On Wednesday, December 3, 2014, the FAA issued a direct to final rule that will increase the allowed use of aviation training devices (ATDs) for instrument training. The rule will double the allowances under 14 CFR section 61.65(i) to 20 hours for credit in an ATD and allows flight schools operating under part 141 Appendix C to have a 40 percent training credit in an ATD for the instrument (IFR) rating. Previous allowances for ATD use were capped at 10 hours under part 61 and 10 percent under 141. The rule also removes the requirement to use a view-limiting device in the ATD. The comment period for the direct final rule will close Friday, January 2, 2015. The rule will become effective Tuesday, January 20, 2015, if no adverse comments are received.
In concert with this rule change is an update to Advisory Circular 61–136A, FAA Approval of Aviation Training Devices and Their Use for Training and Experience, which has been revised to improve guidance for the application and approval of these training devices. The AC also provides additional guidance on ATD use for training and how to properly log the time.
Finally, it looks like the FAA is coming around to agreeing with what we CFIIs have known for years. The airborne cockpit environment is a horrible classroom in which to teach. It’s noisy, full of distractions, occasionally unpredictable and, if the airplane is not tied down with the engine shut off, it is constantly moving through space-time. Frankly, any sane human being is scared of it, at first, though few would admit to it.
Ground school evolved from these realizations. Most flight instructors will acknowledge the learning benefits of imparting knowledge in quiet, well-lit, calming environments. On the ground, in an ATD, CFIs can control how any flight lesson is going to play out.
Why? Because they hold most of the cards; no sudden ATC amendments to lesson plans, no unexpected flashing alternator-out lights, no tilted, giving up the ghost gyros mid-lesson and no unanticipated airspace restrictions or weather anomalies. That is, unless the CFII programs any of those anomalies into the ATD. Total control. Every teacher I know, no matter what discipline or age group, will tell you that really does feel good.
Students may not know it (they are often aching so badly for flight time that the thought of being in an ATD turns their stomachs) but flight simulation by computer is truly an extension of all the good things that ground school imparts to students. Doubling up on the ATD time, especially for IFR students, can easily shorten training time, sometimes cutting it in half, because it is easy for the instructor to program the ATD to quickly set up for repetition. Want to fly seven ILS approaches in an hour? No problem? Need to practice four different holding pattern entries? We can slew you instantly to any location, altitude, attitude—and you can take it from there. Over, and over, until you fly it right.
Cutting training time, however, is just one benefit of the ATD. The other is its cost. Most FBO-owned ATDs cost less to operate than an aircraft. That cost savings is passed to the student, who can save from one third to one half what it would cost to perform the same lesson in an aircraft.
Yes, this time the FAA knows what it is doing and has the stats to back up the decision. So make sure you get on the Federal Register site and let the FAA know we like the new ATD regulation. Do it before January 2!