The Society of Aviation and Flight Educators (SAFE) is asking all pilots to comment on the FAA’s new Notice of Proposed Rulemaking (NPRM) that proposes increasing loggable simulator time toward an instrument rating from 10 hours to 20 hours. An earlier effort to implement the change with a FAA direct-to-final rule failed due to adverse comments from two pilots.
The comment period on the Aviation Training Device Credit for Pilot Certification ends July 16. Comments may be submitted online at Regulations.gov to FAA Docket Number FAA-2015-1846 or by mail to the FAA, DOT, 1200 New Jersey Avenue SE, Room W12-140, West Building Ground Floor, Washington DC 20590-0001.
“Because the idea of additional simulator time is so widely supported in the flight instruction community, SAFE and the FAA had expected the direct-to-final rule to sail through and be in effect by now,” said SAFE interim executive director John Dorcey. “Unfortunately, just two pilots out of all those who commented didn’t like the idea, and that’s why we’re urging pilots to comment favorably on this NPRM.”
Direct-to-final rules are commonly used when a change in regulations is not expected to generate any opposition. Under Federal rulemaking regulations, though, even one adverse comment is enough to defeat a direct-to-final rule. The NPRM issued last week is almost identical to the original proposal but is not subject to that limitation.
For years SAFE has pushed for extra simulator time to be loggable. In initial comments, then-executive director Doug Stewart said “these devices can consistently enhance student retention of lesson material, increase student confidence and reduce accident…rates. (Also), we must find a way to contain training costs without sacrificing safety or operational utility.”
I believe that additional sim time can be a valuable tool. Air carriers can train 100% in a sim why not GA pilots?
Emergencies can be trained better in a sim where the crash of an aircraft is not an issue.
the only issue I have towards applying more sim time towards a rating is simply the fact that a sim is just that: a sim. You miss out on plenty of distractions that come with real world flying. Like ATC chatter, aircraft flight characteristics (that induces vertigo, an incredibly valuable lesson that can only be seen in real world flying), tuning in and navigating real world radios and navigation stations, and any other distractions you can think of. It’s amazing how many green FOs I get that really are very weak in this department.
If we increase allowable SIM time, the overall instrument hours must increase as well, in my opinion. This should be allowed to reduce aircraft time. Otherwise, why not just do all flight training in SIMs only??
And logable sim time doesn’t mean you can only fly 10 hours in a sim. Fly your ass off in that thing if you’re weak in this area! Stop trying to meet the minimum standards to get your rating.
A common misconception I think with GA pilots who’ve never received a type rating or flown for an airline. I log all my SIM time.
What is the purpose of having a simulator after all? Isn’t it just for the purpose of learning the essential skills and understanding how the system works normally or in emergency? If yes, why can’t we make the maximum use of it? Flying is 99% a mind game…no matter how knowledgeable or how skillful you are, if you can’t control your mind and thoughts and slip away in the other world rather than the present time, “here- now”…it is a disaster waiting to happen..”human error?”..
But wait a min, they are just talking about the legality of putting some numerical value in a paper…what difference does it make you log 10 or 20 hrs sim time…? And what about after 20? Do we stop learning after doing 20 hrs of sim time? Why can’t we log more than that?
I think we should have a lower limit of having x amount of logging time but should not have higher limit for logging. After all, we already have various methods of testing every airman like theory exams or checkrides…so why make a fuss on some number games? Lets give both equal credit and scrutinize everything in a checkride, may be, we can increase checkride time from 1 day to 6months time…so we can check everything about a person’s skills and knowledge in every little aspects…!
As a pilot for many years, Comm, Mel, Inst, AGI, IGI, and 4x aircraft owner, I fully appreciate the fact that flying is 95% “upstairs” … i.e. in the cerebral cortex! The rest is “monkey skills” and coordination. Consequently, the ability to master complex instrument procedures in the safety and convenience of a good simulator … and in a timely, efficient and cost effective manner is a “no brainer”!
Good simulator training accelerates and shortens the learning curve, increases confidence and, as a result, greatly enhances safety. I’m also OK with increasing loggable sim time to 20 hrs and increasing the overall requirement by an additional 5 hrs or so … in the interest of satisfying any residual bureaucratic skepticism and maintaining harmony with the FAA!