Basic information on what’s involved in certifying your simulator as an ATD.
By Gabriel Accascina with Jim Williams
AFSBI – June 2018 – All rights reserved.
Like several of our Members, you have probably invested considerably in your flight simulator. You can run through your simulated aircraft checklist and find a realistic equivalent of every control in the real aircraft on your simulator’s cockpit. Your visuals are excellent and the response time, and frame rate realistic. Moreover you have spent considerable money in modern avionics, perhaps even a G1000 setup. At the same time you are taking flying lessons, or know someone who does. Perhaps a flight instructor has already tested your simulator and declared it representative enough for instrument training. In fact, it may even be better than the aircraft for certain type of instructions, especially in managing the software behind the avionics. Who needs to spend money twisting knobs and push buttons while burning 100 low lead when you can do exactly the same in the sim? It’s all about building muscle memory, after all.
Here comes the question, if I am in the US (other countries may differ in their norms), can I certify my simulator, so that I can use it, with a CFI, to log time as an Aviation Training Device (ATD)? Most people, regardless of how sophisticated and life-like your simulator is, will respond: don’t even try. Buy a commercial BATD or AATD (basic or advance ATD) and you will save time and aggravation. Sound advice, perhaps, but should it be so? Before explaining what’s involved, let’s consider the following: today you could, when training for the instrument rating, count up to 10 hours in a BATD or 20 hours of use in an approved AATD toward the FAA time requirements (we will not discuss here the allowance in Part 141 schools, as it is of less interest to our Members) but it goes without saying that if you own a simulator you will likely use it more and, in turn, may become more proficient than if you will rent one at the local flying school. To close this preamble, the interest to many is not financial, they will likely not charge anything to other using their simulator, but rather one of effectiveness in their training and in achieving ongoing proficiency. Especially in some regions of the US, where harsh winters are common, being able to keep up one’s skills all year long becomes a legitimate and valuable proposition.
The FAA unit which deals with Approval of Aviation Training is AFS-800, headed by Mr. Marcel Bernard, Airmen Certification and Training Branch, Flight Standards Service. The official FAA documentation and rule-making related to simulator certification, criteria, technical specifications and allowed use are split across two main documents. The rule-making process is reported in a few more. Start with AC No: 61-136A “FAA Approval of Aviation Training Devices and Their Use for Training and Experience” which describes the two currently allowed type of ATDs. The definition:
“An ATD is a training device, other than a full flight simulator (FFS) or flight training device (FTD), that has been evaluated, qualified, and approved by the Administrator. In general, this includes a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit. It includes the hardware and software necessary to represent a category and class of aircraft (or set of aircraft) operations in ground and flight conditions having the appropriate range of capabilities and systems installed in the device as described within this advisory circular (AC) for the specific basic or advanced qualification level.”
For approval, the FA requires a QAG, a Qualification and Approval Guide. Which is a detailed description of the systems and design criteria for a BATD or AATD. Any changes to the simulator, you guessed it, requires a new QAG. The document then proceed to describe the criterial for approval of an ATD. We note here that the FAA is not strict as to the exact make and model of the aircraft being simulated but rather it: “should closely model the aircraft in the family of aircraft represented”. That is the initial required reading. For those who want to go further: Volume 11, Chapter 10 of Document 8900.1 highlights how to request the approval and the details of the evaluation, inspection and approval process. It also, and importantly, lists what it’s expected of the simulator, as in a curriculum that would be used by trainees.
Two documents, (proposed rule in 2015 and the final rule in 2016 ) highligh part of the recent rulemaking process on credits toward certification, and public comments related to it. AOPA’s article “FAA restores sim time for instrument rating” is a good summary of what is essentially a restoration of a previous rule related to credits.
There are additional FAA levels of certification for simulators depending upon the complexity and purpose of the device. In some cases, a flight school or college may want to certify a flight sim so that provides training in support of specific curriculum. An example would be a jet transition series of classes. The FAA provides another category of training device certification for this purpose and it is referred to as a Level 4 or level 5 Flight Training Device (FTD). The difference between the two is the level of fidelity the simulator provides for a specific aircraft (e.g., B737-800) or a series of similar aircraft. Note this level of certification only applies if an FAA approved flight school buys or sponsors your simulator.
If you have read so far you may want to hear from an expert. For this, we interviewed Jim Williams, who has carried out several simulator certifications. He is AFSBI’s advisor on this issue and consults frequently with those seeking approval.
Q: What does it really take to get approval for a single production simulator?
A: Jim: The first step is determining if your simulator qualifies as a Basic or Advance training device (BATD or AATD). An AATD meets then exceeds all of the requirements for a BATD. Your initial contact with he FAA will provide you with the Federal regulations along with guidelines for the QAG. The FAA is very precise in what goes in that document and exactly how it should be formatted. Don’t be surprised if you go through two or three iterations with the FAA on the “look and feel” of this document. The FAA also suggest that a video be produced that illustrates the major functions of the training device. For example, normal take offs and landings; instrument weather conditions; NAVAID use including instrument approaches; major systems failures especially those in the aircraft operating handbook; and flight tracking through the use of moving maps and other supporting tools. Once the QAG and video are complete they are provided to the FAA for review. After the initial review is complete the FAA will schedule a flight review of your simulator. Depending upon the complexity (single, multi-engine or jet transport), the FAA examiner and perhaps a flight examiner familiar with this type of aircraft will arrive at your location to conduct a flight review that can take a full day. Expect to have the FAA find items in your cockpit that need modifications or additions. A second flight review may be required, but if not, providing pictures of the enhancements might be sufficient. Following each of these steps the FAA will issue a Letter Of Authorization (LOA) specific to your simulator.
Q: What type of people are most of your clients?
A: Jim: The majority of clients will fit into two categories: the university or technical college that provides a flight training program, and the local or regional flight school at your airport. Both clients have similar requirements. You might actually find local pilots who want to use your simulator for IFR refresher training without a CFI present. They can’t log that time, but your simulator will certainly be less costly than one located at a flight school.
Q: Certification timeframe?
A: Jim: Obtaining an LOA for a BATD or AATD can be from six months to a year from the day you start writing the QAG. It is critical to the schedule to follow PRECISELY the FAA regulations and guidelines or the time frame can get excessive. Recertification of your simulator will be required any time you make a change. A change does not refer to updating a tool such as FSUIPC software, but does apply when updating the visual system, adding additional capabilities or switching operating systems.
Q: Any other suggestions?
A: Jim: Even though your first read of the FAA regulations will lead you to believe it is cut and dry with regards to what is required – the loop whole in the regulations is that what is sufficient for controls, their look, their placement and their function is up to each individual FAA examiner. The BATD and AATD guidelines were written with respect to the simulator being representative of low complexity aircraft such as a Cessna 172 or Piper Arrow. As you add complexity, perhaps getting into a King Air Turboprop or perhaps even a Boeing 737-800, the AATD guidelines are difficult to meet. For example, the AATD regulations require that your simulator be capable of presenting every failure in the pilot operating handbook along with every indication on instruments and gauges that reflect that failure. As you can imagine, a low-cost simulator generally is not designed to operate at that level of fidelity. I have found the FAA cooperative in that area but be prepared to fail the flight review if you cannot meet these requirements.
A final comment for home builders about software licensing. Many of you are probably not aware that your simulator is using software that is licensed for home use only. Examples could be FSUIPC, Lockheed’s Prepar3D, Prosim AR’s B737, along with various scenery and weather generation systems. To use your simulator for ANY commercial business would violate the law if it was built using this type of license. There are extreme examples of where this license when purchased for commercial purposes is prohibitively expensive. For example, some high-fidelity flight models such as Prosim B737 are only a few hundred dollars per year to own for home use but can reach into the tens of thousands for a commercial version of the license. Please consider this when looking at certifying your simulator.
Here at AFSBI, we think that the environment for simulation has changed completely, since aircrafts went digital on avionics, engine control and monitoring, communication and navigation. Integrated panels and individual digital instruments, as mentioned above, are easier to learn on an environment that favors complex learning and a simulator surely is. The question then is if simulator-based training should reflect this changing environment by facilitating and supporting even further simulator-based instrument practice. We believe that ATDs are much better at that than at conducting primary instructions, perhaps with the exception of the basic functioning of an aircraft controls and monitoring. It’s an open question with normative consequences, perhaps to be examined in further postings.
Let us have your comments and perspectives from the US and other Countries, below or at our Forum. You can also reach Jim .