In formal comments filed with the FAA July 15, AOPA asked the agency to expedite publication of a final rule that would once again allow pilots to count more hours in an approved aviation training device (ATD) toward an instrument rating.
For many years, the FAA had issued letters of authorization that allowed pilots to count up to 20 hours of ATD time toward the requirements for earning an instrument rating. But in January 2014, the FAA published a policy change that cut that number in half. The agency received more than 200 comments opposing the policy change, and AOPA and others asked the agency to undergo an expedited rulemaking process to restore the higher standard.
In December 2014, the FAA published a direct-to-final rule to restore the 20-hour allowance, but two adverse comments forced the agency to withdraw the direct-to-final rule and go through a standard rulemaking process.
In its most recent comments, AOPA noted that restoring the higher ATD limit would improve safety, reduce training costs, and encourage the use of new technologies and training techniques.
“Regardless of how training is conducted, each airman must be evaluated during the practical exam to ensure he or she possesses the knowledge, skills and risk management needed to hold the desired certificate or rating,” wrote David Oord, AOPA vice president of regulatory affairs. “The new integrated, holistic Airman Certification Standards (ACS) will ensure future pilots possess those aspects and make them safe, competent aviators. This rule change will afford the training industry the flexibility to teach pilots using new and innovative techniques. Only through that innovation will we collectively rise to the next level of safety.”