The Society of Aviation and Flight Educators (SAFE) have informed the FAA that an unexpected change in agency policy on Letters of Authorization (LOAs) for GA flight simulators will harm aviation safety, create a burden on the industry, and run counter to the intent of current LOAs.
“The FAA should be encouraging better pilot training, not discouraging it,” said Doug Stewart, SAFE Executive Director. “The extra simulator training hours allowed by these LOAs is invaluable.”
GA simulators affected by the FAA change in policy will include virtually all FAA approved Personal Computer Aviation Training Devices (PCATD), Flight Training Devices (FTD) level 1-3, Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD), SAFE officials noted.
The FAA’s Notice of Policy Change for the Use of FAA Approved Training Devices, published with docket number FAA-2013-0809 in the Jan. 2 edition of the Federal Register, will sunset all FAA Letters of Authorization (LOAs) for GA flight simulators on Jan. 1, 2015.
That will limit pilots to the FAR Part 61.65(i) maximum of 10 hours of simulator time loggable toward an instrument rating. Some LOAs for advanced simulators currently allow as many as 20 hours of simulator training to count toward an instrument rating.
“FAA officials, understanding the value of simulators in flight training, have been issuing these LOAs since 1980,” said Stewart. “This proposed policy change will take away much of the incentive for pilots to improve their skills in a better classroom than a noisy cockpit.”
SAFE’s official comments ask the FAA to rescind its proposed policy change in the interests of safety. The comments also point out that the proposed change is actually contrary to the intent of current letters of authorization and will create an undue burden on industry by forcing manufacturers and users to revert to prior FAA rule interpretations.
The full text of the Society’s comments is available here.
Comments on the proposal are now being accepted online.