The FAA has withdrawn a change to a rule that would have permitted a wider use of aviation training devices for instrument flight training in the U.S. — because the rule received two adverse comments.
Published on Dec. 3, 2014, the rule would have let pilots credit up to 20 hours of instrument time in an Advanced Training Device (ATD) such as a Redbird FMX or Frasca ATD toward an instrument rating under Part 61 of the Federal Aviation Regulations. Pilots in Part 141 programs would have been able to complete up to 40% of their required training hours in an ATD. The rule also would have eliminated the requirement to wear a view-limiting device while training in an ATD.
In the proposed rule, the FAA stated: “This rulemaking relieves burdens on pilots seeking to obtain aeronautical experience, training, and certification by increasing the allowed use of aviation training devices. These training devices have proven to be an effective, safe, and affordable means of obtaining pilot experience. These actions are necessary to bring the regulations in line with current needs and activities of the general aviation training community and pilots.”
The proposed rule was put forth under the Direct to Final clause, which meant no public comment period was required. In the proposal, the FAA noted that no negative comments were anticipated, however, there was the caveat that if the FAA received any negative comments, the proposed rule would be withdrawn, even if the number of positive comments outweigh the negative.
Of the 20 comments received, just two were negative, both questioning the realism and effectiveness of training obtained in an ATD.
People wishing to comment are not required to supply their names. An anonymous commentator wrote “CFIIs have known for years the airborne cockpit environment has the potential to be a horrible classroom in which to teach. It’s noisy, full of distractions, occasionally unpredictable. With all of this being said, do we really want our flight students to be trained and live in an unrealistic world?”
Let’s really think about a moderate medium vs a Happy Medium.
The commenter, who notes he is an ATP, CFII and air traffic controller, said that while training in the classroom environment and in labs was an excellent preparatory environment, it is nothing like the realities of real life, talking with real pilots, many that can’t communicate properly, with language barriers, and other issues.
He recommends the FAA “proceed with appropriate caution and understand the risk involved. As a quality control manager, we are seeing an increase in poor piloting skills and decisions.”
James Wolfe, an ATP from Ottawa Hills, Ohio, wrote: “As a professional pilot, ATP, CFI, CFII, and MEI land and sea, I do not agree with the new rule. It is my experience that flight requires the use and correlation of ALL our senses in order to make a lasting impression. Recognizing that our senses can sometimes deceive us in IMC, I nevertheless have still found that sounds and feel are vital to recognizing unusual attitudes, even when other senses fail us. More importantly, our acclimation to IMC helps us relate these various inputs to the strategies to deal with them.
“ATDs are valuable as procedure trainers, but not as valuable as everyone seems to think,” he continued. “The rapid redeployment of a situation seems like an advantage, yet it diminishes the learning because it seems so easy to recover from a botched maneuver. Resetting the situation also diminishes the ‘routine’ that a pilot relies on to take him to a specific place. For example: A failed approach followed by instantly reconfiguring the aircraft at the takeoff position for another flight, or even at the approach gate, removes all the preparatory steps a pilot normally follows to get there. This interferes greatly with the learning of each step.
“ATDs are firmly on the ground and no amount of graphic imagery or display setup, even in full motion simulators, ever causes a pilot to lose consciousness of that fact. Consequently, pilots do not experience the fear that accompanies real-life emergencies, or the sensory inputs that come with icing and thunderstorm contact. I have seen pilots paralyzed by encounters with severe turbulence or a stalled aircraft. No ATD can begin to simulate these conditions, yet they are the most likely to end in a fatal crash.”
A search of public records revealed that Wolfe, 68, does hold quite a few aviation certificates, however, there is no indication of his experience with modern ATDs or the amount of experience he has as a flight instructor. Our attempts to reach him were unsuccessful as a telephone number for him could not be located.
Because of the negative comments, the FAA is now required to file a Notice of Proposed Rule Making (NPRM) and seek public comment before considering a change to the regulations.
This turn of events has galvanized aviation advocacy groups and flight instructor organizations.
David Oord, director of regulatory affairs for the Aircraft Owners and Pilots Association, sent a letter to John Duncan, the FAA’s Director of Flight Standards Service, requesting the agency “expedite and publish” a NPRM that allows for an increase in the maximum time that may be credited in an ATD to 20 hours.
Oord noted that the use of ATDs has proven to be both beneficial and cost effective for instrument applicants, and that the applicant’s skill level still must be certified through a practical exam before the certificate is issued.
Both the National Association of Flight Instructors and the Society of Aviation and Flight Educators also expressed disappointment in the FAA’s withdrawal of the ATD Direct to Final Rulemaking, but react with cautious optimism over the idea of a public comment period.
NAFI Vice President of Government and Industry Affairs Phillip Poynor noted: “NAFI is encouraged by and will strongly support FAA’s promised action that it will proceed with a formal rulemaking to ultimately accomplish the same objective intended by the Direct to Final Rule effort. We encourage the FAA to do so with due dispatch as this delay in rulemaking is creating hardship and significant and unnecessary financial penalties upon leading flight training organizations that responded to earlier efforts of FAA to adopt the use of the very capable array of technologies found in today’s modern Aviation Training Devices.”
John Dorcey, SAFE’s interim executive director adds, “We understand the FAA’s need to follow their protocols, but will continue our efforts to get these changes enacted.”
He noted SAFE will ask the FAA to expedite re-issuing the rule as a conventional NPRM, not subject to dismissal due to a single negative comment.
“The fact remains that the existing FAR 61.65(i) is outdated,” Dorcey continued. “Both before and after this regulation was issued in 2009, the FAA issued hundreds of Letters of Authorization to simulator manufacturers permitting simulator hours in excess of the regulation.”
Two additional thoughts. I like the suggestion of the ratio time credit….2 sim equal 1 flight hour. That may have real merit combined with real flight in an aircraft.
The other deals with partial panel. There was a study done in conjunctio with AOPA and the FAA in I believe 2002 which validated a previous study. They used a Bonanza with an electric HSI and a PA-28 (Archer I Think) with vacuum driven DG and AI. The study revealed many things including the fact that total hours and the number of instrument time, real or sim, do not guarantee great results. The most realing, in my opinion, was in recognition of gyro failure. If the instrumentshad fail flgs the pilots obviously saw it faster. The PA-28 had been modified to allow the instructor to fail the static system…the bonanza instructor used a circuit breaker. In a sim you can fail gyros, but in most training the instructor covers the instrument to simulate failure which robs you of the opportunity learn to recognize it happening…and it is not usually instant ly noticeable. The time to recognize the failure varied from jus over 2 minutes to up to over 5 minutes. Proper scan of other indications is obviously needed at all times…such a suction gauges. This type of simulation is for realistic purposes not possible in real aircraft…modifying planes for this is no realistic.
So the final thought is that sim time should count for flifht time in training at so ratio level up to a maximum point with phase checks along the way to measure proper progress. And to the person who says you can not induce disorientation in a sim, he should get a chance to be in a non-moving dome sim and just stand on the platform while it is operating (besure you hold the railing…trust me). He can get real sensations in an Omnimax theater, too.
having given 5000hrs+ instruction in 757/767 A320 simulators, and bit more in the actual airplanes, I can attest to the fact that the simulator’s ability to recreate vertigo/somotographic illusions and negative g’s is not realistic..it needs to be experienced in the actual aircraft to reinforce the need for believing your instruments
I agree that your big plane simulators Probably can’t do it…they don’t move fast enough. I have so far not have had spatial disorientation no matter how hard my instructors/examiner have tried. However, my worst SD occurred in Star Tours at Disneyland where the visual does not equal the motion, but it has been a few years before flight training. My most recent very minor SD occured in the OneG Simulator in Seattle. It has a full immersion visual screen 8′ high by 18′ curved 180 degrees. The sim is a stationary Bonanza cockpit; it may not move, but it can still play games with your head!
With a 20 hr sim limit, or none at all, it still takes 50-70 hrs to train a pilot to be proficient and safe. A pilot is never done training instrument flight! It just saves expensive flight time getting the mental management, SPRM or CRM, G1000 (or others) flight programming/simulation, etc., accomplished on the ground. The failures? Engines, fuel, instruments, pitot & airframe ice, birds, autopilot, ceilings and weather, diversions, unusual attitude recoveries…all the problems needing you to save the airplane. Try that in plane safely…not!
BTW…in the FAR’s, simulator time is logable as flight training, simulator and simulated instrument time.
A student still needs airplane instrument time to qualify for the PPL, so the training in a simulator doesn’t qualify hours for your initial license, but it still may help with comm & nav initial management and ATC comm practice…invaluable before things get real busy when solo flight begins. So, to the naysayers…don’t knock it until you have tried some of the latest, very good simulators (an FAA certified FTD) with an instructor pushing your buttons while in full-on IMC!
One of the major causes of IFR accidents seems to be spatial disorientation, something that is nearly impossible to induce in any simulator…while limited training in these devices initially to teach/reinforce IFR procedures is great, the actual airplane environment needs to be the lion’s share of IFR training..
Simulators can obviously simulate many situations that would not be possible in real aircraft, not to mention unsafe. Developing good cockpit resource management and habits is also possible to a greater extent. Instructors should support this because they can focus on the training without having to split their focus inside and outside the aircraft and other distractions. The airlines and military have recognized the benefits in learning, safety, and cost. The real issue is, should the time count so heavily? I believe yes because of the fact you become immersed in the moment and focused to the point that the situation becomes they real thing. The students already know how to fly and are now “flying” just the same from a mental and muscle memory standpoint. I know someone who went through King Air training and was able to go fly the real thing with no problem. His training was sim only. He had never flown one. He said they training was very real. A possible way to ease some fears might be to have a phase check flight after x number of sim hours, and if the results are at the appropriate level, the CFI can sign the sim time as being credit for flight time. At least with this rule change the FAA is recognizing the future.
I have been teaching and training pilots in an AATD for over four years. In that time the quality of the device has greatly improved. I train many pilots with ATP, and Commercial licenses, fewer with Private but enough to know that is a highly effective device. Nothing but an aircraft replaces an aircraft, however that does not diminish the effectiveness of Simulator training. I strongly support the use of AATD’s when properly supervised by competent instructors using well written curriculum and enforcing the proper discipline. Some of the training that must be completed does not require nasty weather, just IMC that demands excellent scan, good skills and procedural knowledge. The simulator (AATD) is the smart choice for the time that is permitted by regulation. It is past due for the FAA to allow greater use of these devices as the technology has so improved that the results are positive for both instructors and students or certificated pilots in training. Many studies have shown good results, the cost for simulator training is much less than flying in the aircraft and the training can be done in a far broader set of situations and circumstances in a shorter time with far less risk. It just makes good sense to allow greater time credit. That is my opinion after a lifetime in the flying and training business. I believe there is adequate time in aircraft after the 20 hours being proposed for credit in the AATD. Consider this; how would our industry fare if we had to do all training in an aircraft. How would the space program fare without simulation. It seems to me the entire industry is moving in the direction of more simulation, albeit high fidelity, but to take the approach that pilots cannot learn with careful division of simulator time and actual aircraft time seems out of touch with the advances in technology. I hold an ATP, CFI, CFII, MEI in a variety of Military and Corporate aircraft including small GA aircraft.
I’ve been flying IFR over 30 years. When I got my rating I used a desktop simulator fo the Sim time allowed back then, which if I remember right was 1/2 (20 hours). I believe NOT having real world environment HELPED me focus oon learning the procedures and the “mechanics” of IFR flying without distraction. My experience with all forms of education and training is the value of layering information and building on not only knowledge but technique. Once I had procedures very well in mind and practiced I was then prepared to apply that in real world environment and learn to adapt what I knew to new stressful situations and the unexpected. I think to expect training to require more real world environment from day one is incorrect and unrealistic, just as much as it’s not appropriate to rely 100% on simulators no matter how sophisticated and virtual reality it may seem.
In reading this I have used both a sim and actual flight time for my certificates. There is no doubt that the student in the sim does not have all the sensory inputs that are needed, and that is why only part of the time can be sim time. To completely discount this training as some how less productive as actual flight time is a bad view. Sim time is generally compressed you don’t have all the time wasted taxiing and holding short waiting for other planes to land and depart. At high traffic training airports expensive hobbs time is quickly burnt up just waiting in the plane to take off, in the overall scheme of training several hours are wasted siting on the ramp.
Then there is the benefit of the pause button, in an actual plane if a student gets into a situation that has them confused, over whelmed or is just beyond their capabilities the instructor has to get them through it and the student becomes a passenger wasting more time, was it actually productive. Where in a sim if the student is over tasked simply press pause and discuss the issue solve the problem, confusion and move on. The best benefit I see is simply learning your procedures in the sim before wasting the expensive flight hours .
Then to claim that ifr training in the actual airplane is more beneficial because it puts you into dangerous real world situations is a misconception and a false sense of security. Unless your instructor is taking you up into poor weather your still training on relatively decent days. Ive flown with several instrument rated pilots that have very little actual time. So how better prepared are they?
Now do I feel Sim time should be credited equally as flight time, maybe this is where we should be looking, maybe make it worth 50-75% of the hours so 2 sim hours equal 1 or 1.5???
I have really no “horse in this race”—no economic interests “one way or the other”—which sorry to say appears to be the major consideration these days in General Aviation. However, I have been flying IFR for forty five + years. To attempt to contemplate that the situations I have been up against during all these years in IFR could be simulated in a ground based machine to the level of giving credit in the certification process is dangerous phantasy at it best. Most of us start “IFR training” by reading a book and then may be take some classes—not even real ground school yet. From this “level of training” the simulator may be able to “visualize” what we have been reading about. However, to grant direct credit on an hourly basis for the operation of an on ground simulator in the certification process reveals a serious lack of understanding of what it means to operate in an IFR environment as further outlined by some of the commentators.
It seems to me that what we have here is a technology gap. On one side, we have the 25, 30, 40+ year pilots versus those of us with less than 20 years. I have been out of the “left seat” for seven years (for different reason) and have started the way back to the seat. I truely believe that the ATD has been a huge benefit. It has helped me re-learn procedures, cockpit management, handle emergencys, and rebuild muscle memory. All the different scenarios (weather, system failures, crowded airspace) that the instructor can program is a true learning experience that can not be duplicated in the air safely. And speaking of safety, which we all are, if you screw up in the Sim and crash…nobody dies and you don’t destroy an airplane.
I would like to ask you…have you done any time in an ATD? If not, go to your nearest flight center which has one and give it an honest try. I think you will be truely surprised.
I know its off topic but relevant in experience….I’m still baffled how one with some mickey mouse aviation classes makes them a better pilot at 1000 hours than the experience of so one with 1500 and that person make them wait 2 more years, 21 vs 23 yrs old.
May I suggest you look at the Bachelor of Science Degree in Aeronautics requirements for Airline Pilot Specialty or Commercial Pilot Specialty programs at Embry-Riddle University, or North Dakota University aviation programs. You may have to capitalize ‘Mickey Mouse’…and no, I am not a graduate of one of these, but I am a surgeon and all my courses were MICKEY MOUSE! I wish all my flight classroom and flight training was that sophisticated and thorough, but I am not a candidate for ATP. I may end up commercial and/or CFII, just because I always dreamed of it. It’s all about the quality of the programs available…not just air time, but high quality and focused flight triaining. I have had two of my patient clients complete the Embry-Riddle program.
Who paid General Aviation News to put the redbird sims in the forefront of this press?
Maybe this is the reason why some individuals do not like the quality of simulator training.
The FAA should closer evaluate the efficacy of simulators such as theirs.
Good article. Meg. Given the obvious impact on traditional hours-building flight instruction, FAA had to know they would receive at least one letter of opposition to this common-sense rule change. So, they should have taken this ‘direct to NPRM’, and not attempted the ‘Direct to Final’ process. FAA is doing the right thing to withdraw the DTF, just as they said they would. But, their overall handling of this process is predictably maximizing internal workload and public expense, both in terms of time and money.
INCOMING JOHN!!! The one thing that really gets upsets me is the double standard. ATD’s are acceptable for those with an ATP rating to stay current but for those of us with a PPL it is not. And don’t even get me started about the CFI’s. Like the comments below, all they are looking at is that the ATD’s take time away from their logbooks and money from their wallets.
First let me say, i am not looking to build time, I have plenty of it and have been a CFI for 49 years, so don’t anybody say that my motives are selfish. i want to produce the absolute best student that i can. My students do 60 degree bank turns, spins ,upset recovery and get a good look inside of clouds before their PPL ride.
I have no problem with simulators, under the proper circumstances, but those circumstances do not include flight training, either initial or for advanced training. Granted the cockpit is a bad environment to learn in, but the situations that make it a bad environment are the same situations that you must cope with to operate an aircraft safely. If you have not experienced them in training, when they hit you in real life, you are dead.
Sims are great for currency and problem solving. got a problem grasping holding patterns, do it in the sim, Need help with transitions from en-route to approach, do it in the sim, But do the real training in the real thing.
OK, i am ducking under my desk so everyone can throw things at me.
I am a 225 hr pilot, 24 hrs inst training time, and 46 hr sim training time in 30 months. I both fly and sim train almost weekly. I didn’t start sim instrument training until after 175 hrs of flight time and 15 hrs of inst flight training, so my perspective may be a bit slanted. I am a professional near retirement at 68 y/o.
The pre-flight, brief, routine comm, nav, and GPS inputs, along with ATC contact has been so enhanced by my sim time to creat a mental management system and improved scan that flight safety, precision and confidence are very much improved. My flight instructor is ATC to my sim time, so that is now easy!
I see my real scan and situational awareness improving so much because my sim CFII throws enough ‘surprises’ at me, like bird strikes, fuel issues, partial panel, frozen pitot, AP failures, and missed, along with the varied ceiling/RVR.
When my real AP failed twice in IMC flight training it didn’t cause much panic and it has done that several times during VFR. I think it overheats and quits…rentals!!
The sim time (98% IMC) has made the cockpit functions more routine, so that my airplane flight control is enhanced, stabilized approaches routine, my eyes outside the plane are more effective, and I easily and routinely talk/listen to ATC even when VFR outside of busy traffic areas. So, the sim is valuable ‘flight training’ you so flippantly try to discredit! I lose as much sleep over my mistakes in the sim, as I do in the plane.
Yes, I am building commercial sim time as well. My ‘butt’ is more aware of what the plane is doing because the static sim time has made real attitude changes in flight that much more noticeable.
This sounds crazy, I know, but the Bonanza mock-up sim at Modern Pilot is amazing: full panel w/Garmin 430, fuselage structure, and floor to ceiling 180 degree screen. The visual is very good, except I am usually in the clouds!
So all the airline pilots in the world should be grounded? as all the initial training for any modern airliner is done on simulators and then you will do your first real flight on the airplane with passengers…
Many CFIIs have no incentive to get on board with Flight Sims, since they are actively trying to gather flight hours to get their own next job. It doesn’t matter that it may be a better teaching tool for at least some portions of instrument training if it doesn’t plus up the CFIs logbook.
I think it would be helpful if flight schools would find a way to pay CFIs for results, not by the flight hour. I don’t have a complete solution, but some sort of bonus, (like 5 hours of ME time at cost), for successfully coaching each student through their Private or Instrument ticket might be an incentive that would lead some instructors to use the very best tools available. They should also be compensated for ground instruction, simulator time and other critical non-flying activities at rates comparable to, or better than, instruction given in the airplane.
Wow. I’m not sure where to even start with this one. Truly, it’s the same old story in an ever-changing flight training environment.
There’s been a resistance to simulators for years now. Of course there would be in any industry when something threatens the status quo, and the pocket books of big business. Yes, the technology has lacked at times, but that cannot be said today.
The example of “Consequently, pilots do not experience the fear that accompanies real-life emergencies, or the sensory inputs that come with icing and thunderstorm contact. I have seen pilots paralyzed by encounters with severe turbulence or a stalled aircraft. No ATD can begin to simulate these conditions, yet they are the most likely to end in a fatal crash.” is laughable.
So you’re telling me that you take your students into icing and thunderstorms to show them what it’s like? I hope now. But a simulator? Guess what, it can at least START to teach them what that situation would be like- and how to get out of it.
All arguments against simulators (and applying more credit for hours) fall apart very quickly. This is the 21st Century. Costs for actually running an airplane are so high that people don’t want to/can’t get into flying. We either change our thinking and get with the times, or the industry as a whole keeps suffering from a nearly impossible business model.
Let’s hope the FAA, and those that support this change, can step up and put a voice to it.
It’s about time we started thinking of the Gen-X and Millennials, and how they’ll fit into the future of aviation.
Chris Palmer, you greased it on the numbers! Roger that!
A CFII who firmly believes in sending a student up in a “real airplane for real-world IFR” in order to learn about the “sensory inputs which come with icing and thunderstorm contact” is dangerous, irresponsible, and willfully ignorant of the amazing ground-based tools equipping pilots today in the 21st century!
To all of those opposed to simulator-flight, Primary Instrument flight-training is about learning the basics of attitude-flying and building up from a well-developed foundation. It’s not about icing, severe weather, CBs, and whatever life-threatening scenario one can invent.
Also, if CFIs are squawking about simulators because it takes away their time logged in an airplane, that’s messed up. They have a problem and should get out of education and fly 135 or pull a banner.
Instrument-training is about learning to safely, accurately, and confidently fly an airplane solely by reference to instruments. ATC, weather, special conditions, and “real-world” scenarios are integrated with the basics as one grows in skill. No noob is going to launch into 200 & 1/2 at night as ATC chews his or her ears off while managing strong wind and turbulence because it’s the real world of IFR.
What kills an instrument pilot is NOT lack of “real-world” skill, its poor judgment. A 10,000 hr ATP can die just as fast as a low-time PP with a new instrument-rating.
I have over 2,000 hours of SIMULATOR time which includes ATDs and desktop sims. Of course most couldn’t be legally logged, but instrument experience gained in the virtual world has and continues to enhance my mastery of real-world instrument and weather flight of two decades in multiple airplanes.
Soberly reconsider the positive evidence about sim-flight in IFR training. If unable, the opposition already has its mind made up refusing to recognize the true fact sims have helped improve many student’s ability to fly well. One who minimizes a sim to the level of a “procedures-only trainer” is not being wise. These great machines are much more valuable than that.
Know this, I’m not saying we should replace “real-world” IFR flight with a ground-based simulator, but to enhance the quality of instrument training with more legally loggable instrument flight time.