Through a formal Notice of Proposed Rulemaking, the Federal Aviation Administration (FAA) is proposing to amend current flight simulation device qualification requirements, to include establishment of increased regulatory oversight of all operators. The FAA is also proposing a mandatory quality assurance program for continued operational approval of flight simulation devices.
The proposed flight simulation device regulations will significantly increase the complexity and operational costs to all general aviation pilot training schools that use flight simulation devices for pilot training, pilot evaluation, or required flight experience. This will translate into an overall increase in the cost of general aviation flight training and proficiency, with no safety benefit. For years, general aviation pilot schools have used flight simulation devices to enhance flight training and proficiency under the FAA's current rules and advisory circular guidance without incurring any known safety problem. The use of flight simulation devices gives general aviation pilots access to important procedures and proficiency training opportunities in a safe environment that helps enhance safety. It also provides other benefits such as reducing noise, air pollution and air traffic congestion, and conserving petroleum resources. The type of general aviation flight simulation training devices range from the simulation of single-engine and multi-engine piston aircraft to light turboprop and light jet aircraft. The costs associated with the proposed regulations could cause many general aviation pilot schools, which cater to these types of aircraft operators, to discontinue providing necessary simulator based training, thus undermining general aviation's use of simulators as an effective training and proficiency tool. Significant provisions:
The FAA proposes to establish a new Federal Aviation Regulation (FAR) Part 60 — Flight Simulation Device Initial and Continuing Qualification and Use. The FAA also proposes to modify Part 1 — Definitions and Abbreviations, Part 61 — Certification: Pilots, Flight Instructors, and Ground Instructors, Part 141 — Pilot Schools, and Part 142 — Training Center.
The following are the proposed regulations' significant provisions:
AOPA believes that the proposed rule change is unnecessary because there is not a safety problem with the use of flight simulation devices. AOPA also believes that the proposed rules are cost prohibitive for general aviation pilot schools. The FAA estimates that the overall costs associated with these proposed rules will be $1.9 million over a 10-year period, with over $1.3 million being incurred by the pilot schools and training centers. AOPA believes that the cost estimate is understated as well as the cost impact, in that the FAA does not adequately identify all of the operators that will be affected with the inclusion of general aviation pilot schools. In addition, these costs do not have any specific offsetting safety benefits. AOPA expects that these costs will most likely cause some general aviation pilot schools to either eliminate the use of flight training devices or pass on the additional costs of complying with the proposed rules to its flight training customers, and will only serve to the detriment of general aviation safety.
AOPA thanks our members for their continued support in protecting the freedom to fly.