General Aviation Advisory Circulars

Appendix A

Exemption from Chapter 4, Appendix 4A, paragraph 2.f
and Appendix 4B, paragraph 3.2.C.9 of the Aeroplane
and Rotorcraft Simulator Manual standard
(TP 9685)
made pursuant to Subsection 606.03(2) of the
Canadian Aviation Regulations

Pursuant to subsection 5.9(2) of the Aeronautics Act, and after taking into account that the exemption is in the public interest and is not likely to affect aviation safety, I hereby exempt all operators of ATC 810 and AST 300 Flight Training Devices (FTDs) in Canada from the standard set out in the Aeroplane and Rotorcraft Simulator Manual (TP 9685), Chapter 4, Appendix 4A, paragraph 2.f. and Chapter 4, Appendix 4B, paragraph 3.2.C.9., subject to the following conditions.

Synthetic Flight Training Equipment

606.03(2) stipulates that the Minister shall, where it is determined that the synthetic flight training equipment meets the standards set out for that equipment in the Aeroplane and Rotorcraft Simulator Manual, issue to the operator of that equipment a flight simulator certificate or flight training device certificate.


The purpose of this exemption is to permit pilot training in Instrument Flight Rules (IFR) procedures utilizing an ATC 810 or AST 300 FTD, Level 2 Flight Training Device (FTD) which do not meet, in its totality, the requirements of Aeroplane and Rotorcraft Simulator Manual (TP 9685), specifically those of Chapter 4, Appendix 4A, paragraph 2.f. and Chapter 4, Appendix 4B, paragraph 3.2.C.9.

The lack of oscillation in pitch, evident in the phugoid dynamic test, does not provide for negative learning of IFR procedures such as departure, enroute, holding, arrival, approach and emergency procedures. However, in the development of basic instrument flight skills, the devices are deemed unsuitable.

Use of the devices for pilot training towards the private pilot licence (PPL), the VFR over-the-top (VFR OTT) and the night rating is not in the public interest. In recognition of the practice of training some radio navigation instrument procedures during pilot training towards the commercial pilot licence (CPL), a limited use of the devices for this purpose will be allowed.


This exemption is subject to the following conditions:

  1. The device shall meet the standards of a level 2 FTD, as set out in the Aeroplane and Rotorcraft Simulator Manual (TP 9685), with the exception of the requirement to display phugoid dynamics as set out in Chapter 4, Appendix 4A, paragraph 2.f and Chapter 4, Appendix 4B, paragraph 3.2.C.9. The device will then be qualified as a level 2(R) (restricted) FTD.
  2. The phugoid test shall be conducted and the results recorded.
  3. The device shall be used for CPL and instrument rating training in accordance with a flight training unit's flight training program outline.
  4. The device shall be physically located in Canada on the signatory date of this exemption and shall have a current Transport Canada certification or shall be certified by Transport Canada prior to September 1, 2005.
  5. The device shall not be used for training credits towards the private pilot licence and the VFR OTT and night ratings.
  6. For the purpose of radio navigation training on VOR, ADF, ILS and GPS, the device shall be limited to 5 of the 10 hours of instrument ground time allowed for the commercial pilot licence.
  7. All devices shall be subject to annual renewal of the FTD certificate.


This exemption is in effect until the earliest of the following:

  1. the date on which any condition set out in this exemption is breached; or
  2. the date on which this exemption is cancelled in writing by the Minister where he is of the opinion that it is no longer in the public interest or is likely to affect aviation safety.

Dated at Ottawa, Ontario, Canada, this 28th day of July 2005, on behalf of the Minister of Transport.

Original signed by Michel Gaudreau

Michel Gaudreau
Commercial and Business Aviation

Date modified: