[Avionics Today 01-26-2015] The FAA has withdrawn a final rule that would have established a new regulation allowing pilots to log more hours using approved Aviation Training Devices (ATDs) toward obtaining an Instrument Flight Rules (IFR) rating. According to a statement regarding the rule withdrawal, the agency received "adverse comments" about the final rule and, by a matter of protocol on the rulemaking process, was forced to withdraw the final rule.
"The Jay" is a desktop-based Aviation Training Device (ATD) from Redbird Flight Simulations. Photo: Redbird.
Pilot trainees are required to log 40 hours of flying in order to obtain an IFR rating, which allows them to legally fly in clouds and adverse weather conditions solely by reference to the instruments in the aircraft. Under the FAA's newly proposed rule, which was withdrawn on Jan. 15, instrument pilot trainees would have been able to log 20 hours of instrument time using an approved ATD under Part 61 — or no more than 40 percent of total training hour requirements for an instrument rating under Part 141.
The push toward the new rule regulating the use of ATDs to obtain an IFR type rating began in early 2014, Aircraft Owners and Pilots Association Director of Regulatory Affairs David Oord told Avionics Magazine. In January 2014, the FAA issued a new policy statement on ATDs, indicating that pilots are only authorized to use certain advanced ATDs for 10 hours of credit, and were required to log the remaining 30 hours in an aircraft doing real-world IFR flight training.
Prior to that, the FAA had been issuing Letters of Authorization (LOAs) to flight training schools and instructors approving the use of the more advanced ATDs, such as the desktop ATDs produced by Redbird, which are much more advanced and provide better training than previous generations of the devices. However in January of last year, the agency issued a new policy statement effectively rescinding those LOAs so that every pilot trainee would be held to the same requirements under its official regulation for ATDs, which only allows 10 hours.
"What happened in January 2014, the FAA said we cannot have LOAs that conflict the regulation therefore we need to rescind all of these LOAs and reissue them to match the current regulation which allowed 10 hours," said Oord. "When we saw that, we issued a letter to the FAA expressing our disappointment because this is going to have real cost ramifications on flight students. An hour in a plane is a lot more expensive than an hour in a training device. We feel strongly that the evidence and the data shows that ATDs are useful. This is advantageous for people to learn how to fly instruments. This is an instrument rating, this is learning how to fly an instrument procedure, how to interpret the instruments, how to really focus on the instrument and fly the procedures and get into scenarios that are not as safe to do in the airplane."
Newer ATDs, such as "The Jay" by Redbird allow pilots to select pre-set scenarios, such as flying in the clouds or adverse weather conditions and trains them on how to fly in these conditions only using the aircraft instruments. Realizing the proficiency of these more advanced ATDs, the FAA proposed its new rule allowing pilots to use them for up to 20 hours toward obtaining an IFR credit.
However the rule was withdrawn after the agency received two negative comments out of 20 comments. One of the commenters, a licensed Air Transport Pilot, James Wolfe, expressed his belief that the ATDs increase a pilot's reliance upon automation enabled by modern cockpit avionics.
"Instead of increasing a pilot's skill, however, they have come between real-world flying and desktop flying. They have increased reliance on screens and autopilots and diminished the pilots sense of being in charge of the aircraft and the flight,” said Wolfe. "Stalls, thunderstorms, and icing are the greatest dangers, yet ATD's cannot depict these accurately or realistically.”
Several flight training organizations, including the Society of Aviation and Flight Educators (SAFE) as well as WNC Aviation, expressed support for the new rule. SAFE, in particular, issued a direct response to Wolfe's comments.
"Mr. Wolfe expresses concern that sensory inputs are difficult to mimic in many ATDs and points out that this is contrary to the principles noted in the FOI. We sympathize with the first part of his statement although we note that microprocessor developments over the past several years have resulted in a new generation of increasingly affordable mid and upper level devices, such as those currently marketed by Red Bird, which replicate sensory inputs with an incredible degree of accuracy and which are becoming commonplace in the training market," the organization said in its response.
AOPA's Oord agrees with SAFE's position, and also told Avionics Magazine that research about the use of newer ATDs indicates that they do provide an adequate method of preparing pilots to fly instrument flight rules.
"Over the last two decades, we’ve seen an explosive growth in cockpit technology when it comes to [General Aviation] GA aircraft," said Oord. "In order to get your instrument rating you have to have 40 hours, 20 of which we think is more than adequate to learn in the training device because you’re learning how to load a procedure into your avionics, interpret your avionics and then you will take that knowledge and skill that you’ve gained in the training device and equate it to an airplane when you do your on airplane training."