New Simulation and Training Rules Due in June 2018

The final rule is set for publication on June 27, 2018 (see this notice at the Federal Register). I’ll provide a summary here at BruceAir.

You can read more about the NPRM published in May 2016 at my blog, here.

11 thoughts on “New Simulation and Training Rules Due in June 2018”

  1. Hi Bruce,

    Thanks for your good analysis of this this NPRM. It’s nice to see (albeit still theoretical) movement towards real-world improvements in currency and training/certification, or at least removing some of the logistical roadblocks.

    I haven’t been able to find clarifications on some of the details of the TAA definition, namely, what is meant by the term “integrated autopilot”? Do one of the screens have to show A/P modes etc…

    This borders on semantics, but I think that a literal interpretation could possibly preclude the use of even Cirri that are older (Avidyne-paneled), as the MFD does not explicitly “provide gps” (the NAV interface is the GNS430 or installed equivalent) nor autopilot (the interface is in neither of the screens). Older G1000 DA-40’s could be excluded as well, as the KAP-140 autopilot is less-integrated than those equipped with the Garmin unit.

    A liberal definition could include anything down to something with a digital AI replacement (that shows magnetic heading) and a moving-map GPS w/2-axis autopilot. If simply having two big screens is the requirement, then many perfectly suitable training aircraft (per the features listed) may be excluded.

    The details of the definition of this could influence the decision making of many people, given that the recent developments in avionics options give the possibility of upgrading older training aircraft to these standards for not-obscene amounts of money, and I suspect that there are more than a few owners of experimental birds who are wondering if they’ll be included, or of older airframes who are looking at the newly-approved avionics options from Avidyne, Trutrak, and Garmin. Even owners of older Cirrus’s w/Aspen PFD’s may fall on either side of the line, as I see it.

    Speaking from my own position, sitting on a currently for-sale DA-40 (with the Garmin A/P) and shopping older Cirrus’s (which have a wide variety of panel equipage), I have to wonder if I should wait until I’ve completed my upcoming CPL checkride and CFI training (leading to a checkride), and how this would influence a purchase decision (or the marketability of my Diamond).

    1. My reading of the NPRM (we’re still waiting for the final rule) suggests that most autopilots would meet the requirements outlined for TAA if the autopilot can track nav sources, including the required GPS. Using a GNS-series and Avidyne avionics, such as in older Cirrus models, shouldn’t preclude those aircraft from being classified as TAA. For more information, read some of the comments (e.g., from Garmin and others) that are in the docket, here:

  2. One further note – per the details in the NPRM, to qualify as a TAA, “an independent MFD must be installed that provides a GPS with moving map navigation system and an integrated two axis autopilot.”

    At least in the G1000, the autopilot and the panel interact through the PFD – not the MFD.

    1. Again, see especially Garmin’s comments in the NPRM docket. I suspect that the definitions in the final rule will address some of these issues.

      1. Thanks Bruce. Some good information in there, and though the answers don’t exist just yet, it’s good to see that my concerns were raised by other parties.

  3. Hi Bruce,

    I am wondering if you have further updates on when the new simulation rule and TAA rule (for Commercial and CFI ratings) might be finalized? Thanks.

    1. No. Your best option is to check the Federal Register and sign up for email updates on the docket. I will post an update when the final rule is published.

  4. With the new publication, Agency Information Collection Activities: Requests for Comments; Clearance of Renewed Approval of Information Collection: Certification: Pilots, Flight Instructors, and Ground Instructors ( on 6/14/2018, which has a comment period ending 8/13/2018, does this mean more significant delays in the final rule? It looks like they are now collecting comments regarding the Paper Reduction Act and the asking of the OMB for information collection.Or is this part of the normal process?

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