model. We asked for costs and received a wide range of costs, 

however we believe it will be on the lower end of the range because of other options available to 

the FSTD sponsor including third party solutions. In the end we determined that $1 million is a 

reasonable estimate. 

The OEM estimated cost solution for the FSTDs in this category does not include wind gust models 

and implementation costs so the FAA adds the cost estimates derived during the NPRM phase of 
33

$21,100 and $54,807, respectively to the cost for each FSTD to meet the rule requirements. In 

addition, the FAA triples the $22,500 cost of lost productivity that was estimated in the NPRM RIA 

as it is likely the FSTD will be taken offline for a more extended period of time to conduct these 

pre-update modifications. 

The total cost per FSTD is $1.1 million for each of 8 FSTDs in this category and the total cost for 

the category is $9.0 million.

Summary of Costs to Update FSTDs for the Crewmember and Aircraft Dispatcher Training 

final rule

The table below presents the estimates for each cost category as well as total costs to modify and 

evaluate the FSTDs that will be necessary to conduct the training required by the new training rule. 

Costs are provided in or converted to 2012 $. 11 These costs 12 plus the travel costs that will be 

discussed next are representative of the FSTD directive costs that are attributed to the new training 

rule. 

 11 The OEM solution cost of $25,000, the third party solution cost of $88,000 and the various pre update cost estimates 

were converted to 2012 $, the others are already in 2012 $.

12 Although these costs include the costs of icing models, some estimated 15% of the FSTDs will need additional work 

to bring icing models into compliance with the final rule. Also, icing costs that are included have already been incurred 

and it will cost more to remove the icing models, according to an industry source. Therefore we use only the costs of 

additional modifications to the models as representative of the icing model costs which we need to justify outside of the 

training rule. These additional icing modifications are estimated later in the document and form the second benefit 

basis.
34

Cost (1) of Updates to FSTDs to meet the New Training Rule Requirements

# FSTD Model 

2015 $

Model 

2012 $ 

(2)

Sim data/ 

Hardware 

Update 

2015 $

Sim data/ 

Hardware 

Update 

2012 $ (2)

ImplementationLost 

Productivity

Wind 

Gust 

Models

Bounced 

Landing

Replace 

IOS

Total per 

FSTD Total 

Category A 106 $88,000 $84,064 $0.00 $0 $0.00 $22,500 $21,100 $28,933 $0.00 $156,597 $16,599,233

Category B 132 $25,000 $23,882 $0.00 $0 $54,807 $22,500 $21,100 $0.00 $0.00 $122,289 $16,142,107

Category C 34 $25,000 $23,882 $0.00 $0 $54,807 $22,500 $21,100 $28,933 $0.00 $151,222 $5,141,537

Category D 39 $25,000 $23,882 $200,000 $191,053 $54,807 $45,000 $21,100 $0.00 $0.00 $335,842 $13,097,845

Category E 10 $25,000 $23,882 $500,000 $477,634 $54,807 $67,500 $21,100 $0.00 $0.00 $644,922 $6,449,224

Category F 6 $25,000 $23,882 $500,000 $477,634 $54,807 $67,500 $21,100 $0.00 $250,000 $894,922 $5,369,535

Category G 8 $25,000 $23,882 $1,000,000 $955,267 $54,807 $67,500 $21,100 $0.00 $0.00 $1,122,556 $8,980,449

Total 335 $71,779,930

Totals may not add due to rounding

(1) Does not include travel costs. (2) to convert to 2012 $ we used the chained GDP price index Office of Management and Budget, Historical Tables - Table 10.1

Category A Non-Aircraft OEM/third Party Solution

Category B Simple OEM Solutions That Already Meet Bounced Landing requirements

Category C Simple OEM Solutions That Do Not Already Meet Bounced Landing requirements

Category D Aircraft OEM Solution with Standard Data Package Update 

Category E Aircraft OEM Solution with Standard Data Package and Hardware Update No IOS Replacement

Category F Aircraft OEM Solution with Standard Data Package and Hardware Update Needs IOS Replacement

Category G Aircraft OEM Solution with Standard Data Package and Hardware Update (Fly-By-Wire Aircraft) No New IOS
35

Travel Costs

Travel costs will be incurred as technicians go to FSTD sites to evaluate and modify previously 

qualified FSTDs. We did not include travel costs in the NPRM, but we include them here. 

According to an industry source it might require 3 people 2 days to install the updates. This 

estimate allocates one plane flight for each FSTD needing modification. As some locations have 

several FSTDs that can be updated during one trip, the cost of airfare is likely overestimated.

Travel Expenses for Individuals Travelling to Modify 

Equipment

Number of people travelling for each modification 3

Cost of round trip airfare [1][2] $387

Number of nights 2

Number of FSTDs to modify 335

Per diem [3] $273

Total $936,660

[1] Source: U.S. DoT Department of Transportation Statistics, Annual 

U.S. Domestic Average Itinerary Fare, 2014 constant dollars converted 

to 2015 using CPI

[2] Bureau of Labor Statistics Table 1. Consumer Price Index for All 

Urban Consumers (CPI-U), Unadjusted % change in airline fare Sept. 

2014-Sept. 2015

[3] U.S. General Services Administration FY 2015 Per Diem Rates, 

uses District of Columbia per diem rates, which likely over-estimate per 

diem.

Totals may not add due to rounding.

The cost of modifying FSTDs to meet the new training rule requirements and the cost of travel to 

FSTD locations to implement the modifications form the first benefit basis (i.e. that which will be 

evaluated against the benefits of the training rule).
36

iv. Estimate of the Cost of Icing Modifications

The FAA’s understanding is that most of the enhanced stall models will include icing solutions. 

These icing solutions cannot feasibly be separated from the enhanced stall model solutions. This is 

in general agreement with information provided by some aircraft OEM data providers that adequate 

aerodynamic and system effects of icing are captured in the current data packages. However, some 

FSTDs might not currently have an adequate icing accretion model and might require additional 

cost to be incurred to improve their pre-stall ice accretion models. We estimate that 15% of all 13

the 335 previously qualified FSTDs in this analysis will need this additional icing modelling work 

at an estimated average cost of $25,000 per FSTD. This results in a total estimate of $1.3 million 

for approximately 50 devices to have improved icing models installed. We assume that these 

additional improvements to the icing models will occur at the same time as the other modifications;

therefore we do not include additional travel costs for icing modifications. The cost of additional 

icing modifications will form the second benefit basis for the FSTD directive. 

v. Cost of the Flight Simulator Training Device Directive

We assume that a third of FSTD sponsors will update their devices each year beginning in the year 

the rule is expected to be published. By 2019 we assume that all previously qualified FSTDs will 

be modified in time to meet the March 2019 compliance date of the Crewmember and Aircraft 

Dispatcher Training final rule. This assumption likely overestimates the number of FSTDs that will 

incur these costs because it includes all FSTDs that could potentially be used in part 121 training. 

 13 Although it is more likely that a higher percentage of FSTDs classified as using a third party solution than FSTDs 

using OEM solutions will require additional modifications to their existing icing models to meet the rule’s 

requirements, overall we believe that 15% of all FSTDs in this analysis will have to make these additional modifications 

to their icing models.
37

For previously qualified FSTDs only those that are used in the new training actually have to comply 

with the rule. Also, FSTDs that will be used after March 2019 will not have to comply until they 

are used for the specific training tasks.

The table below shows the costs of the FSTD directive without additional icing modifications, the 

cost of the additional icing modifications, and the total cost of the FSTD directive distributed over 

the three year period and discounted by 7% and 3%. 
38

Total cost of FSTD Directive Distributed by Year and Discounted (2012 $)

Year

Cost of FSTD 

Directive 

Without 

Additional 

Icing 

Modifications

Cost of 

Travel to 

Implement 

updates -

Previously 

Qualified 

FSTDs

Total Cost of 

FSTD 

Directive -

previously 

qualified 

Non-icing 

provisions 

including 

travel costs

Cost of FSTD 

Directive For 

Additional 

Icing 

Modifications

Total Cost 

of FSTD 

Directive

7 % Present 

Value Cost

3 % Present 

Value Cost

2015 - - - - - - -

2016 $23,926,643 $312,220 $24,238,863 $418,750 $24,657,613 $23,045,006 $23,940,077 

2017 $23,926,643 $312,220 $24,238,863 $418,750 $24,657,613 $21,535,960 $23,242,266 

2018 $23,926,643 $312,220 $24,238,863 $418,750 $24,657,613 $20,128,010 $22,564,182 

Total $71,779,930 $936,660 $72,716,590 $1,256,250 $73,972,840 $64,708,975 $69,746,526

Note: Details may not add to row or column totals due to rounding
39

vi. Licensing Fees

In this cost analysis, the FAA considered the potential for licensing fees imposed upon FSTD 

sponsors by the original FSTD manufacturer in order to access their intellectual property needed to 

accomplish the modifications required by this rule. This intellectual property could be FSTD wiring 

diagrams, software, manuals, and other information needed to implement and integrate software or 

hardware solutions on an existing FSTD.

The FAA did not receive any cost estimates in the public comments concerning these potential 

additional licensing fees that might be charged by an FSTD manufacturer for the implementation of 

data by a third party.

The FAA has not included this particular licensing fee in the cost of this rule for the following 

reasons. First, FSTD sponsors, including airlines and other training providers, routinely modify 

hardware and software on their FSTDs without additional licensing fees for maintenance purposes 

and to improve FSTDs for training. The FAA does not expect this practice to change going forward 

after this final rule becomes effective. Second, where an FSTD currently employs a data package 

supplied by an aircraft OEM data provider, the FAA does not expect additional licensing fees from 

the FSTD manufacturer to be applicable in instances where an existing OEM data package is 

updated as necessary to comply with this rule. Finally, where the aircraft OEM data provider or 

other original data provider support is not available and a third party solution must be employed, the 

FAA conducted an analysis of the qualification records on these devices and found that the average 

age of these FSTDs is approximately 19 years old. Particularly with FSTDs that have been sold to 

other sponsors, the FAA finds it unlikely that licensing fees to the FSTD manufacturer will be 
40

collected on these older devices. In addition to the relative age of these devices, many of the 

original FSTD manufacturers are no longer in business, further decreasing the likelihood that the 

FSTD manufacturer’s licensing fees will be collected from the FSTD sponsor.

The FAA did not receive any cost estimates in the public comments concerning these 

potential additional licensing fees that might be charged by an FSTD manufacturer for the 

implementation of data by a third party.

vii. Estimate of the Cost of Aligning With ICAO

This requirement applies only to newly qualified FSTDs. The FAA uses the costs estimated in the 

NPRM Regulatory Impact Analysis to align with the ICAO guidance, with the exception that based 

on updated data we estimate an average of 23 FSTDs will be newly qualified each year once the 

industry must comply with the rule. Costs are slightly overestimated based on the following. In 

response to comments the FAA removed the requirement that had been proposed to increase the 

visual system field of view requirements to 200 degrees (horizontal). One commenter stated that 

this requirement could add 20% - 30% of the cost of a visual system. The FAA did not reduce the 

costs to align with ICAO, although it is likely that these costs will be reduced because the visual 

system field of view will not be increased.

These slightly updated costs are presented in the table below.
41

Cost for Newly Qualified FSTDs to Meet Requirements to Align with ICAO

Year

Newly 

Qualified 

FSTDs

Nonrecurring 

costs 

[1][2]

Costs 

incurred 

per A/C 

platform 

[3] $35,000 

each 

platform

Unit Costs 

per FSTD 

[4] 

Cost of 

Proposed 

changes to 

QPS 

Appendices

3% Present 

Value Cost

2015 - - - - - -

2016 - $250,000 $2,485,000 - $2,735,000 $2,655,412 

2017 23 $460,000 $460,000 $433,596 

2018 23 $460,000 $460,000 $420,946 

2019 23 $460,000 $460,000 $408,710 

2020 23 $460,000 $460,000 $396,796 

2021 23 $460,000 $460,000 $385,250 

2022 23 $460,000 $460,000 $374,026 

2023 23 $460,000 $460,000 $363,124 

2024 23 $460,000 $460,000 $352,544 

2025 23 $460,000 $460,000 $342,286 

Total $250,000 $4,140,000 $6,875,000 $6,132,690

Note: Some of the costs are in Canadian dollars, which we did not convert to U.S. dollars, 

which makes the costs on this table an overestimate.

Totals may not add due to rounding.

[1] Non-recurring costs of $50K to develop a standard QTG template and testing methods to meet the new ICAO standards. 

Assume these costs are incurred per manufacturer and there are 5 manufacturers. 

Therefore $50K times 5 = $250,000.

[2] Assume non-recurring costs occur in the year before FSTD sponsors must become compliant.

[3] Costs to develop an A/C specific QTG template that can be used by FSTDs of the same aircraft type. 

Assume these costs are incurred per A/C type. Estimate 71 aircraft types.

[4] Unit costs of $20K per FSTD.

Total Estimated Cost of Final Rule

The table below presents the total estimated costs of this final rule. We provide 

three separate sets of costs for which we later provide three separate benefit bases. 

The first set is the cost of the FSTD Directive which includes cost to evaluate and 

modify the FSTDs as well as travel costs for the technicians. The second set is the 
42

cost to modify those FSTDs that will require additional icing modifications. The 

third set is the cost to align standards with ICAO 9625.
43

Cost of FSTD Directive Upgrades 

Necessary for New Crewmember 

and Dispatcher Training Rule Tasks

Cost of 

FSTD 

Directive 

Icing 

Upgrades 

Cost to 

Align 

Standards 

with 

ICAO

Total Cost of the Proposed Part 60 

Rule

Year

Cost of 

FSTD 

Directive -

Update of 

previously 

qualified not 

including 

additional 

icing updates

Cost of 

Travel to 

Implement 

updates -

Previously 

Qualified 

FSTDs

Total Cost of 

FSTD 

Directive -

previously 

qualified

provisions 

including 

travel costs

Cost of 

FSTD 

Directive -

previously 

qualified 

icing 

provisions

Cost of 

Proposed 

changes to 

QPS 

Appendices 

- Newly 

Qualified Total Cost 

7% Present 

Value Cost

3% Present 

Value Cost

2015

2016 $23,926,643 $312,220 $24,238,863 $418,750 $2,735,000 $27,392,613 $25,601,137 $26,595,488 

2017 $23,926,643 $312,220 $24,238,863 $418,750 $460,000 $25,117,613 $21,937,724 $23,675,862 

2018 $23,926,643 $312,220 $24,238,863 $418,750 $460,000 $25,117,613 $20,503,508 $22,985,128 

2019 $460,000 $460,000 $350,934 $408,710 

2020 $460,000 $460,000 $327,980 $396,796 

2021 $460,000 $460,000 $306,498 $385,250 

2022 $460,000 $460,000 $286,442 $374,026 

2023 $460,000 $460,000 $267,720 $363,124 

2024 $460,000 $460,000 $250,194 $352,544 

2025 $460,000 $460,000 $233,818 $342,286 

Total $71,779,930 $936,660 $72,716,590 $1,256,250 $6,875,000 $80,847,840 $70,065,954 $75,879,215
44

IV. Benefits

In the cost sections we estimated three separate sets of costs, which have three

separate benefit bases. The first set of costs will be incurred to evaluate and modify

the FSTDs to provide a more accurate training environment for new training required 

by the new Crewmember and Aircraft Dispatcher Training final rule. The second set 

of costs will be incurred to improve existing FSTD icing models to enhance existing

training requirements. Lastly there is a set of FSTD improvements that will align the 

FSTD evaluation requirements for newly qualified FSTDs with ICAO

recommendations. 

A. Benefit of Modifying FSTDs to Support the Crewmember and Aircraft 

Dispatcher Training final rule

As discussed in the NPRM RIA, the best way to understand the benefits of this final rule is to 

view it in conjunction with the Crewmember and Aircraft Dispatcher Training final rule. That

final rule used a market price for hourly full flight simulator (FFS) training rates as a measure of

society’s resource costs of complying with the new training requirement. This market price of

$500 an hour assumed a fully allocated cost for using a simulator that complies with all FAA

requirements. In the Crewmember and Aircraft Dispatcher Training final rule, sensitivity analyses 

were run at different hourly rates, up to 120% of current estimated hourly rates.

14 In all cases, the

safety benefits of that rule exceeded the costs.

 14 The FAA conducted a sensitivity analysis using $550 and $600 for an hourly FSTD rental rate.
45

In this final rule we calculate the incremental cost of evaluating and modifying existing FSTDs to 

meet the revised qualification standards in support of the new Crewmember and Aircraft 

Dispatcher Training final rule. In that rule, part 121 operators are required to provide additional

training for their pilots in FSTDs that have incorporated the modifications as specified in this final

rule. The benefit-cost justification for the Crewmember and Aircraft Dispatcher Training final 

rule used $500 per simulator hour which includes the simulator modification cost. That rule’s

requirement for additional time in a modified FSTD represents a cost to the operators, which was 

fully accounted for and justified in that rule. In turn the cost to the operator for additional pilot 

training in a modified FSTD as required by that rule is now revenue to the FSTD owner in the 

context of this final rule. 15 16 For the FSTD owner to receive the additional FSTD training 

revenue, as required in the Crewmember and Aircraft Dispatcher Training final rule, the FSTD

must be modified at an approximate average cost of $217,000 per FSTD. 17 The owner of an 

average FSTD will recover these costs after renting the FSTD for approximately 217 two- hour 

sessions at a rate of $500 per hour. In the case of an airplane operator that provides in-house 

training to its pilots, the cost to modify their FSTDs will, in most cases, be less than the cost to 

send their pilots out to train at a training center. The cost of training is mandated by the 

Crewmember and Aircraft Dispatcher Training final rule and must be incurred. We expect most 

operators will choose the least costly option to comply with the final rule. Thus the incremental 

 15 We use the term owner here and elsewhere rather than sponsor because in isolated instances the FSTD sponsor may 

not be the owner of the device.

16 In many cases the airplane operator is the simulator owner. The simulator operations within a carrier can be viewed as 

a profit center for the carrier so it can be viewed as a transfer from one part of the company to another. 

17 The total cost to modify FSTDs for the new training requirements is $72.7 million. With 335 FSTDs subject to the 

directive per FSTD cost is approximately $217,000 ($72.7 million divided by 335).
46

FSTD modification cost will be more than fully recovered within a short period of time by the 

revenue received by the FSTD owner from the air carrier paying for the additional training time 

required by the new training rule.

B. Benefit of Icing Modifications

As discussed in the initial regulatory evaluation, this modification does not support a new training

requirement, but will enhance existing training requirements in operations of the anti-icing/de-icing

equipment and further address NTSB 18 and ARC recommendations to the FAA.

These costs are approximately $1.3 million and are expected to comprise a small percentage of the

total cost of compliance with the FSTD Directive. One avoided severe injury would justify the

minor costs of complying with these icing requirements across the whole industry.

C. Benefits of Aligning with ICAO

We have not quantified benefits of aligning part 60 qualification standards with ICAO guidance, 

but we expect aligned FSTD standards to contribute to improved safety as they are developed by 

a broad coalition of experts with a combined pool of knowledge and experience. The FAA 

expects more realistic training to result from these changes. The changes are expected to improve 

overall simulator fidelity by enhancing the evaluation standards for visual display resolution, 

system transport delay, sound direction, and motion cueing.

 18 NTSB recommendations A-11-46 and A-11-47 address engine and airframe icing.
47

Furthermore, internationally aligned FSTD standards for FSTD sponsors can reduce the redundant 

testing and documentation that are required to meet multiple national regulations and standards for 

FSTD qualification, potentially resulting in cost savings.

The addition of the Level 7 FTD through the ICAO alignment will provide training providers

with more options that do not exist today to conduct training at lower cost. If the sponsor 

chooses to qualify a level 7 FTD, it is because they expect the benefits to exceed the costs. We 

have not quantified these costs and benefits.

V. Conclusion

The costs of FSTD modifications to support the Crewmember and Aircraft Dispatcher Training

final rule were fully accounted for and justified by that rule. Once these FSTD modifications are 

made, the costs of training justified in that rule will become a revenue stream for FSTD sponsors. 

FSTD sponsors are expected to recoup the cost of modifications within a short period and then to 

receive ongoing revenue as the new training tasks continue. The costs of the additional icing 

modifications are less than the costs of avoiding one severe injury and comprise only a small 

percent of the costs to comply with the FSTD directive. The FAA expects more realistic training 

and therefore increased safety to result from aligning part 60 qualification standards with ICAO 

guidance. The FAA also expects cost savings from this alignment as we expect a reduction in 

burden due to redundant evaluation and documentation requirements that are necessary to meet 

multiple national regulations and standards. Based on our analysis, as shown in the table below, we

find this rule to have benefits exceeding the costs. 
48

NPRM 

Estimate

Final Rule 

Cost 

Estimate

Final Rule 

Cost 

Estimate 

Present 

Value at a 

7% Rate

Final Rule 

Cost 

Estimate 

Present 

Value at a 

3% Rate

FSTD Modifications for New Training 

Requirements

Cost $45,215,480 $72,716,590 $63,610,049 $68,562,049

Benefits Rational simulator owner will choose to comply.

Icing provisions

 Cost $468,000 $1,256,250 $1,098,926 $1,184,476

 Benefits

Only one prevented severe injury valued at $2.5 million 

makes the icing benefits exceed the costs.

Aligning Standards with ICAO

 Cost $6,695,000 $6,875,000 $5,356,979 $6,132,690 

 Benefits Improved safety and cost savings.

Total Cost $52,378,480 $80,847,840 $70,065,954 $75,879,215 

Totals may not add due to rounding.
49
50

Appendix A - FSTDs Potentially Affected by the Proposed FSTD Directive

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

825 A.T.S. Inc. BE-1900-D C Englewood 120-40B A

564 ABX Air, Inc. B-767-200 C Wilmington 120-40B A REDI

48 ABX Air, Inc. DC-9-30 C Wilmington 120-40B A LINK

725 AIMS Community College BE-1900-D C Greeley 120-40B A AAI

712 Airbus A-320-200 D Miami Springs 120-40B A REFL

1195 Airbus A-320-200 D Miami Springs 14 CFR Part 60 Change 1, Appendix A A ST7X

1258 Airbus A-320-200 D Miami Springs 14 CFR Part 60 Change 1, Appendix A A FSI

1175 Airbus A-320-232 D Miami Springs 14 CFR Part 60 Change 1, Appendix A A TTSL

1287 Airbus A-330-200 D Miami Springs 14 CFR Part 60 Change 1, Appendix A A ST7X

534 Airbus A-330-202 C Miami Springs 120-40B/Draft 40C A TSCF

592 Alaska Airlines B-737-400 C Seattle 120-40B A REDI

652 Alaska Airlines B-737-700 D Seattle 120-40B A TTS

770 Alaska Airlines B-737-800 D Seattle 120-40B/Draft 40C A TTSL

1371 Alaska Airlines B-737-800 D Seattle 14 CFR Part 60 Change 1, Appendix A A ST7X

1424 Allegiant Airlines A-320-200 D Las Vegas 14 CFR Part 60 Change 1, Appendix A A

631 American Airlines A-320-200 D Charlotte 120-40B/Draft 40C A ST7X

1079 American Airlines A-320-200 D Charlotte 14 CFR Part 60 Change 1, Appendix A A ST7X

1250 American Airlines A-320-200 D Charlotte 14 CFR Part 60 Change 1, Appendix A A ST7X

1293 American Airlines A-320-200 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1412 American Airlines A-320-200 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1325 American Airlines A-320-200 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

613 American Airlines A-320-211 D Charlotte 120-40B/Draft 40C A ST7X

795 American Airlines A-320-232 D Phoenix 120-40B/Draft 40C A TTSL

1068 American Airlines A-320-232 D Phoenix 14 CFR Part 60 Change 1, Appendix A A ST7X

1074 American Airlines A-330-223 D Charlotte 14 CFR Part 60 Change 1, Appendix A A ST7X

643 American Airlines A-330-323 D Charlotte 120-40B A ST7X

16 American Airlines B-727-200 D Dallas 120-40A A LINK

721 American Airlines B-737-800 D Dallas 120-40B/Draft 40C A ST7X

1249 American Airlines B-737-800 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1143 American Airlines B-737-800 D Dallas 14 CFR Part 60 Change 1, Appendix B A ST7X

588 American Airlines B-737-823 D Dallas 120-40B/Draft 40C A ST7X

591 American Airlines B-737-823 D Dallas 120-40B/Draft 40C A ST7X

675 American Airlines B-737-823 D Dallas 120-40B/Draft 40C A ST7X

752 American Airlines B-757-200 D Dallas 120-40B/Draft 40C A ST7X

60 American Airlines B-757-200 C Charlotte 120-40 A ST7X

312 American Airlines B-757-200 C Phoenix 120-40A A ST7X

324 American Airlines B-757-223 D Dallas 120-40B A ST7X

389 American Airlines B-757-223 D Dallas 120-40B A ST7X
51

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

20 American Airlines B-767-200 C Dallas 120-40 A LINK

228 American Airlines B-767-200 D Dallas 120-40A A LINK

596 American Airlines B-767-300 D Dallas 120-40B/Draft 40C A ST7X

646 American Airlines B-777-200 D Dallas 120-40B/Draft 40C A ST7X

572 American Airlines B-777-200 D Dallas 120-40B/Draft 40C A ST7X

615 American Airlines B-777-200 D Dallas 120-40B/Draft 40C A ST7X

1289 American Airlines B-777-300ER D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1351 American Airlines B-787-8 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1431 American Airlines B-787-8 D Fort Worth 14 CFR Part 60 Change 1, Appendix A A ST7X

813 American Airlines CL-600-2B19 D Charlotte 120-40B/Draft 40C A ST7X

661 American Airlines CL-600-2B19 D Charlotte 120-40B/Draft 40C A ST7X

826 American Airlines CL-600-2B19 D Phoenix 120-40B/Draft 40C A ST7X

814 American Airlines CL-600-2C10 D Charlotte 120-40B/Draft 40C A ST7X

700 American Airlines CL-600-2C10 D Charlotte 120-40B/Draft 40C A ST7X

1194 American Airlines CL-600-2C10 D Phoenix 14 CFR Part 60 Change 1, Appendix A A ST7X

918 American Airlines CL-600-2D24 D Charlotte 120-40B/Draft 40C A ST7X

1002 American Airlines CL-600-2D24 D Phoenix 120-40B/JAR-STD 1A Amdt 3 A ST7X

196 American Airlines DC-9-82 D Dallas 120-40 A LINK

23 American Airlines DC-9-82 D Dallas 120-40 A LINK

24 American Airlines DC-9-82 D Dallas 120-40 A LINK

263 American Airlines DC-9-82 C Dallas 120-40A A LINK

240 American Airlines DC-9-82 D Dallas 120-40A A LINK

393 American Airlines DHC-8-100 C Charlotte 120-40B A ST7X

423 American Airlines DHC-8-300 C Charlotte 120-40B A ST7X

672 American Airlines EMB-145-145 D Dallas 120-40B/Draft 40C A ST7X

621 American Airlines EMB-145-145 D Dallas 120-40B/Draft 40C A ST7X

902 American Airlines ERJ-170-100 D Charlotte 120-40B/JAR-STD 1A Amdt 3 A ST7X

816 Atlas Air, Inc B-747-200 C Miami 120-40B A LINK

722 Atlas Air, Inc B-747-400F C Miami 120-40B A ST7X

1092 Atlas Air, Inc B-747-400F D Miami 120-40B/JAR-STD 1A Amdt 3 A ST7X

746 Boeing Flight Services Australia B-717-200 D Brisbane 14 CFR Part 60 Change 1, Appendix A A FSI

636 Boeing Training and Flight Services B-717-200 D Miami 120-40B A FSI

304 Boeing Training and Flight Services B-737-300 C Miami 120-40B A FSI

748 Boeing Training and Flight Services B-737-700 D Miami 120-40B/Draft 40C A FSI

978 Boeing Training and Flight Services B-737-700 D Miami 120-40B/JAR-STD 1A Amdt 3 A ST7X

581 Boeing Training and Flight Services B-737-700 D Miami 120-40B/JAR-STD 1A Amdt 3 A ST7X

1378 Boeing Training and Flight Services B-737-700 D Singapore 14 CFR Part 60 Change 1, Appendix A A

749 Boeing Training and Flight Services B-737-800 D Miami 120-40B/Draft 40C A FSI

794 Boeing Training and Flight Services B-737-800 D Miami 120-40B/Draft 40C A ST7X

957 Boeing Training and Flight Services B-737-800 D Miami 120-40B/JAR-STD 1A Amdt 3 A ST7X
52

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

1097 Boeing Training and Flight Services B-737-800 D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

1282 Boeing Training and Flight Services B-737-800 D Singapore 14 CFR Part 60 Change 1, Appendix A A TTSL

1379 Boeing Training and Flight Services B-737-800 D Singapore 14 CFR Part 60 Change 1, Appendix A A

1091 Boeing Training and Flight Services B-747-400F D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

1264 Boeing Training and Flight Services B-747-8F D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

1167 Boeing Training and Flight Services B-757-200 D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

333 Boeing Training and Flight Services B-757-200 C Miami 120-40A A FSI

359 Boeing Training and Flight Services B-767-300 C Miami 120-40B A REDI

330 Boeing Training and Flight Services B-767-300 C Miami 120-40A A FSI

1183 Boeing Training and Flight Services B-767-300ER D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

469 Boeing Training and Flight Services B-777-200 D Miami 120-40B/ICAO A ST7X

1231 Boeing Training and Flight Services B-777-200 D Singapore 14 CFR Part 60 Change 1, Appendix A A ST7X

969 Boeing Training and Flight Services B-777-300ER D Miami 120-40B/ICAO A ST7X

530 Boeing Training and Flight Services B-777-300ER D Miami 120-40B/JAR-STD 1A Amdt 3 A FSI

1340 Boeing Training and Flight Services B-777-300ER D Singapore 14 CFR Part 60 Change 1, Appendix A A TTSL

1232 Boeing Training and Flight Services B-777-300ER D Singapore 14 CFR Part 60 Change 1, Appendix A A ST7X

1185 Boeing Training and Flight Services B-787-8 D Miami 14 CFR Part 60 Change 1, Appendix A A TTSL

1184 Boeing Training and Flight Services B-787-8 D Miami 14 CFR Part 60 Change 1, Appendix A A TTSL

1228 Boeing Training and Flight Services B-787-8 D Singapore 14 CFR Part 60 Change 1, Appendix A A TTSL

1227 Boeing Training and Flight Services B-787-8 D Singapore 14 CFR Part 60 Change 1, Appendix A A TTSL

1363 Boeing Training and Flight Services B-787-8 D Toronto 14 CFR Part 60 Change 1, Appendix A A ST7X

315 Boeing Training and Flight Services MD-11-11 D Miami 120-40B A ST7X

1144

Boeing UK Training and Flight Services 

Ltd B-737-700 D Crawley 14 CFR Part 60 Change 1, Appendix A A FSI

1375

Boeing UK Training and Flight Services 

Ltd B-737-800 D Crawley 14 CFR Part 60 Change 1, Appendix A A FSI

1145

Boeing UK Training and Flight Services 

Ltd B-737-800 D Crawley 14 CFR Part 60 Change 1, Appendix A A FSI

1222

Boeing UK Training and Flight Services 

Ltd B-787-8 D Crawley 14 CFR Part 60 Change 1, Appendix A A TTSL

1358

Boeing UK Training and Flight Services 

Ltd B-787-8 D Crawley 14 CFR Part 60 Change 1, Appendix A A TTSL

1359

Boeing UK Training and Flight Services 

Ltd B-787-8 D Crawley 14 CFR Part 60 Change 1, Appendix A A TTSL

642

Boeing US Training and Flight Services, 

LLC B-717-200 D Atlanta 120-40B A ST7X

734

Boeing US Training and Flight Services, 

LLC B-717-200 D Atlanta 120-40B/Draft 40C A ST7X

882

Boeing US Training and Flight Services, 

LLC B-737-700 D Atlanta 120-40B/Draft 40C A FSI

880

Boeing US Training and Flight Services, 

LLC B-737-800 D Atlanta 120-40B/Draft 40C A FSI

1011 CAE SimuFlite DFW East ERJ-170-100 D Dallas-Fort Worth Airport 120-40B/JAR-STD 1A Amdt 3 A ST7X

940 CAE SimuFlite DFW East ERJ-190-100 D Dallas-Fort Worth Airport 120-40B/JAR-STD 1A Amdt 3 A ST7X

804 CAE SimuFlite Inc. B-737-800 D Dallas 120-40B/Draft 40C A ST7X

840 CAE SimuFlite Inc. CL-600-2B19 D Eagan 120-40B/Draft 40C A ST7X

838 CAE SimuFlite Inc. CL-600-2C10 D Eagan 120-40B/Draft 40C A ST7X

897 CAE SimuFlite Inc. CL-600-2D24 D Eagan 120-40B/Draft 40C A ST7X

823 CAE SimuFlite Inc. CL-600-2D24 D Eagan 14 CFR Part 60 Change 1, Appendix A A ST7X

841 CAE SimuFlite Inc. EMB-145-145 D Dallas 120-40B/Draft 40C A ST7X
53

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

790 CAE SimuFlite, Inc. A-320-232 D San Francisco 14 CFR Part 60 Change 1, Appendix A A ST7X

1117 Compass Airlines, LLC ERJ-170-200 D Minneapolis 120-40B/JAR-STD 1A Amdt 3 A FSI

539 Delta Air Lines, Inc. A-320-211 C Atlanta 120-40B A LINK

607 Delta Air Lines, Inc. A-320-211 D Atlanta 120-40B A ST7X

335 Delta Air Lines, Inc. A-320-211 C Atlanta 120-40A A LINK

299 Delta Air Lines, Inc. A-320-211 D Atlanta 120-40A A TSCF

865 Delta Air Lines, Inc. A-330-223 D Atlanta 120-40B/Draft 40C A TTSL

1046 Delta Air Lines, Inc. A-330-223 D Atlanta 120-40B/JAR-STD 1A Amdt 2 A ST7X

667 Delta Air Lines, Inc. B-737-800 D Atlanta 120-40B/Draft 40C A ST7X

1429 Delta Air Lines, Inc. B-737-800 D Atlanta 14 CFR Part 60 Change 1, Appendix A A

1433 Delta Air Lines, Inc. B-737-800W D Atlanta 14 CFR Part 60 Change 1, Appendix A A

702 Delta Air Lines, Inc. B-737-832 D Atlanta 120-40B/Draft 40C A ST7X

590 Delta Air Lines, Inc. B-737-832 D Atlanta 120-40B/Draft 40C A ST7X

273 Delta Air Lines, Inc. B-747-451 D Atlanta 120-40A A ST7X

403 Delta Air Lines, Inc. B-757-200 D Atlanta 120-40B A REDI

45 Delta Air Lines, Inc. B-757-200 C Atlanta 120-40 A LINK

280 Delta Air Lines, Inc. B-757-200 C Atlanta 120-40A A LINK

325 Delta Air Lines, Inc. B-757-251 C Atlanta 120-40A A ST7X

601 Delta Air Lines, Inc. B-767-300ER D Atlanta 120-40B A ST7X

353 Delta Air Lines, Inc. B-767-300ER D Atlanta 120-40B A ST7X

766 Delta Air Lines, Inc. B-767-300ER D Atlanta 120-40B/Draft 40C A ST7X

671 Delta Air Lines, Inc. B-767-400ER D Atlanta 120-40B/Draft 40C A ST7X

619 Delta Air Lines, Inc. B-777-200 D Atlanta 120-40B A ST7X

1114 Delta Air Lines, Inc. B-777-200LR D Atlanta 14 CFR Part 60 Change 1, Appendix A A ST7X

298 Delta Air Lines, Inc. MD-88-88 C Atlanta 120-40A A LINK

368 Delta Air Lines, Inc. MD-88-88 D Atlanta 120-40B A ST7X

253 Delta Air Lines, Inc. MD-88-88 D Atlanta 120-40B A LINK

390 Delta Air Lines, Inc. MD-88-88 D Atlanta 120-40B A ST7X

459 Delta Air Lines, Inc. MD-90-30 D Atlanta 120-40B A ST7X

768 Embry Riddle Aeronautical Univ. CL-600-2B19 D Daytona Beach 120-40B A FSI

754 Endeavor Air CL-600-2B19 D Eagan 120-40B/Draft 40C A ST7X

1067 Endeavor Air CL-600-2D24 D Eagan 120-40B/JAR-STD 1A Amdt 3 A FSI

668 ExpressJet Airlines, Inc. EMB-145-145 D Houston 120-40B A ST7X

862 ExpressJet Airlines, Inc. EMB-145-145 D Houston 120-40B/Draft 40C A ST7X

788 ExpressJet Airlines, Inc. EMB-145-145 D Houston 120-40B/Draft 40C A ST7X

547 Federal Express Corp. A-300-B4600 D Hong Kong 120-40B A REDI

645 Federal Express Corp. A-300-B4600 D Memphis 120-40B A TTS

434 Federal Express Corp. A-300-B4600 D Memphis 120-40B A ST7X

461 Federal Express Corp. A-310-200 C Memphis 120-40B A ST7X

491 Federal Express Corp. A-310-300 C Memphis 120-40B A ST7X
54

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

1032 Federal Express Corp. B-757-200 D Memphis 120-40B/Draft 40C A ST7X

1041 Federal Express Corp. B-757-200 D Memphis 120-40B/Draft 40C A ST7X

1157 Federal Express Corp. B-757-200 D Memphis 120-40B/Draft 40C A ST7X

1394 Federal Express Corp. B-767-3S2F D Memphis 14 CFR Part 60 Change 1, Appendix A A

1260 Federal Express Corp. B-777-FS2 D Memphis 14 CFR Part 60 Change 1, Appendix A A ST7X

1390 Federal Express Corp. B-777-FS2 D Memphis 14 CFR Part 60 Change 1, Appendix A A ST7X

1076 Federal Express Corp. B-777-FS2 D Memphis 14 CFR Part 60 Change 1, Appendix A A ST7X

1101 Federal Express Corp. B-777-FS2 D Memphis 14 CFR Part 60 Change 1, Appendix A A ST7X

662 Federal Express Corp. MD-10-30F C Memphis 120-40B A ST7X

674 Federal Express Corp. MD-10-30F C Memphis 120-40B A ST7X

364 Federal Express Corp. MD-11-11F D Anchorage 120-40B/Draft 40C A ST7X

638 Federal Express Corp. MD-11-11F D Memphis 120-40B/Draft 40C A ST7X

648 Federal Express Corp. MD-11-11F D Memphis 120-40B/Draft 40C A ST7X

989 Federal Express Corp. MD-11-11F D Memphis 120-40B/Draft 40C A ST7X

360 FlightSafety International ATR-42-300 C Houston 120-40A A FSI

258 FlightSafety International ATR-42-300 C Houston 120-40A A FSI

845 FlightSafety International ATR-42-500 D Houston 120-40B A FSI

890 FlightSafety International ATR-72-212A D Houston 120-40B A FSI

476 FlightSafety International BE-1900-D D Flushing 120-40B A FSI

695 FlightSafety International CL-600-2B19 D Atlanta 120-40B A FSI

664 FlightSafety International CL-600-2B19 D Atlanta 120-40B A FSI

719 FlightSafety International CL-600-2B19 D Atlanta 120-40B/Draft 40C A FSI

847 FlightSafety International CL-600-2C10 D Atlanta 120-40B/Draft 40C A FSI

1372 FlightSafety International CL-600-2C10 D Atlanta 14 CFR Part 60 Change 1, Appendix A A FSI

714 FlightSafety International DHC-8-100 C Atlanta 120-40B A FSI

802 FlightSafety International DHC-8-200 D Atlanta 120-40B A FSI

753 FlightSafety International DHC-8-300 D Atlanta 120-40B A FSI

345 FlightSafety International EMB-120-120 C Atlanta 120-40A A FSI

751 FlightSafety International EMB-145-145 D Houston 120-40B/Draft 40C A FSI

786 FlightSafety International EMB-145-145 D Houston 120-40B/Draft 40C A FSI

809 FlightSafety International EMB-145-145 D Paris 120-40B/Draft 40C A FSI

982 FlightSafety International ERJ-170-100 D Paris 120-40B/JAR-STD 1A Amdt 3 A FSI

292 FlightSafety International SD-3-60 C Flushing 120-40A A FSI

211 FlightSafety International SF-340-340A D Houston 120-40B A FSI

408 FlightSafety International SF-340-340B D Houston 120-40B A FSI

846 FlightSafety International (023 South) CL-600-2C10 D St Louis 120-40B/Draft 40C A FSI

1028 FlightSafety International (023 South) DHC-8-400 D St Louis 120-40B/JAR-STD 1A Amdt 3 A FSI

779 FlightSafety International (023 South) EMB-145-145 D St Louis 120-40B/Draft 40C A FSI

1036 FlightSafety International (023 South) ERJ-170-100 D St Louis 120-40B/JAR-STD 1A Amdt 3 A FSI

944 FlightSafety International (023 South) ERJ-170-100 D St Louis 120-40B/JAR-STD 1A Amdt 3 A FSI
55

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

1335 FlightSafety International (023 South) ERJ-170-100 D St Louis 14 CFR Part 60 Change 1, Appendix A A FSI

1345 FlightSafety International (023 South) ERJ-170-100 D St Louis 14 CFR Part 60 Change 1, Appendix A A FSI

1203 FlightSafety International (023 South) ERJ-190-100 D St Louis 14 CFR Part 60 Change 1, Appendix A A FSI

972 FlightSafety International 023 CL-600-2B19 D St Louis 120-40B/Draft 40C A FSI

930 FlightSafety International 023 CL-600-2C10 D St Louis 120-40B/Draft 40C A FSI

1010 FlightSafety International 023 CL-600-2D24 D St Louis 120-40B/JAR-STD 1A Amdt 3 A FSI

819 FlightSafety International 023 EMB-145-145 D St Louis 120-40B/Draft 40C A FSI

660 FlightSafety International 023 EMB-145-145 D St Louis 120-40B/Draft 40C A FSI

968 FlightSafety International 023 ERJ-170-100 D St Louis 120-40B/JAR-STD 1A Amdt 3 A FSI

1409 FlightSafety International 023 ERJ-170-100 D St Louis 14 CFR Part 60 Change 1, Appendix A A FSI

850 FlightSafety International 172 CL-600-2C10 D Dallas 120-40B/Draft 40C A FSI

904 FlightSafety International 172 EMB-145-145 D Dallas 120-40B/Draft 40C A FSI

327 FlightSafety International(004 EMB-120-120 C Long Beach 120-40A A FSI

514 FlightSafety International(029 BE-1900-D D Seattle 120-40B A FSI

465 FlightSafety International(029 DHC-8-100 C Seattle 120-40B A FSI

367 FlightSafety International(029 DHC-8-100 C Seattle 120-40B A FSI

557 FlightSafety International(029 DHC-8-200 D Seattle 120-40B A FSI

1242 FlightSafety International(029 DHC-8-200 D Seattle 14 CFR Part 60 Change 1, Appendix A A FSI

517 FlightSafety International(029 DHC-8-300 C Seattle 120-40B A FSI

370 FlightSafety International(029 DHC-8-300 C Seattle 120-40B A FSI

1243 FlightSafety International(029 DHC-8-300 D Seattle 14 CFR Part 60 Change 1, Appendix A A FSI

709 FlightSafety International(029 DHC-8-400 D Seattle 120-40B A FSI

1008 FlightSafety International(029 DHC-8-400 D Seattle 120-40B/JAR-STD 1A Amdt 3 A FSI

632 FlightSafety International(030 CL-600-2B19 D Salt Lake City 120-40B A FSI

787 FlightSafety International(030 CL-600-2B19 D Salt Lake City 120-40B/Draft 40C A FSI

743 FlightSafety International(030 CL-600-2B19 D Salt Lake City 120-40B/Draft 40C A FSI

899 FlightSafety International(030 CL-600-2C10 D Salt Lake City 120-40B/Draft 40C A FSI

1248 FlightSafety International(030 CL-600-2C10 D Salt Lake City 14 CFR Part 60 Change 1, Appendix A A FSI

693 FlightSafety International(033 BE-1900-D D Toronto 120-40B A FSI

288 FlightSafety International(033 DHC-8-100 C Toronto 120-40B A FSI

822 FlightSafety International(033 DHC-8-100 C Toronto 120-40B A FSI

821 FlightSafety International(033 DHC-8-200 D Toronto 120-40B/Draft 40C A FSI

422 FlightSafety International(033 DHC-8-300 C Toronto 120-40B A FSI

791 FlightSafety International(033 DHC-8-300 D Toronto 120-40B/Draft 40C A FSI

676 FlightSafety International(033 DHC-8-400 D Toronto 120-40B A FSI

1147 FlightSafety International(033 DHC-8-400 D Toronto 120-40B A FSI

553 FlightSafety International(044 CL-600-2B19 D Erlanger 120-40B A FSI

666 FlightSafety International(044 CL-600-2B19 D Erlanger 120-40B A FSI

683 FlightSafety International(044 CL-600-2B19 D Erlanger 120-40B A FSI

772 FlightSafety International(044 CL-600-2B19 D Erlanger 120-40B/Draft 40C A FSI
56

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

775 FlightSafety International(044 CL-600-2B19 D Erlanger 120-40B/Draft 40C A FSI

571 FlightSafety International(044 EMB-145-145 D Erlanger 120-40B/Draft 40C A FSI

1317 FlightSafety International(044 ERJ-170-100 D Erlanger 14 CFR Part 60 Change 1, Appendix A A FSI

172 Global One Training Group, LLC B-727-200 C Sanford 121-14C A REDI

1330 Hawaiian Airlines, Inc. A-330-200 D Honolulu 14 CFR Part 60 Change 1, Appendix A A

920 JetBlue Airways A-320-232 D Orlando 120-40B/Draft 40C A ST7X

921 JetBlue Airways A-320-232 D Orlando 120-40B/Draft 40C A ST7X

924 JetBlue Airways A-320-232 D Orlando 120-40B/Draft 40C A ST7X

919 JetBlue Airways A-320-232 D Orlando 120-40B/Draft 40C A ST7X

949 JetBlue Airways ERJ-190-100 D Orlando 120-40B/JAR-STD 1A Amdt 3 A ST7X

928 JetBlue Airways ERJ-190-100 D Orlando 120-40B/JAR-STD 1A Amdt 3 A ST7X

941 Kalitta Air, LLC B-747-200 C Ypsilanti 120-40B A ST7X

1234 Kalitta Air, LLC B-747-400 C Ypsilanti 14 CFR Part 60 Change 1, Appendix A A ST7X

358 Pan Am Int. Flight Academy SF-340-340B C Miami 120-40B A ST7X

633 Pan Am Int. Flight Academy SF-340-340B D Miami 120-40B A ST7X

56 Pan Am International Flight Academy A-300-B4 C Miami 120-40 A TSCF

640 Pan Am International Flight Academy A-320-200 D Miami 120-40B A REFL

174 Pan Am International Flight Academy B-727-222A C Miami 121-14C A ST7X

559 Pan Am International Flight Academy B-737-200 C Miami 120-40B A REDI

446 Pan Am International Flight Academy B-737-300 C Miami 120-40B A AAI

1059 Pan Am International Flight Academy B-737-400 C Miami 120-40B A REDI

1168 Pan Am International Flight Academy B-737-800 D Henderson 14 CFR Part 60 Change 1, Appendix A A

1104 Pan Am International Flight Academy B-737-800 D Miami 14 CFR Part 60 Change 1, Appendix A A

1161 Pan Am International Flight Academy B-737-800 D Miami 14 CFR Part 60 Change 1, Appendix A A

1241 Pan Am International Flight Academy B-737-800 D Miami 14 CFR Part 60 Change 1, Appendix A A

1322 Pan Am International Flight Academy B-747-400 D Miami 14 CFR Part 60 Change 1, Appendix A A TTS

119 Pan Am International Flight Academy B-757-251 D Henderson 120-40 A LINK

525 Pan Am International Flight Academy B-767-200 C Miami 120-40B A REDI

679 Pan Am International Flight Academy B-767-269 C Miami 120-40B A ST7X

31 Pan Am International Flight Academy B-767-275 C Miami 120-40 A REDI

1307 Pan Am International Flight Academy B-777-200 D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

1347 Pan Am International Flight Academy B-777-200 D Miami 14 CFR Part 60 Change 1, Appendix A A ST7X

350 Pan Am International Flight Academy DC-9-82 D Henderson 120-40A A ST7X

410 Pan Am International Flight Academy DC-9-82 C Miami 120-40B A REDI

348 Pan Am International Flight Academy MD-11-11 D Memphis 120-40B A ST7X

241 Pan Am International Flight Academy MD-88-88 C Henderson 120-40A A ST7X

302 Pan Am International Flight Academy MD-88-88 C Miami 120-40A A LINK

373 Pan Am International Flight Academy SF-340-340A C Miami Springs 120-40B A FSI

374 Pan Am International Flight Academy SF-340-340B D Miami Springs 120-40B A FSI

561 Sierra Academy of Aeronautics B-737-700 D Atwater 120-40B A ST7X
57

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

955 Sierra Academy of Aeronautics B-737-800 D Atwater 120-40B A ST7X

27 Southwest Airlines B-737-300 C Dallas 120-40A A REDI

65 Southwest Airlines B-737-300 C Dallas 120-40A A REDI

435 Southwest Airlines B-737-300 C Dallas 120-40B A REFL

579 Southwest Airlines B-737-700 D Dallas 14 CFR Part 60 Change 1, Appendix A A TTS

799 Southwest Airlines B-737-700 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

801 Southwest Airlines B-737-700 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1115 Southwest Airlines B-737-700 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

936 Southwest Airlines B-737-700 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1419 Southwest Airlines B-737-800 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1268 Southwest Airlines B-737-800 D Dallas 14 CFR Part 60 Change 1, Appendix A A ST7X

1319 Spirit Airlines, Inc. A-320-200 D Ft Lauderdale 14 CFR Part 60 Change 1, Appendix A A

1318 Spirit Airlines, Inc. A-320-200 D Ft Lauderdale 14 CFR Part 60 Change 1, Appendix A A

1383 Spirit Airlines, Inc. A-320-200 D Las Vegas 14 CFR Part 60 Change 1, Appendix A A

1337 Strategic Simulation Solutions L.L.C. A-320-200 D Aurora 14 CFR Part 60 Change 1, Appendix A A

1391 Strategic Simulation Solutions L.L.C. ERJ-170-100 D Aurora 14 CFR Part 60 Change 1, Appendix A A FSI

1430 Strategic Simulation Solutions L.L.C. ERJ-170-100 D Aurora 14 CFR Part 60 Change 1, Appendix A A FSI

1320 Sun Country Airlines B-737-800 D Minneapolis 14 CFR Part 60 Change 1, Appendix A A

614 United Airlines A-320-232 D Denver 120-40B A TTS

445 United Airlines A-320-232 D Denver 120-40B A REDI

566 United Airlines A-320-232 D Denver 120-40B A TTS

585 United Airlines A-320-232 D Denver 120-40B A TTS

798 United Airlines A-320-232 D Denver 120-40B/Draft 40C A TTSL

282 United Airlines B-737-300 D Denver 120-40B A ST7X

261 United Airlines B-737-322 D Denver 120-40A A ST7X

1004 United Airlines B-737-800 D Houston 120-40B A ST7X

616 United Airlines B-737-800 D Houston 120-40B/Draft 40C A ST7X

1136 United Airlines B-737-800 D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

1137 United Airlines B-737-800 D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

1354 United Airlines B-737-800 D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

1420 United Airlines B-737-900ER D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

29 United Airlines B-747-200 C Denver 120-40B A REDI

589 United Airlines B-747-400 D Denver 120-40B A ST7X

420 United Airlines B-747-400 D Denver 120-40B A ST7X

267 United Airlines B-747-422 D Denver 120-40A A ST7X

578 United Airlines B-757-200 D Denver 120-40B A ST7X

513 United Airlines B-757-200 D Houston 120-40B A TTS

328 United Airlines B-757-222 D Denver 120-40B A ST7X

329 United Airlines B-757-222 D Denver 120-40B A ST7X

179 United Airlines B-767-300 C Denver 120-40B A ST7X
58

Sim ID Company Name Make Model Series

Sim 

Level City Name Code Active

Company 

Identifier

680 United Airlines B-767-300 D Denver 120-40B/Draft 40C A ST7X

665 United Airlines B-767-400 C Denver 120-40B/Draft 40C A FSI

691 United Airlines B-767-400ER D Denver 120-40B/Draft 40C A ST7X

606 United Airlines B-777-200 D Denver 120-40B A ST7X

511 United Airlines B-777-200 D Denver 120-40B A REDI

467 United Airlines B-777-222 D Denver 120-40B A REDI

550 United Airlines B-777-222 D Denver 120-40B A TTS

1245 United Airlines B-787-8 D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

1434 United Airlines B-787-8 D Houston 14 CFR Part 60 Change 1, Appendix A A ST7X

699 United Parcel Service A-300-B4600R D Louisville 120-40B/Draft 40C A TTS

254 United Parcel Service A-300-B4600R D Louisville 14 CFR Part 60 Change 1, Appendix A A LINK

1012 United Parcel Service B-747-400 D Anchorage 120-40B/ICAO A ST7X

318 United Parcel Service B-757-200 D Louisville 120-40B A REDI

485 United Parcel Service B-757-200 D Louisville 120-40B/Draft 40C A REDI

1140 United Parcel Service B-767-300ER D Louisville 14 CFR Part 60 Change 1, Appendix A A TTSL

326 United Parcel Service MD-11-11 D Louisville 120-40B A ST7X

1037 United Parcel Service MD-11-11F D Anchorage 120-40B/Draft 40C A ST7X
59
60

Appendix B Full Definitions 19

Flight Simulation Training Device (FSTD) – A full flight simulator (FFS) or a flight training 

device (FTD).

FSTD Directive —a document issued by the FAA to an FSTD sponsor requiring a modification to 

the FSTD due to a safety-of-flight issue and amending the qualification basis for the FSTD.

Flight Training Device (FTD) —a replica of aircraft instruments, equipment, panels, and controls 

in an open flight deck area or an enclosed aircraft flight deck replica. It includes the equipment and 

computer programs necessary to represent aircraft (or set of aircraft) operations in ground and 

flight conditions having the full range of capabilities of the systems installed in the device as 

described in part 60 of this chapter and the qualification performance standard (QPS) for a specific

FTD qualification level. (Part 1)

Full flight simulator (FFS) means a replica of a specific type; or make, model, and series aircraft 

cockpit. It includes the assemblage of equipment and computer programs necessary to represent 

aircraft operations in ground and flight conditions, a visual system providing an out-of-the- cockpit 

view, a system that provides cues at least equivalent to those of a three-degree-of- freedom motion 

system, and has the full range of capabilities of the systems installed in the device as described in 

part 60 of this chapter and the qualification performance standards (QPS) for a specific FFS 

qualification level.

 

19 Appendix F to Part 60—Definitions and Abbreviations for Flight Simulation Training Devices, Electronic Code 

of Federal Regulations, http://www.ecfr.gov/cgi-bin/textidx?c=ecfr&SID=9505f8bab8371e9001265430eb5286f7&rgn=div9&view=text&node=14:2.0.1.1.1.0.1.25.6&idno= 14
61

Sponsor – a certificate holder who seeks or maintains FSTD qualification and is responsible for 

the prescribed actions as prescribed in this part and the QPS for the appropriate FSTD and 

qualification level.

Objective Test —a quantitative measurement and evaluation of FSTD performance

Qualification Performance Standard (QPS) —the collection of procedures and criteria used when 

conducting objective and subjective tests, to establish FSTD qualification levels. The 

Qualification Performance Standards are published in the appendices to this part, as follows: 

Appendix A, for Airplane Simulators; Appendix B, for Airplane Flight Training Devices; 

Appendix C, for Helicopter Simulators; Appendix D, for Helicopter Flight Training Devices; 

Appendix E, for Quality Management Systems for Flight Simulation Training Devices; and 

Appendix F, for Definitions and Abbreviations for Flight Simulation Training Devices.

Qualification Test Guide (QTG) —the primary reference document used for evaluating an aircraft 

FSTD. It contains test results, statements of compliance and capability, the configuration of the

aircraft simulated, and other information for the evaluator to assess the FSTD against the 

applicable regulatory criteria.

Subjective Test —a qualitative assessment of the performance and operation of the FSTD.
62

Appendix C Definitions of FSTD Levels

FTD Level Descriptions

a. The following is a general description of each level of FTD. Detailed standards and tests for the various levels of

FTDs are fully defined in Attachments 1 through 3 of this appendix. 39

(1) Level 4. A device that may have an open airplane-specific flight deck area, or an enclosed airplanespecific flight deck and at least one operating system. Air/ground logic is required (no aerodynamic

programming required). All displays may be flat/LCD panel representations or actual representations of

displays in the aircraft. All controls, switches, and knobs may be touch sensitive activation (not capable

of manual manipulation of the flight controls) or may physically replicate the aircraft in control

operation.

(2) Level 5. A device that may have an open airplane-specific flight deck area, or an enclosed airplanespecific flight deck; generic aerodynamic programming; at least one operating system; and control

loading that is representative of the simulated airplane only at an approach speed and configuration. All

displays may be flat/LCD panel representations or actual representations of displays in the aircraft.

Primary and secondary flight controls (e.g., rudder, aileron, elevator, flaps, spoilers/speed brakes, engine

controls, landing gear, nosewheel steering, trim, brakes) must be physical controls. All other controls,

switches, and knobs may be touch sensitive activation.

(3) Level 6. A device that has an enclosed airplane-specific flight deck; airplane-specific

aerodynamic programming; all applicable airplane systems operating; control loading that is

representative of the simulated airplane throughout its ground and flight envelope; and significant

sound representation. All displays may be flat/LCD panel representations or actual representations

of displays in the aircraft, but all controls, switches, and knobs must physically replicate the aircraft

in control operation.

The following is a general description of a level 7 FTD proposed by this rule.

(4) Level 7. A Level 7 device is one that has an enclosed airplane-specific flight deck and

aerodynamic program with all applicable airplane systems operating and control loading that is

representative of the simulated airplane throughout its ground and flight envelope and significant sound

representation. All displays may be flat/LCD panel representations or actual representations of displays

in the aircraft, but all controls, switches, and knobs must physically replicate the aircraft in control

operation. It also has a visual system that provides an out-of-the-flight deck view, providing cross-flight

deck viewing (for both pilots simultaneously) of a field-of-view of at least 200 horizontally and 40°

vertically.

FFS Level Descriptions (based upon proposed Part 60 NPRM)

Level D. A device that has an enclosed airplane-specific flight deck; airplane-specific 

aerodynamic and ground handling programming; all applicable airplane systems operating; static 

and dynamic control loading that is specific to the simulated airplane throughout its ground and 

flight envelope; and aircraft specific sound representation that has been objectively measured. It 

also has a visual system that provides an out-of-the-flight deck view, providing cross-flight deck 

viewing (for both pilots simultaneously) of a field-of-view of at least 200° horizontally and 40° 

vertically. Additionally, it requires motion cueing in at least six degrees of freedom (pitch, roll, 

yaw, surge, heave, and sway) and objectively measured airplane specific characteristic motion 

vibrations.

39 Appendix B to part 60, 24. Levels of FTDs.
63

Level C. A device that has an enclosed airplane-specific flight deck; airplane-specific 

aerodynamic and ground handling programming; all applicable airplane systems operating; 

static and dynamic control loading that is specific to the simulated airplane throughout its 

ground and flight envelope; and aircraft specific significant sound representation. It also has a

visual system that provides an out-of-the-flight deck view, providing cross-flight deck viewing

(for both pilots simultaneously) of a field-of-view of at least 200° horizontally and 40° 

vertically. Additionally, it requires motion cueing in at least six degrees of freedom (pitch, roll,

yaw, surge, heave, and sway) and airplane specific motion special effects and buffets. Level C 

FSTDs are qualified to conduct the same tasks as Level D FSTDs, but are restricted from 

crediting certain training and testing for pilots that do not meet the experience requirements as 

defined in Part 121 Appendix H.

Level B. A device that has an enclosed airplane-specific flight deck; airplane-specific 

aerodynamic and ground handling programming; all applicable airplane systems operating; 

static control loading that is specific to the simulated airplane throughout its ground and flight 

envelope; and basic aircraft sound representation. It also has a visual system that provides an 

out-of-the-flight deck view of at least 45° horizontally and 30° vertically. Additionally, it 

requires motion cueing in at least three degrees of freedom (pitch, roll, and heave) and airplane 

specific motion special effects and buffets. For certain training tasks such as takeoff, landing, 

and taxi, Level B FSTDs are qualified only for continuing qualification training.

Level A. A device that has an enclosed airplane-specific flight deck; airplane-specific 

aerodynamic programming; all applicable airplane systems operating; static control loading

that is specific to the simulated airplane throughout its ground and flight envelope; and basic

aircraft sound representation. It also has a visual system that provides an out-of-the-flight deck 

view of at least 45° horizontally and 30° vertically. Additionally, it requires motion cueing in 

at least three degrees of freedom (pitch, roll, and heave). Level A FSTDs are not qualified to 

conduct most takeoff, landing, or taxi training tasks.
64

Appendix D Changes between the Final Rule and the NPRM

Issue Significant Changes Rationale Cost Impact

Full Stall 

Evaluation

Improved definition of the stall angle 

of attack for the purposes of defining 

the required aerodynamic modeling 

range. 

Made clarifications concerning 

acceptable source data for stall 

aerodynamic models. Clarified that 

data sources other than the aircraft 

manufacturer may be acceptable if 

they meet the modeling and SME 

pilot evaluation requirements.

Improved the defined qualification 

requirements for subject matter 

expert (SME) pilots that subjectively 

evaluate the stall model. Adds 

deviation authority if an acceptable 

SME pilot cannot be located. 

Allows for SME evaluation to be 

conducted on an engineering or 

development simulator.

Removed requirement for all newly 

qualified FSTDs to be evaluated and 

qualified for full stall training tasks. 

Full stall qualification will only be 

required for FSTDs used to conduct 

this training.

(Previously qualified FSTDs) 

Removed the objective testing 

requirements for stall maneuvers 

where validation data is not likely to 

Ensures the aerodynamic 

model covers an adequate 

range of angle of attack to 

conduct stall recovery 

training. Clarifies specific 

issues with stick pusher 

equipped and envelope 

protected aircraft.

Commenters requested 

clarification on whether 

OEM provided models were 

required or not.

Commenters requested 

clarification on SME 

qualification requirements. 

SME evaluation on a 

common engineering 

simulator will reduce burden 

on sponsors and data 

providers for FSTDs that 

share a common 

aerodynamic model.

Part 91 and part 135 

operators currently have no 

mandate for training full 

stall maneuvers. If such 

training becomes mandatory 

in the future, these FSTDs 

will become subject to the 

FSTD Directive if used in 

training. Sponsors can 

choose which FSTDs to 

qualify.

The NPRM requirement for 

“baseline” objective testing 

has no added value other 

than for repeatability testing. 

None

None

Small to 

Moderate 

cost 

decrease

Moderate 

cost

decrease

Small to 

Moderate 

cost 

decrease
65

Issue Significant Changes Rationale Cost Impact

exist (cruise and turning flight stall). 

These conditions will still require 

aerodynamic modeling and 

subjective evaluation by a subject 

matter expert pilot. 

UPRT 

Evaluation

Removed FSTD evaluation 

requirements for Level A and Level 

B FSTDs.

Removed specific requirement for 

features and malfunctions necessary 

to drive upset scenarios. 

Removed the requirement for audio 

and video record/playback 

functionality.

Improved the definition of required 

instructor operating station (IOS) 

parameters and feedback 

mechanisms. Allows for methods 

other than graphical displays to be 

used where the required parameters 

are provided to support the training 

program.

Expands the definition of UPRT to 

include unusual attitude training in 

which scenarios are introduced that 

are intended to exceed the defined 

parameters of an aircraft upset. 

Better differentiates UPRT from the 

existing part 60 unusual attitude 

training requirement.

Level A and Level B FSTDs

lack much of the required 

cueing needed to train 

UPRT. Operators desiring 

to use a Level A or Level B 

FSTD will still have the 

option of applying for 

deviation authority under § 

121.423.

This has been addressed in 

FAA guidance material on 

upset prevention and 

recovery training (Advisory 

Circular 120-111).

Commenters cited this as a 

potentially higher cost item 

(for older FSTDs) that is not 

necessary to accomplish the 

training objectives.

Commenters cited this as a 

potentially higher cost item 

(for older FSTDs) that is not 

necessary to accomplish the 

training objectives.

Ensures FSTDs are not 

being inappropriately used 

for unusual attitude training 

into aircraft upset conditions 

without proper evaluation. 

Current part 60 requirements 

limit unusual attitude 

training/qualification to 

within the “normal 

envelope”.

None

Minimal 

cost 

decrease

Moderate 

cost 

decrease

Moderate 

cost 

decrease

None

Engine 

and 

Clarified that specific icing effects 

are only required to be introduced 

Clarification requested by 

commenters.

None
66

Issue Significant Changes Rationale Cost Impact

Airframe 

Icing 

Evaluation

where representative of the 

particular aircraft.

Revised the legacy part 60 engine 

and airframe icing special effects test 

(Table A3F) to remove references to 

gross weight increments and to 

better align with the updated 

requirements.

Clarified that flight test data is not 

necessarily required for the 

development of icing models. 

Engineering and analytical methods 

may be used to develop 

representative icing models.

Added provisions to allow for 

supplemental tuning of the icing 

model using an SME pilot 

assessment.

Corrected errors in the 

NPRM and aligned existing 

requirements.

Clarification requested by

commenters

Clarifications requested by 

commenters

None

None

None

Gusting 

Crosswind 

Evaluation

Removed references to the 

windshear training aid for gusting

crosswind model development. 

Recommended gusting crosswind 

profiles will be provided by the FAA 

in guidance material.

Removed minimum qualification 

requirement for Level A and Level B 

FSTDs.

Commenters requested that 

the FAA provide gusting 

crosswind profiles to meet 

the qualification 

requirements. The models 

will be provided as guidance 

and will not be a minimum 

requirement. Sponsors will 

retain the ability to develop 

their own models.

Removed minimum 

requirement for lower level 

FFSs that are not fully 

qualified for all landing 

tasks.

Small cost 

decrease

None

Bounced 

Landing 

Recovery 

Evaluation

Removed ground reaction 

requirement to compute nosewheel 

exceedances. 

Clarified the requirements to 

emphasize the effects and 

indications of ground contact due to 

landing in an abnormal aircraft 

attitude and that aircraft dynamics in 

This parameter is not 

typically provided with 

simulator data packages and 

is not necessary to conduct 

the training.

Clarification requested by 

the commenters

Small cost 

decrease

None
67

Issue Significant Changes Rationale Cost Impact

a bounced landing recovery are 

already adequately covered in the 

current part 60 rule.

ICAO 

9625 

Alignment

Restored the current general 

requirements table (Tables A1A and 

B1A) format, numbering system, 

and content to the current part 60 

versions. Appended the proposed 

ICAO 9625 (Edition 3) requirements 

from the NPRM into their applicable 

sections. 

Restored the existing part 60 visual 

system field of view (180°x40°) and 

system geometry requirements.

Adopted the less restrictive visual 

system lightpoint brightness 

tolerance (5.8 ft.-lamberts) from the 

updated ICAO 9625 (Edition 4) 

document.

Adopted the less restrictive transport 

delay tolerances (100/120 

milliseconds) from the updated 

ICAO 9625 (Edition 4) document.

Modified the objective motion 

cueing test (OMCT) description to 

not require testing for continuing 

qualification evaluations, remove 

minimum tolerances, and further 

moved much of the technical test 

details into guidance material.

Incorporated various clarifications, 

corrections, and other improvements 

from the recently published ICAO 

9625 (Edition 4) document.

ICAO numbering system 

and format was found to be 

confusing and inadvertently 

included requirements on 

some FSTD levels not 

impacted by the alignment.

The additional field of view 

introduced by the ICAO 

alignment was cited as not 

necessary for training and 

could drive significant cost 

increases for new FSTDs.

The tolerances in the NPRM 

introduced from the ICAO 

9625 (Edition 3) document 

were found to be difficult 

for certain types of new 

visual projectors to meet 

(LED systems).

The tolerances in the NPRM 

introduced from the ICAO 

9625 (Edition 3) document 

were found to be difficult to 

meet on some FSTDs.

Testing is beneficial in the 

motion algorithm tuning 

process, but fixed tolerances 

have not matured. Technical 

test details are more 

appropriate for guidance 

material.

Corrects issues identified 

with the ICAO 9625 

(Edition 3) document as 

proposed. Where new and 

more restrictive 

requirements were added to 

the ICAO document, these 

None

Moderate 

cost 

decrease

Small cost 

decrease

Moderate 

cost 

decrease

Small cost 

decrease

None
68

Issue Significant Changes Rationale Cost Impact

Aligned language where practical for 

similar stall, UPRT, and icing 

requirements from the ICAO 9625 

(Edition 4) document.

Added deviation authority for the 

FAA to accept alternate FSTD 

evaluation standards issued by ICAO 

or other national aviation authorities 

where an equivalent level of safety is 

demonstrated. 

Reorganized the flight training 

device (FTD) requirements in 

Appendix B to restore the existing 

table structure and better separate 

requirements for the new Level 7 

FTD and the legacy part 60 FTD 

levels.

Clarified the Level 7 FTD’s 

minimum qualified training tasks to 

better align with the ICAO 9625 

guidelines. 

Removed minimum requirements for 

extended envelope training tasks that 

are not included in the ICAO 9625 

(Edition 4) document for the Type V 

device.

were included in nonregulatory information 

sections as recommended 

practices.

Alignment of language with 

the international guidance as 

recommended by 

commenters. Some 

differences were maintained 

to address comments to the 

NPRM.

Allows for FSTD sponsors 

to optionally use an updated 

international standard. 

Promotes a more timely 

recognition of updated 

FSTD evaluation criteria as 

well as multi-national 

qualification of FSTDs.

Addresses commenter 

concerns with the new Level 

7 FTD requirements being 

inadvertently carried over to 

legacy FTD levels. 

Addresses commenter 

concerns that this fixed-base 

FTD may be used 

inappropriately in lieu of a 

full flight simulator beyond 

the ICAO recommendations.

Part 121 requires this 

training to be conducted in a 

Level C or Level D FSTD. 

Maintains consistency with 

the ICAO document.

Minimal 

cost 

decrease

Small to 

Moderate 

cost 

decrease

None

None

None
69

Appendix E Cost Estimates of Standard Data Updates (Pre-updates) to 

FSTDs

In order to estimate the cost of standard FSTD data updates that may be necessary before 

additional modifications can take place to meet the requirements of this rule, the FAA gathered 

information from some FSTD sponsors and manufacturers on the typical cost to conduct a 

standard data blockpoint update. As described in the previously defined categories of aircraft 

OEM provided updates, the FAA expects a variance in cost as a function of the age of the FSTD, 

the current data package revision, and whether the FSTD represents a fly-by-wire (FBW) aircraft 

that may require a more extensive integrated data update. For each category, the FAA has 

estimated the following additional costs for a standard data update. These estimates represent 

the additional cost to conduct pre-updates that may be required before modifications to the 

aerodynamic model can be incorporated to meet the requirements of this final rule. 

• Simple Aircraft OEM Solution: No additional standard data update costs will apply to 

FSTDs in this category.

• Standard Data Package Update: The FAA has estimated that a standard data package 

blockpoint update will cost an additional $200k per FSTD. This cost is based upon 

estimates from Flight Standards personnel who have experience in similar FSTD data 

updates as well as feedback from discussions with several FSTD manufacturers and air 

carriers . While typical data updates on some FBW equipped aircraft FSTDs can cost 

significantly more, in the range of $800,000 and higher, most standard data package 

updates for FBW aircraft include additional elements, such as avionics systems updates 

and other changes that have little to no relevance to the aerodynamic model changes 

necessary to support stall and upset recovery training. Furthermore, because the average 

age of FBW FSTDs in this category is only 3.8 years old, the FAA does not believe 
70

extensive hardware modifications will be required on these FSTDs that would warrant 

such a high cost range.

• Standard Data Package Update with Hardware Updates (Non-FBW Aircraft): The 

FAA has estimated that a standard data package blockpoint update with a replacement 

simulator host computer will cost an additional $500,000 per FSTD. This cost is based 

upon estimates from Flight Standards personnel who have experience in similar FSTD 

data updates as well as feedback from discussions with FSTD manufacturers and 

operators.

• Standard Data Package Update with Hardware Updates (FBW Aircraft): The FAA 

has estimated that a standard data package blockpoint update on an older FBW aircraft 

FSTD which may require significant hardware updates will cost an additional $1 million

per FSTD. This cost is based upon feedback from FSTD manufacturers and operators 

who state that many of the older Airbus FSTDs will require significant modifications to 

bring them up to the latest revision of their data package. While the FAA received a wide 

range of cost estimates from industry to conduct such a major update, the FAA chose a 

nominal $1 million in cost for the following reasons. First, a typical FBW data package 

contains updates to many areas in the simulation that have little impact on stall and 

UPRT training, such as avionics systems and other systems simulation. Second, 

particularly for older devices that are nearing the end of their useful lifespan, the FAA 

expects the FSTD sponsors will explore the viability of using a lower cost nonOEM/third party provided solution in lieu of conducting extensive modifications to these 

older FSTDs that may not be necessary to conduct the required training tasks. Due to 

these factors, the FAA believes the market will potentially drive a lower cost solution for 

those sponsors.