Please don't fix what isn't broken. That's the message from AOPA and a group of general aviation simulator manufacturers and flight training experts to the FAA. The agency wants to write new regulations - a new Part 60 - to govern all types of flight simulation devices, from the flight training devices (FTDs) found in small general aviation flight schools to the full-motion simulators used by the large airline training academies.
"What the FAA wants to do, in essence, is 'type certificate' a flight training device, then make the users adopt quality management systems and recordkeeping requirements equal to what the FAA requires for airline simulators," said Luis Gutierrez, AOPA director of Regulation and Certification Policy. "In fact, they want more for an FTD bolted to the floor than a training aircraft out on the flight line."
The rule would cover all flight training devices, which are full-scale replicas of airplanes' instruments and controls in a cockpit-like environment. Level 1 through 3 FTDs are usually generic and don't represent a specific aircraft model. They don't have a motion base, like a true simulator, but have "real" aircraft controls and "real" instruments. (Personal computer aviation training devices - PCATDs - usually use a computer screen to recreate the aircraft instruments.)
"Here's the irony," said Gutierrez. "The FAA has just come out with its light-sport aircraft rule saying it doesn't need to regulate simple, small aircraft, but it does need to regulate a flight training device that can only be used for partial credit toward a certificate."
In a letter to Nicholas Sabatini, the FAA's associate administrator for regulation and certification, the flight training group said, "We strongly oppose any regulatory attempt to codify Level 1-3 FTDs, PC-ATDs, Basic ATDs, and Advanced ATDs.... Safety is in no way being compromised by the use of these devices, and in fact, a compelling argument can be made that by regulating these devices safety could be undermined."
That's because flight schools long ago discovered that these training devices are in many ways better than the actual aircraft for teaching certain things, particularly instrument flight. But if the FAA gets its way, the flight training devices could become prohibitively expensive to buy and operate and, therefore, unavailable to most students.
The group pointed out, "Unlike the airline simulators where pilots receive initial and recurrent training without ever touching the controls of an airplane, with the lower level FTDs pilots are limited to the amount of logable time and are subject to progress checks and ultimately a practical test in an aircraft to ensure their competency."
But the airline experience may be the problem. The part of the FAA wanting the change is the National Simulator Program, which regulates the big airline simulators. For that reason, the group said the approval and oversight of basic flight training devices should be assigned to the Certification and Flight Training Branch (AFS-840), "because of AFS-840's experience with simulation devices used in general aviation training.... It is imperative in the development of these standards that the FAA only seek the advice and input from manufacturers and sponsors of flight simulation devices that are knowledgeable in and understand the use of these devices in general aviation flight training."
July 28, 2004