In an effort to cut training costs and increase the number of licensed pilots, the FAA, with AOPA’s input, issued a new ruling, effective as early as June 27, 2018. The ruling is part of the modernization of CFR Part 61 and other parts. Its major rationale is as follows:
“The FAA estimates that pilots and operators will save up to $113.5 million over five years (in 2016 dollars), with the most significant savings to come from allowing instrument-rated pilots who use advanced aviation training devices (ATDs) to satisfy flight experience requirements to enjoy six months of currency rather than two. That part of the Part 61 overhaul takes effect Nov. 26. The extended currency interval also will allow instrument-rated pilots to use any combination of aircraft and ATD to accomplish the flight experience required for currency. The FAA estimates (in 2016 dollars) that these changes to 14 CFR 61.57(c) alone will save pilots $76.1 million over five years.”
The changes affecting the use of simulators are described in this table (click to expand). The requirement to have an instructor present for the pilot to log simulator time has been removed. This will allow training savings in the order of, according to the FAA, $12.5 million. We think that this is an important step toward the widespread use of simulators in flight training and have asked NAFI, the National Flight Instructors Association, to comment on this and will post their response below.
The other major change is the extension of the validity of simulator time: “Required frequency interval to accomplish instrument proficiency experience in ATD to be reduced from every two months to every six months; allows any combination of aircraft and ATD to accomplish required experience.” This brings currency validity on par with aircrafts, and it is expected to save an additional $12.5 million in instrument currency training. Additionally and of much interest to us at AFSBI, the word “approved” in reference to ATD’s has been dropped. Here is the FAA actual rationale and ruling.
The FAA Rule
“The FAA proposed to define ATD as a training device, other than a FFS or FTD, that has been evaluated, qualified, and approved by the Administrator. The FAA proposed to add this definition to § 61.1 to differentiate ATDs from FFSs and FTDs qualified under part 60 and to establish that an ATD must be evaluated, qualified, and approved by the Administrator to be used to meet aeronautical experience requirements under part 61.
The FAA received 3 comments on the proposed definition of “aviation training device.”
The Society of Aviation and Flight Educators (SAFE) concurred with the proposal. The Aircraft Owners and Pilots Association (AOPA), however, recommended removing the words “evaluated” and “qualified” from the proposed definition because they are redundant with “approved” and because the FAA may, at times, only need to “approve” a previously approved ATD model.
The FAA is retaining the terms “evaluated” and “qualified” because the evaluation and qualification of an ATD are important parts of the approval process. An ATD is evaluated and qualified before it is approved under § 61.4(c). Evaluating and qualifying ATDs validates their effectiveness for successful training. In response to AOPA’s comment regarding previously approved ATD models, the FAA finds that defining an ATD, in part, as “evaluated, qualified, and approved” will not adversely affect the use of ATD models that have been previously approved. Unlike FSTD which must be individually qualified under part 60, the FAA has permitted the use of ATDs that have been produced identical to the model evaluated, qualified, and approved utilizing a standard letter of authorization (LOA) for over 12 years. After the FAA provides initial approval of a specific model, that approval covers production of additional identical models by the manufacturer. However, the FAA reserves the right to re-evaluate any ATD used to meet pilot certification or experience requirements. Additional conditions and limitations in the LOAs explain that any changes or modifications made to the ATD that have not been approved in writing by the General Aviation and Commercial Division may terminate the LOA.
An individual commenter asked the FAA to clarify whether the definition eliminates the basic ATD and advanced ATD categories described in Advisory Circular (AC) 61-136. The individual also asked the FAA to update the related guidance and advisory materials with this clarification.
The ATD definition does not eliminate the qualification of an ATD as basic or advanced. The FAA is adding a general definition of ATD to § 61.1 to differentiate ATDs from FFSs and FTDs qualified under part 60 and to establish that an ATD must be evaluated, qualified, and approved by the Administrator. The FAA will continue to provide guidance in AC 61-136, as amended, to qualify an ATD as basic or advanced. Comparatively, the definition in part 1 for a FTD does not delineate qualification levels.“
“As stated in the NPRM, because instrument recency experience is not training, the FAA no longer believes it is necessary to have an instructor present when instrument recency experience is accomplished in an FSTD Start Printed Page 30237or ATD. The FAA is therefore removing the requirement for an authorized instructor to be present when a pilot accomplishes his or her instrument recency experience in an FFS, FTD, or ATD, as proposed. The FAA is, however, slightly revising the proposed rule language by removing the word “approved” because an FFS or FTD used to satisfy § 61.51(g)(5) is qualified, not approved, by the National Simulator Program under part 60. Furthermore, § 61.51(g)(4) retains the requirement for an authorized instructor to be present in an FSTD or ATD when a pilot is logging training time to meet the aeronautical experience requirements for a certificate or rating.“
We applaud the FAA for its advanced stance on the use of simulator for instrument recency purposes. We do not have any other example of a civil aviation authority allowing this, although some countries might outside our knowledge.
We hope to see more recognition, in the near future, of the home-based simulator’s role in training and practicing, and as an avenue to transition from simulation to real flying. Especially now that avionics are getting more capable and a lot more complex, having an affordable simulator at home and being able to use it for required currency may make a difference for many. Everyone agrees that knowledge of the complexities of the software used by digital, GPS-based avionics is better honed in a simulator rather than in the air. As we now see vendors marketing advanced simulator panels and other components that very closely resemble those of real airplanes, with the same functionality and physical controls, we ask if there will be scope for qualifying these systems for currency requirements as well.
We appreciate your comments here.