FAA has published new regulations and guidance for pilots and instructors who use aviation training devices (ATD).
Updated AC 61-136A
First, FAA published AC 61-136A: FAA Approval of Aviation Training Devices and Their Use for Training and Experience on November 17, 2014. This updated document provides information and guidance for manufacturers of ATD and for instructors and pilots who intend to use a BATD or AATD for activities involving pilot training or certification under 14 CFR Part 61 and 141.
The updated AC also explains the requirements for obtaining a letter of authorization from the FAA for all ATDs. That LOA must be renewed every five years.
Changes to 14 CFR Part 61 and Part 141
On December 3, 2014, FAA published changes to 14 CFR Part 61 and Part 141. (You can read the full announcement of the changes in the Federal Register here.) The changes are effective January 20, 2015.
The new language in § 61.65 revises paragraph (i) and adds paragraph (j) to read:
(i) Use of an aviation training device. A maximum of 20 hours of instrument time received in an aviation training device may be credited for the instrument time requirements of this section if—
(1) The device is approved and authorized by the FAA;
(2) An authorized instructor provides the instrument time in the device; and
(3) The FAA approved the instrument training and instrument tasks performed in the device.
(j) A person may not credit more than 20 total hours of instrument time in a flight simulator, flight training device, aviation training device, or combination toward the instrument time requirements of this section.
Part 141.41 is updated to read:
An applicant for a pilot school certificate or a provisional pilot school certificate must show that its flight simulators, flight training devices, aviation training devices, training aids, and equipment meet the following requirements:
(a) Flight simulators and flight training devices. Each flight simulator and flight training device used to obtain flight training credit in an approved pilot training course curriculum must be:
(1) Qualified under part 60 of the chapter; and
(2) Approved by the Administrator for the tasks and maneuvers.
(b) Aviation training devices. Each aviation training device used to obtain flight training credit in an approved pilot training course curriculum must be evaluated, qualified, and approved by the Administrator.
(c) Training aids and equipment. Each training aid, including any audiovisual aid, projector, tape recorder, mockup, chart, or aircraft component listed in the approved training course outline, must be accurate and appropriate to the course for which it is used.
And Appendix C of Part 141,section 4, paragraph (b) is updated to read:
4. Flight training.* * *
(b) For the use of flight simulators, flight training devices, or aviation training devices—
(1) The course may include training in a flight simulator, flight training device, or aviation training device provided it is representative of the aircraft for which the course is approved, meets the requirements of this paragraph, and the training is given by an authorized instructor.
(2) Credit for training in a flight simulator that meets the requirements of § 141.41(a) cannot exceed 50 percent of the total flight training hour requirements of the course or of this section, whichever is less.
(3) Credit for training in a flight training device that meets the requirements of § 141.41(a), an aviation training device that meets the requirements of § 141.41(b), or a combination of these devices cannot exceed 40 percent of the total flight training hour requirements of the course or of this section, whichever is less.
(4) Credit for training in flight simulators, flight training devices, and aviation training devices if used in combination, cannot exceed 50 percent of the total flight training hour requirements of the course or of this section, whichever is less. However, credit for training in a flight training device or aviation training device cannot exceed the limitation provided for in paragraph (b)(3) of this section.
Ground Instructors, ATDs, and Flight Simulators
Some ground instructors have asked about their ability to provide instruction to pilots using ATDs and flight simulators. The FAA has published two letters of legal interpretation to clarify this matter.
The Gatlin letter, issued on September 24, 2010, discusses whether an Advanced Ground Instructor or Instrument Ground Instructor is an “Authorized Instructor,” as defined in 14 CFR 61 for purposes of giving instrument instruction to candidates for pilot certificates and ratings.
The letter explains that ground instructors are authorized to provide only ground training and are not specifically allowed to supervise training time in a flight simulator or training device for purposes of logging time toward an instrument rating or pilot certificate.
The Frick letter, issued on March 30, 2011, backs up that interpretation. It explains that a ground instructor may use training devices as tools, or aids to instruction, but the time cannot be counted towards meeting the aeronautical requirements for a pilot certificate or rating.
In addition, the Frick letter notes that ground instructors may provide instruction in a training device or simulator that helps a pilot meet proficiency requirements. Again, a ground instructor use the devices as tools during training, but that time may not be logged, endorsed, or credited towards recency experience for maintaining a rating.