Month: September 2013

Draft AC 61-136A: FAA Approval of Aviation Training Devices and Their Use for Training and Certification

FAA has released the draft of an update to the advisory circular that sets FAA standards for Aviation Training Devices (ATD) and how the agency approves their use in pilot training programs.

FAA updated AC 61-136 in September 2018. You can read about those changes at New AC for ATDs.

On June 27, 2018, the FAA published several key changes to 14 CFR Part 61 that govern the use of ATD to maintain IFR currency. You read about that changes at BruceAir here.

The draft AC 61-136A will supplant AC 61-136 when it is adopted.

I’ve looked over the proposed changes, and I discuss the key changes below.

You can learn more about ATDs, which include Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD), in my latest book about PC-based flight simulations, Scenario-Based Training with X-Plane and Microsoft Flight Simulator.

ATDs are not Simulators

It’s important to understand that Aviation Training Devices are not simulators. As you can see from the definitions below, ATDs are devices that include:

…hardware and software necessary to represent a category and class of aircraft (or set of aircraft) operations in ground and flight conditions…

ATDs are intended to:

Provide an adequate training platform for both procedural and operational performance tasks specific to … ground and flight training requirements

But they are not required to be substitutes for specific aircraft. In other words, they are training aids intended to help pilots learn, practice, and master aviation-related tasks and procedures.

No Regulation Changes

It’s also important to note that the proposed AC won’t change any FAA regulations that govern the use of ATDs and how much simulator time you can credit toward the minimums required for pilot certificates and ratings:

This AC does not change regulatory requirements; therefore, the provisions of the current regulation always control. This AC applies only to the evaluation and use of BATDs and AATDs. This notice does not apply to Full Flight Simulators (FFS) and Flight Training Devices (FTD) that are regulated under 14 CFR part 60.

Specifically, the AC does not change the amount of simulator time that may be credited toward the requirements for certificates and ratings as specified in:

a. 14 CFR part 61, §§ 61.4, 61.51, 61.57, 61.65, 61.109, 61.129, and 61.159.

b. 14 CFR part 141, §§ 141.41, 141.55, 141.57, and appendices B, C, D, E, F, G, I, K and M.

Logging Training Time and Experience

However, the updated AC does include language that clarifies how pilots and instructors should document the time they spend using ATDs:

Authorized instructors utilizing an FAA approved ATD for airmen certification, pilot time, and experience requirements are required to log the time in a pilot logbook as dual instruction and as BATD or 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 the 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. Logging time in this fashion will allow a pilot to credit this time towards the aeronautical experience and recent experience requirements as specified in part 61 or 141. It is recommended that a notation be included in the remarks section of the pilot logbook indicating the device name and manufacturer as described in the LOA. It is the responsibility of the flight instructor, student, or certificated pilot to verify the device is qualified and approved for certification or experience requirements. It would be appropriate for the person using the ATD to retain a copy of the LOA.

NOTE: There are no restrictions on the amount of training accomplished and logged in training devices. However, the regulatory limitations on maximum credit allowed for the minimum pilot certification requirements are specified by 14 CFR part 61 and part 141 and in the LOA. No approvals or authorizations are provided for aircraft type ratings using aviation training devices.

New Five-Year Re-Authorization Requirement

Paragraph 8 (b) of the proposed AC requires that all approved training devices will require re-authorization on a five year schedule:

All FAA approved training devices that are not evaluated or approved by the National Simulator Program in Atlanta, GA (AFS-205 under 14 CFR part 60), come under the evaluation, approval and control of the General Aviation and Commercial Division (AFS-800). AFS-800 has determined that all devices will require re-authorization on a five year schedule. This evaluation ensures current standards required by this advisory circular continue to be met. After June 1, 2015, all approvals for ground trainers, simulators (except Level A, B, C, and D), Level 1-3 FTD’s, PCATD’s and ATDs with authorizations that were either not issued by AFS-800 or do not contain an expiration date will terminate. The manufacturer must request this re-evaluation no later than 180 days prior to June 1, 2015.

Definitions of ATD and BATD Remain Essentially the Same

The new AC does not appear to change the basic definitions of ATD, BATD, or AATD. But there are some subtle distinctions in some of the descriptions.

Aviation Training Device (ATD)

As in the current AC 61-136, an ATD (the general term for either a BATD or AATD) is defined as:

A replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit. It includes the hardware and software necessary to represent a category and class of aircraft (or set of aircraft) operations in ground and flight conditions having the full range of capabilities of the systems installed in the device as described within this AC for the specific basic or advanced qualification level.

Basic Aviation Training Device (BATD)

The current AC 61-136 defines a BATD as a device that:

(2) Provides a training platform for at least the procedural aspects of flight relating to an integrated ground and flight instrument training curriculum

The proposed update adds some specificity to those criteria:

(2) Provides an adequate training platform and design for both procedural and operational performance tasks specific to the ground and flight training requirements for Private Pilot Certificate and Instrument Rating per Title 14 of the Code of Federal Regulations 14 CFR parts 61 and 141;

(3) Provides an adequate platform for both procedural and operational performance tasks required for instrument experience and pilot time

AATD

The same basic changes also apply to Advanced Aviation Training Devices (AATD), although an AATD can also be used for training toward the ATP and CFI certificates. An AATD is a device that:

(1) Meets or exceeds the criteria outlined in Appendix 2 (BATD Requirements);

(2) Meets or exceeds the criteria outlined in Appendix 3 (AATD Requirements);

(3) Provides an adequate training platform for both procedural and operational performance tasks specific to the ground and flight training requirements for Private Pilot Certificate, Instrument Rating, Commercial Pilot, and Airline Transport Pilot Certificate, and Flight Instructor Certificate, per Title 14 of the Code of Federal Regulations (CFR) parts 61 and 141;

(4) Provides an adequate platform and design for both procedural and operational performance tasks required for instrument experience, the instrument proficiency check and pilot time

The details of how an AATD may be used in such training will be specified in the LOA for that device:

AUTHORIZED USE. Except for specific aircraft type training and testing, an AATD may be approved and authorized for use in accomplishing certain required tasks, maneuvers, or procedures as applicable under 14 CFR parts 61 and 141. The FAA will specify the allowable credit in the AATD LOA for Private Pilot, Instrument Rating, instrument recency of experience, Instrument Proficiency Check, Commercial Pilot, and Airline Transport Pilot.

More Detailed Qualification Criteria

Manufacturers of ATDs will need to review the proposed AC carefully. It includes more detailed standards that ATDs must meet for FAA approval, and it specifies how manufacturers must inform the FAA when they update or make substantial changes to their devices.

The proposed AC also addresses compatibility of the software and hardware used in ATDs:

a. An approved ATD consists primarily of two components: software (programming) and hardware (central processor, monitor or display, appropriate flight and power controls, and avionics). The software and hardware components must be compatible because the hardware sends “values” from sensors to the software by means of voltage and digital inputs (e.g., avionics frequencies, switches, and buttons). Hardware and software compatibility are assured when the hardware manufacturer and the software developer work in close cooperation to develop the correct union of inputs for the ATD.

b. In some cases, the hardware manufacturer and the software developer do not work together in developing the ATD. Instead, the software is “licensed for use” to the ATD manufacturer and incorporated into the device. In those cases, the manufacturer must attest in writing (in the QAG) that all hardware technical requirements (analog and digital input values) are compatible with the software used in the ATD. To do so, the manufacturer should obtain a “compatibility statement” from the software developer, which may, at the FAA’s discretion, be used to satisfy this requirement. The following is an example compatibility statement:

“This is to certify that <Name of Software Company or Developer> has demonstrated that the operating system software <Software part number and version/revision>, is compatible with <Name of ATD Manufacturer, Make and Model> and can assure that the communications/transport data latency is not greater than 200 milliseconds and all analog and digital input signals meet the performance criteria established for software performance by the ATD manufacturer.”

c. Only the owner or co-developer can validate certification of the transport delay time stated in Appendix 2 and the correct analog and digital inputs necessary to ensure that the software performs adequately. Similarly, the software developer must determine the minimum computer requirements to effectively run the software.

Approval of ATD for use Under Part 61

According to the AC, to be approved for use for pilot training and certification under part 61, an ATD should:

a. Be capable of providing procedural training in all areas of operation for which it is to be used. Those tasks should be specified in an acceptable training curriculum or as specifically authorized by the FAA and meet the description and suggested criteria outlined in Appendix 4.

Approval of ATD for use Under Part 141

As you might expect, the process for approval for use under Part 141 includes an endorsement from a flight school’s principal operations inspector:

The jurisdictional FSDO may approve an ATD as part of an overall part 141 school curriculum approval and certification process. Pilot schools that want to use an ATD as part of their training curriculum must notify their principal operations inspector (POI). The POI is responsible for approving how the ATD is to be used in the certificate holder’s part 141 curriculum and Training Course Outline (TCO).

Flight Dynamics (Flight Modeling)

As under the present guidance, there is no requirement for an ATD to have control loading to exactly replicate any particular aircraft. An air data-handling package is not required for determination of forces to simulate during the manufacturing process. Such detailed and accurate representations of specific aircraft are required only for Flight Training Devices and Full Flight Simulators.

The new AC, does, however, require manufacturers to include a performance table for each aircraft configuration represented in an ATD:

 (1) Flight dynamics of the ATD should be comparable to the way the represented training aircraft performs and handles. However, there is no requirement for an ATD to have control loading to exactly replicate any particular aircraft. An air data-handling package is not required for determination of forces to simulate during the manufacturing process.

(2) Aircraft performance parameters (such as maximum speed, cruise speed, stall speed, maximum climb rate, and hovering/sideward/forward/rearward flight) should be comparable to the aircraft or family of aircraft being represented. A performance table will need to be included in the QAG for each aircraft configuration for sea level and 5,000 ft.

The sample table in the proposed AC is basic; it includes only ranges for cruise and stall speeds and related information. As noted above, it is not a detailed description of the flight characteristics of a specific aircraft.

Late September Aerobatic Ride

We had a lovely September afternoon to fly. My passenger had given her son a ride as birthday present earlier in the summer, and after seeing how much fun he had, she wanted to go for a flight herself. As you can hear, she enjoyed the experience, and the scenery was spectacular in the late-summer (almost fall) afternoon light.

I added Aresti diagrams for some of the maneuvers.

Videos: Integrated Instrument Panel in Action

I took advantage of clear skies to log several night landings in the Bonanza (an A36). The first step was a quick flight from Boeing Field (KBFI) to Bremerton (KPWT) to get dinner at the airport diner and wait for sunset at the non-towered airport. I flew the ILS RWY 20 @ KPWT under VFR to verify a fix to the glideslope reception of the new avionics.

I used two GoPro cameras, one focused outside, the other pointed obliquely at the instrument panel.

After dinner, I logged landings at KPWT, and then I returned IFR to Boeing Field to practice with all the new toys and get another night landing.

I used two GoPro cameras, one pointed outside, the other at the instrument panel. The inside camera got knocked off-kilter for the last video; The Cabinet of Dr. Caligari effect was unintentional.

For more information about the video equipment that I use, see Aviation Video Tips.

Aviation Video Tips

I often get questions about the equipment and editing tools that I use to make the in-cockpit videos on my YouTube channel, BruceAirFlying.

Here are some answers.

Cameras

I typically use three cameras for the aerobatic videos:

  • GoPro Hero3 Black Edition; price recently reduced to $329
  • GoPro Hero2 (apparently discontinued, but still available from many sources)
  • Contour (my first action camera; the company recently restarted under new ownership).

Garmin recently introduced a line of action cameras, the VIRB. I haven’t tried one yet.

Audio

To record cockpit audio, both the intercom and air traffic control communications, I connect the GoPro Hero3 with this patch cord available from Aircraft Spruce, Amazon, and other sources. Pilot USA makes similar cords for several models of the GoPro. You can also find patch cords and adapters at The Squawk Shoppe. Nflightcam also makes a range of mounts and accessories for GoPro cameras, including audio cables and filters.

The other two cameras record ambient engine and cockpit sounds.

Camera Mounts

I use several camera mounts. To record the pilot’s-eye view from the rear seat of the Extra 300L, I wear the GoPro Hero3 using the company’s head strap mount. I install the camera in the skeleton housing accessory (it has slots and isn’t waterproof) so that I can easily connect the audio cable.

I also mount a camera pointed at the left wing. It’s attached to the top of the rear-cockpit instrument panel with a standard GoPro sticky-mount and adapters.

The front “hero” camera in my videos is the ContourHD. I use RAM mounts to hold it securely in place on one of the cockpit braces.

If you fly a typical light aircraft and want to capture in-cockpit video, try the Fat Gecko Co-Pilot.

I have also been experimenting with the GoPro Jaws: Flex Mount. For more information, see Another Go-Pro Camera Mounting Option here at my blog.

I used a Fat Gecko to capture this video of a flight in the Bonanza.

Exterior Mounts

Many pilots are posting videos shot with cameras mounted outside the airplane. Much debate ensues when pilots discuss what’s legal (and wise), and that subject is too complicated to go into here. A good summary of the issues is “Pilot’s-Eye View,” an article in the February 2013 issue of EAA Sport Aviation Magazine. Suffice it to say that sticking a camera on or near a control surface, such as a rudder (as in this video), is a bad idea.

You can find more information about mounting cameras externally in “Lights Camera, Action!” in the January/February 2014 issue of FAA Safety Briefing. I also posted details about that article here.

FAA also published a memorandum on March 13, 2014 to clarify its stance on externally mounted cameras. Here’s a PDF version of that FAA-camera-memo.

Lens Filters

Digital cameras use a rolling shutter that scans images onto the sensor (a CCD). The rolling shutter causes scimitar-like distortion of the propeller and other effects that can mar aviation videos.

You can dramatically reduce the propeller distortions by attaching a neutral-density filter to your camera. I use the Slim Frame Neutral Density Glass Filter made by Polar Pro.

It snaps onto either the waterproof or skeleton housing for the GoPro Hero3. Polar Pro makes a range of filters for different GoPro models. They’re available direct from the company and from sources like Amazon.

Nflight Technology also makes filters for the GoPro series, including the GoPro Hero3 Propeller Filter and the GoPro 55mm Variable ND with Adapter.

Editing

If you use only one camera, you can edit videos with basic, free tools such as Windows Movie Maker or iMovie—even GoPro Studio. These tools support cutting and merging scenes, fading video in and out, adding transitions, and other basic effects.

To work with video shot with more than one camera—which adds visual interest—you need a tool that can handle multiple tracks. I use Adobe Premier Elements, but you can choose from among many applications.

Synchronizing tracks can be tricky, but you can use simple techniques to “slate” the cameras and provide reference points. For example, hold your hand in view of all the cameras and count down three fingers. Or use a key point such as closing the cockpit door or canopy as a reference. You can edit that extraneous video after you line up the tracks.

For more information about the basics of video editing, see these sources:

General Tips

Audio Volume: I recommend using your camera’s settings to reduce the recording volume. I set the GoPro input volume to 70%, even for the camera that records cockpit audio. When I edit the video, I adjust the gain (volume) of the tracks that contain ambient sound. I typically reduce those audio tracks by 12 to 22 dB. That level still provides background engine sounds, but it keeps the engine and airstream noise from overwhelming conversation and other sounds.

Trimming Video: The last, and most important, of the late Elmore Leonard’s 10 Rules of Writing is, “Try to leave out the part that readers tend to skip.” The same advice applies to video. Now, when I make video for my students and aerobatic-ride customers, I generally include enough video to tell a story that they can share. And I often include geeky details such as the ATIS broadcast, to add an aviation ambiance. How much of the preflight, engine start, taxi, and general cruising around you include is, of course, up to you. But for sightseeing, “look-at-my-airplane flying along” videos, long tracking shots are best left to professionals.

Point of View: Even if you have only one camera, consider moving it during a flight or making several flights with the camera in different positions. Then edit the scenes into a story that’s far more compelling than a video recorded from just one perspective.

Music

Finally, please don’t make another aviation video dubbed with “Sail”! It’s become as trite as “Danger Zone.”

Many video editing tools include automated music tracks that you can add to your videos. Of course, if you want to press your luck with copyright, you can include favorite songs, but picking the right soundtrack is an art. Choose wisely.

Late August Aerobatic Ride

Proof that women often tolerate aerobatics better than men. The thrill-seeker in this video received an aerobatic ride as a birthday gift from her husband. Unlike many people, she most enjoyed the sensation of G as we flew through loops and related maneuvers on a lovely late-summer day.

Many people are anxious about aerobatics, but most folks enjoy the experience, provided they’re eased into the maneuvers. I wrote about my approach to giving aerobatic rides in the April 2013 issue of Sport Aerobatics. You can read “Your Toughest Judges” here (PDF).

More videos on my YouTube channel, BruceAirFlying.