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Simulation semantics

Many of you—and likely many of your children—have spent hours flying everything from a Piper Cub to a Boeing 747 on Microsoft Flight Simulator. Even though home-based simulators offer realistic imagery and sound effects, they are not FAA-approved for pilot training. As a flight training professional, you should become familiar with the various types of FAA-approved simulation equipment, and how recent regulatory changes might affect your use of these devices.

The FAA divides its simulation trainer approvals into three specific categories: full flight simulators (FFS), flight training devices (FTD), and aviation training devices (ATD). Advisory Circular 61-136A, FAA Approval of Aviation Training Devices and Their Use for Training and Experience, provides the criteria for ATD approvals and use, and then divides them into basic or advanced ATD approvals. Flight instructors who teach and fly in general aviation aircraft will likely use some form of ATD. According to AC 61-136A, an ATD is a training device, other than a FFS or FTD, that “includes a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit.”

AC 61-136A also provides guidance on how instruction using an ATD should be logged: “Authorized instructors utilizing an FAA-approved ATD for airmen training, pilot time, and experience requirements are required to log the time as dual instruction and as basic aviation training device (BATD) or advanced aviation training device (AATD) time appropriately. Any columns that reference flight time should remain blank when logging ATD time. Simulated instrument time can be logged in an ATD, but only during that time when the visual component of the training session is configured for instrument meteorological conditions (IMC) and the pilot is maintaining control solely by reference to the flight instruments.”

Be careful when logging ATD time, as many pilot logbooks include a column labeled “simulator or FTD.” You may also see a column labeled “ground trainer.” Our local FAA designated pilot examiner suggested that we create a separate column labeled “ATD” to avoid confusion. The current 8710-1 Airman Certificate and/or Rating Application allows you to enter FSS, FTD, or ATD time.

In practice, the key difference between an AATD and a BATD is that while either may be used to log up to 10 hours of simulated instrument time toward an instrument rating under FAR 61.65(i), an AATD may, according to AC 61-136A, also be used to provide some training toward a commercial, ATP, or flight instructor certificate under parts 61 and 141. Examples of BATDs include the Redbird TD and TD2 and the Elite PI-135, all of which can be purchased for less than $10,000. You’ll spend twice that or more for an AATD such as the Redbird FMX or the Elite PI-1000.

Any variant of ATD may be used on its own or with an airplane to meet the recent flight experience requirements for IFR flight under FAR 61.57(c)(3) or (4). Read the regulations carefully, though, because the “six in six” requirement changes when using an ATD.

Our flight school owns and operates an Elite PI-135 BATD. While our primary use of the device is for instrument training, it’s also a very effective, efficient, and inexpensive tool for teaching student pilots how to navigate using VOR and GPS. But you won’t find any reference to using an ATD in FAR 61.109, which describes the aeronautical experience required to earn a private pilot certificate.

For this, you have to look in the letter of authorization (LOA) provided by FAA for the make and model of ATD that you are using. Our current LOA from Elite states that the PI-135 can be used for up to 2.5 hours toward the aeronautical experience of FAR 61.109(k)(1), but with a note that “training or experience requirements such as cross country, night, solo, takeoffs and landings, or the 3 hours of training within 2 calendar months of the practical test must be accomplished in an aircraft. Private Pilot Airplane applicants must also complete the requirement for 3 hours of control and maneuvering of an airplane solely by reference to instruments specified in 61.109 in an airplane.”

On Jan. 15, the FAA announced that it was withdrawing a direct final rule published Dec. 3, 2014, that would have increased the maximum time that may be credited in an ATD toward the instrument time requirements for an instrument rating under FAR 61.65(i) to 20 hours. It also would have revised 61.65(i)(4) to eliminate the requirement that pilots logging instrument time in an ATD wear a view-limiting device.

Why the change? The FAA received two adverse comments to the rule, and by law the agency was obligated to withdraw it. According to FAA, “one commenter raised concerns regarding the effectiveness of ATDs for training, suggesting that these devices do not provide appropriate sensory cues or provide a realistic environment. Another commenter believed that the increases in time/percentage of training contained in the direct final rule were too great.”

I don’t know which ATDs the commenters had concerns about, but based on my experience with our BATD, my response is that it doesn’t fly like a real airplane because it’s not designed to fly like a real airplane. What it does best is allow students to learn to scan the instruments properly, avoid fixation, and maintain control while doing other tasks such as programming a GPS, tuning a VOR, looking at a chart, or briefing an approach plate. You don’t need a full-motion simulator to learn these skills, and you certainly don’t need to be wearing a view-limiting device while sitting at a desk in front of a computer in a flight school office, where there is no horizon to reference anyway. I hope that in a future amendment to the rule, the FAA removes this requirement as it did previously. I think 10 hours is an appropriate amount of training time to be allowed in a BATD, and I hope that the FAA will continue to support us and the rest of the flight instruction community in our efforts to best serve our customers.

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