Credit for Using ATDs and AATDs

The FAA allows pilots to use flight simulators, flight training devices (FTD), and aviation training devices (ATD) to accumulate some of the aeronautical experience required in 14 CFR Part 61 for various pilot certificates and ratings.

Guidance for using ATD during training is in AC 60-136B and in the letters of authorization (LOA) issued with each ATD.

OneG-foundation

The Foundation from one-G, an AATD based on the C172, is among the newest FAA-approved ATDs.

For additional background about the types of “simulators” that the FAA authorizes, including ATDs and AATDs (advanced aviation training devices), see New AC for ATDs and Simulations, Flight Simulators, FTDs, and ATDs here at BruceAir.

Unfortunately, the regulations aren’t always easy to parse, and when pilots and instructors consider the use of ATDs and AATDs, one regulatory paragraph, 14 CFR Part 61.4(c), is often overlooked, probably because it’s the last sentence in a rule titled “Qualification and approval of flight simulators and flight training devices,” and that section doesn’t specifically mention ATD.

But 14 CFR Part 61.4(c) says: “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.” And that’s the key to understanding the credit allowed in the LOAs.

The flight school where I instruct, Galvin Flying, has several AATDs, each of which has an LOA from the FAA that describes how the devices may be used during training. The LOAs specifically note credits for tasks and for aeronautical experience associated with various certificates and ratings, in accordance with AC 60-136B and 14 CFR Part 61.

Most of the criteria are clear. But over the years, the flight school has received conflicting interpretations about how much experience in the AATDs may apply toward the aeronautical experience requirements set out in 14 CFR Part 61.

For example, 14 CFR § 61.129 [(i)(1)(i)] states that up to 50 hours of simulated flight time in a “full flight simulator” or a “flight training device” may be credited toward the 250 hrs total time required for a commercial certificate. That regulation does not specifically mention “aviation training devices” or “advanced aviation training devices,” distinctions that were made with both regulatory changes and the publication of AC 60-136B.

Now, AC 60-136B notes that the LOA associated with each approved ATD or AATD describes the device’s authorized uses and allowable credit toward specific aeronautical experience requirements. For example:

C.2 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, IPC, commercial pilot, and ATP.

D.3 Logging Training Time and Experience.

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 parts 61 and 141 and in the LOA. No approvals or authorizations are provided for aircraft type ratings using ATDs.

Each of the LOAs for the AATDs at Galvin Flying includes the following language related to the commercial pilot certificate:

…The [model name] AATD is approved for use in satisfying the following sections of parts 61 and 141:…

§ 61.129(i)(1)(i)—Commercial Pilot Certificate: up to 50 hours;…

That language seems clear, but as I noted earlier, the fact that the regulation itself doesn’t mention ATD has led to confusion.

So I wrote the FAA asking for clarification. Here, in part, is the reply, which confirms that the language in the LOAs supplements the regulations in 14 CFR Part 61:

The rule is silent in these rule sections concerning the use of ATD’s including rule sections for Private Pilot, Commercial Pilot, and Airline Transport Pilot certificates. However, Part 61.4(c) states, “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.” All aviation training device (ATD) letters of authorization (LOA) reference §61.4(c) in the first paragraph of the letter. The maximum amount of credit for various certificates and ratings is provided in the LOA. The FAA uses the letter of authorization (LOA) to approve the use of advanced aviation training devices (AATD’s) for private pilot, commercial pilot, and ATP experience requirements utilizing the provision of 14 CFR §61.4(c). The LOA also provides credit allowances for the instrument rating and associated experience requirements.


Marcel Bernard
Aviation Safety Inspector
Aviation Training Device (ATD) National Program Manager
Federal Aviation Administration, Flight Standards Service HQ

In other words, 14 CFR Part §61.4(c) allows you to use an ATD toward the experience requirements in 14 CFR Part 61, as long as you use the ATD in accordance with its LOA.

Here’s a link to a chart from FAA that summarizes credit for use of various training devices and simulators. (But see below for additional information about using simulation devices during training.)

The reply to my query from the FAA (and the language in AC 60-136B) also emphasizes another important point: There’s no absolute limit to the amount of time you can spend using an ATD during training.

Finally, it is important to understand that you can log as much time as you want in an ATD, flight training device (FTD) or full flight simulator (FFS). Many flight instructors believe that you can only “log” what time is indicated on the LOA. This is a common misconception. “Training credit” and “logging of pilot time” are two different considerations. Proactive flight instructors will accomplish and log as much time as needed with their student in the simulator, until the student is proficient for that particular task. This usually results in the student needing far less time in the aircraft to compete the same flight tasks, saving time, money and wear and tear on the aircraft. Additionally, many emergency scenarios that can’t be safely accomplished in the aircraft, can be accomplished in a simulator without risk.

You should always practice tasks to acceptable level of proficiency (ACS standards) in the simulator first, before doing the same task in the aircraft, no matter how much time it takes in the simulator. Without this practice it defeats the advantages, logic and use of a simulator during training.

Marcel Bernard
Aviation Safety Inspector
Aviation Training Device (ATD) National Program Manager
Federal Aviation Administration, Flight Standards Service HQ

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