Flying an Approach with only an iPad

You’re suddenly having a bad IFR day. As you approach your destination, Huron, SD, after a routine departure and a comfortable cruise in IMC, most of your panel abruptly goes dark. You still have basic flight instruments, including an electronic PFD and an HSI, which run on backup batteries. Your last communications with ATC included a clearance to an initial approach fix and “expect the ILS RWY 12 approach.” But your GPS navigator, which includes navigation receivers, is now kaput, along with your second nav/com. In other words, you have no moving map or course guidance in the panel–just attitude, airspeed, altitude, and heading. You can’t even see a GPS track indicator.

The good news is, you have an iPad with a built-in GPS (or a tablet connected to an external GPS source) running ForeFlight or a similar app. The EFB confirms that your blue “own ship” symbol is tracking toward HUMSO, an initial approach fix that marks the beginning of a feeder route that takes you to the final approach course.

Using just your track shown on the approach chart, and your basic instrument flying skills, can you fly the approach?

See my article on this topic at AOPA Flight Training magazine: When the Screens Go Dark.

I practice such scenarios periodically during recurrent training. In my A36 Bonanza, operating under VFR with a safety pilot, I switch the navigation screen on my GTN 750Xi to the traffic page, which provides no navigation information, and then I practice getting to an airport and flying an approach using only the iPad for guidance.

Of course, an iPad isn’t a “suitable RNAV system” as defined in the AIM and FAA advisory circulars, but in IMC under IFR, this scenario qualifies as an emergency, and you can bend the rules as necessary to arrive safely.

As you’ll see in this video, a challenge like this is also an excellent workout in an aviation training device. Galvin Flying, the flight school in Seattle where I instruct, has two ATDs made by one-G Simulations. They emulate C172s. You can connect ForeFlight to the Wi-Fi signals broadcast by each trainer, which send position, altitude, speed, and other information to your tablet. As far as ForeFlight is concerned, you’re flying.

Just as in the airplane, provided your EFB can receive GPS signals, you have a good 2-D navigation solution. If you can keep your blue airplane tracking along the lines on a geo-referenced approach chart, you’ll follow the intended path. What you don’t get, however, is any type of vertical guidance. It’s up to you to establish and maintain a steady descent that keeps you as close as possible to an ILS glideslope or a GPS glidepath for an approach to a DA, or to the profile for a non-precision approach to an MDA.

You may also want to practice using the synthetic vision feature, if your EFB app supports it. Although I prefer flying with the procedure chart visible, synthetic vision would be a terrific aid if you lose the basic flight instruments.

Flying an approach like this successfully requires mastery of fundamental instrument skills, what we used to call flying with only “needle, ball, and airspeed.” You must understand and be able to apply the control-performance method of instrument flying—establishing the appropriate attitude, setting power and configuration, monitoring your progress, and making constant, smooth adjustments as you proceed. In other words, it’s a good test that takes you back to drills like flying Pattern A and Pattern B that you practiced early in your IFR training.

Watch the video to see how accurately I flew two approaches in the ATD with just the airplane symbol on an approach chart for guidance.

A Better Approach to Teaching and Using Technology in the Cockpit

Here’s a video version of a presentation that gave at the Northwest Aviation Conference in February 2022. I have long argued that flight instructors and pilots need to adapt how we teach and use technology such as electronic flight displays, GPS navigation, and electronic flight bags (EFBs) to reflect how pilots fly in the real world.

We certainly don’t want to create so-called children of the magenta line, pilots who are helpless without GPS guidance and autopilots. But given the reality that most of us fly today with at least some advanced technology, we should do a better job of preparing pilots to use the tools available to them. And we should remember that the “good old days” weren’t really so good, at least when we consider the frequency of accidents related to weather, loss of situational awareness, running out of fuel, and so forth.

This 25-minute presentation also offers suggestions that can help flight instructors use technology, such as autopilots, flight directors, and aviation training devices, to introduce basic skills to new students–and to help pilots who have upgraded their panels and avionics adapt their old flying habits.

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.

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

New AC for ATDs

FAA has published AC 61-136B, FAA Approval of Aviation Training Devices and Their Use for Training and Experience, an update to the previous edition of the advisory circular.

I wrote about the earlier update to this AC in 2013, here. See also New IFR Currency Rules and Other Changes to 14 CFR Part 61.

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

This AC provides information and guidance for Aviation Training Device (ATD) manufacturers seeking Federal Aviation Administration (FAA) approval of a basic aviation training device (BATD) or advanced aviation training device (AATD)…

This AC also provides information and guidance for those persons who intend to use a BATD or AATD for activities involving pilot training and experience, other than for practical tests, aircraft-type-specific training, or an aircraft type rating.

For most pilots, flight schools, and flight instructors, the most relevant section is Appendix D, Training Content and Logging Provisions, which includes a syllabus for integrated training using ATDs.

That appendix also clarifies how pilots and CFI should log time when using ATDs.

Logging Training Time and Experience. 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. ATD time can only be logged as Instruction Received (Dual), Instrument Time, or Total Time as reflected on the pilot time section of FAA Form 8710-1, Airman Certificate and/or Rating Application. 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 instrument experience requirements as specified in part 61 or part 141. It is required under § 61.51(b)(1)(iv) that the type and identification of the ATD be included when logging pilot time as described in the letter of authorization (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 parts 61 and 141 and in the LOA. No approvals or authorizations are provided for aircraft type ratings using ATDs.

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.

Comments on Proposed Rule Changes

The FAA recently proposed several significant changes to regulations that expand the use of aviation training devices, training for the commercial pilot and certified flight instructor certificates, maintaining instrument currency, and other issues of interest to many general aviation pilots and flight instructor.

Below are my comments on some portions of the proposed rules, which I have submitted to the docket.

Use of TAA for Commercial and Flight Instructor Certificates

For all the reasons outlined in the proposal, I support the option to substitute a TAA (as redefined in the proposed rule) for the training and practical tests required for the commercial pilot and certified flight instructor certificates with single-engine-land ratings.

One commenter objects that pilots won’t gain experience “with higher performing engine[s], retractable gear, constant speed propeller, etc.” But most flight schools offering training for those certificates rely on aircraft such as the C172RG or Piper Arrow, which have at most 200-hp engines. These are hardly high-performance aircraft, either as defined by FAA regulation or by their speed, sophisticated avionics and equipment, or handling characteristics. Pilots who want to fly aircraft with retractable landing gear, constant-speed propellers, turbocharged engines, and other characteristics typically associated with high-performance aircraft will still, as a practical matter, require checkouts and operating experience mandated by regulations (e.g., the endorsement required to act as PIC in an aircraft with an engine rated at more than 200 HP), insurance, flight school policies, commercial operator specifications, and common sense (a refreshing concept endorsed in the recent proposal to revise 14 CFR Part 23 aircraft certification rules—viz., “The part 23 regulations should not need to prescribe basic physical principles, sound engineering judgment, and common sense.”).

The checkout required for aircraft like the C172RG or Piper Arrow is hardly a leap from a Skyhawk or Warrior. Instead, it’s a small step, and learning to operate and confirm the configuration of, for example, retractable landing gear, is only a small part of a complete commercial pilot or CFI training syllabus, and that basic training hardly prepares a pilot to fly a truly high-performance “complex” aircraft such as Cirrus SR22 (which has fixed landing gear) or a Beechcraft Bonanza.

Similar examples: (1) Pilots with MEL ratings on their pilot certificates legally can fly any multiengine aircraft that doesn’t require a type rating. But in the real world, they must receive training and gain operating experience in specific makes and models to obtain insurance, fly rental aircraft, or act as PIC in a commercial operation; (2) Regulations require only a single logbook endorsement to fly tailwheel aircraft. But the handling characteristics of tailwheel aircraft vary widely (even among those that don’t have big engines, constant-speed propellers, etc.). Again, insurance, rental policies, and common sense oblige pilots who fly tailwheel aircraft to receive training and gain operating experience in specific makes and models.

Maintaining IFR Currency with ATDs

I applaud the proposed changes that would allow instrument-rated pilots to maintain currency with in any combination of aircraft, FFS, FTD, or ATD without requiring an instructor to be present. The current regulations are a deterrent to pilots who use ATDs. They must parse the rules and carefully review their logbooks to ensure that they have met the arcane requirements for various tasks, time limits, and calendar constraints. Instead of using training devices, today most pilots hop in their aircraft with a safety pilot (not necessarily an instructor) and repeatedly fly the same familiar procedures in their local areas, missing opportunities to practice the important skills of briefing and setting up a variety of DPs, arrivals, and approaches that include such elements as DME arcs and course reversals. They also typically don’t gain experience handling realistic equipment failures, challenging weather, and so forth. As the FAA notes, the proposed changes would encourage pilots to maintain their instrument skills.

My experience as an instructor strongly suggests that it’s the mental, puzzle-solving side of IFR flying that deteriorates most quickly over time. Use of training devices is the most effective, efficient way to hone and maintain those mental skills.

Pilots who want to use a training device at a flight school will still require at least an initial checkout on the equipment to ensure that they can use it effectively. Those checkouts are an opportunity for pilots to work with instructors to deficiencies in both their understanding of IFR flying and specific piloting skills, and those encounters will help instructors to develop relationships with pilots who otherwise might not be receiving training.

Pilots are upgrading aircraft to include sophisticated avionics (even if the panel doesn’t meet the revised definition of a TAA). They are increasingly using tablets and other devices as substitutes for charts and to provide information about weather, traffic, and other details. Allowing pilots wider, creditable use of training devices that include, for example, GPS navigators, will help them develop and maintain the essential skills described in such publications as the Advanced Avionics Handbook and Instrument Procedures Handbook. Using training devices also gives pilots opportunities to practice using new technology and develop good operating procedures.

Definition of ATD

The notice includes a new definition of aviation training device (ATD):

The FAA is now proposing to define ATD in § 61.1 as a training device, other than a full flight simulator or flight training device, that has been evaluated, qualified, and approved by the Administrator.

It’s not clear, however, if the proposed changes would eliminate the basic aviation training device (BATD) and advanced aviation training device (AATD) categories as described in AC 61-136 FAA Approval of Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD). The language in various sections of the proposed rules is ambiguous and should be clarified, and AC 61-136 and related policy guidance should be revised to ensure that both FAA and airmen throughout the system have a clear understanding of distinctions among the devices. I understand that for the purposes of FAA approval the existing categories may remain desirable—especially for manufacturers. But FAA inspectors, pilots, and instructors should not be confused about the practical application of ATDs for training and maintaining currency.

Updates on Using Aviation Training Devices (ATD)

FAA has published new regulations and guidance for pilots and instructors who use aviation training devices (ATD).

On June 27, 2018, FAA published several important changes to 14 CFR Part 61 that expand the use of ATD, FTD, and FFS to maintain IFR currency. You can read about those changes at BruceAir here.

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.

FAA published AC 61-136B in September 2018. For more information about that update, see New AC for ATDs.

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.

New FAA Policy on Flight and Aviation Training Devices

On January 2, 2014, the FAA published a Notice of Policy Change for the Use of FAA Approved Training Devices in the Federal Register. The change, issued without consulting the aviation training community, will make it harder for instructors and flight schools to use ATDs. In the words of the Society of Aviation and Flight Educators:

“FAA officials, understanding the value of simulators in flight training, have been issuing these LOAs since 1980,” said [executive director Doug] Stewart.  “This proposed policy change will take away much of the incentive for pilots to improve their skills in a better classroom than a noisy cockpit.”

I have prepared my own comments on the new policy, which you can read below.

Federal Aviation Administration
AFS-810, Airmen Certification and Training Branch
800 Independence Ave. SW. Washington, DC 20591

RE: Agency/Docket Number: FAA-2013-0809 / Document Number: 2013-31094.

Greetings,

I am disappointed to learn of the “Notice of Policy Change for the Use of FAA Approved Training Devices” published in the Federal Register on January 2, 2014 (Agency/Docket Number: FAA-2013-0809 / Document Number: 2013-31094).The change, announced without consulting the flight training community, represents a step backward in encouraging and broadening the use of interactive tools that help pilots safely and efficiently learn critical concepts, develop fundamental skills, and maintain proficiency during initial training and throughout their flying careers.

The new policy also runs counter to several of FAA’s own initiatives, from the approval of aviation training devices (ATD) to the emphasis on scenario-based training, both in FITS-oriented programs and in the latest editions of the practical test standards, which emphasize aeronautical decision making, resource management, and related skills that are ideally suited for introduction and practice in training devices. Indeed, FAA-accepted FITS syllabi all emphasize the use of training devices from lesson one.

To quote from my latest book about the use of PC-based flight simulations to complement flight training:

FAA-Industry Training Standards (FITS) is a joint initiative between the aviation industry and the Federal Aviation Administration:

• To make pilot training more relevant as technology rapidly transforms aircraft cockpits, and
• To help flight instructors use new tools (especially simulation) and teaching methods to increase the effectiveness and efficiency of flight instruction…

The ultimate goal is to reduce the number of aviation accidents and incidents by emphasizing and addressing the perennial cause of most crashes—pilot error.

The FITS approach includes several key components:

• Scenario-Based Training (SBT)
• Extensive use of simulation
• Aeronautical Decision Making (ADM)
• Risk Management

Often overlooked amid the jargon, however, is an important and beneficial side effect of scenario-based training [complemented extensively with simulation]—it makes learning to fly…more interesting, challenging, and fun. In other words, SBT creates “adventures for learning” that:

• Give you realistic reasons—missions—to fly
• Present real-world challenges such as changing weather, equipment malfunctions, pressures from passengers, and other unexpected circumstances, that pilots must handle even on routine flights
• Help you measure your progress against specific goals
• In short, FITS focuses on teaching you to think like a pilot.

All of those goals are best addressed by using a combination of tools and resources—including and especially simulation—during training.

The Aviation Instructor’s Handbook (FAA-H-8083-9A), while not specifically addressing flight simulation, emphasizes the value of interactive technologies (see, for example, “Instructional Aids and Training Technologies” in Chapter 4, “The Teaching Process”). The GA flight-training industry, airline, and military flight training programs all make extensive use of simulation, including part-task trainers and training devices (even those not specifically approved by FAA), because these tools have proven their value.

The new policy is also at odds with FAA’s description of ATD in AC 61-136, FAA Approval of Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD). That document describes a BATD as:

…a training platform for at least the procedural aspects of flight relating to an integrated ground and flight instrument training curriculum.

According to the same AC, the more sophisticated AATD:

Provides a training platform for both procedural and operational performance tasks related to ground and flight training towards private pilot, commercial pilot, and airline transport pilot certificates, a flight instructor certificate, and instrument rating.

Note that both of those descriptions emphasize “integrated ground and flight instruction” and “procedural and operational tasks.” ATDs are deliberately named Aviation Training Devices (not simulators) because the primary goal in using them isn’t to hone stick-and-rudder skills in a specific make and model of aircraft. Instead, as noted above, they are tools that help aviators, throughout their training, think like pilots.

The policy change is apparently an attempt to update FAA guidance with respect to the rapidly developing technology of flight simulation. But focusing on details such as display refresh rates and latency (in milliseconds) and the form of the physical controls for a simulation also runs counter to FAA’s own standards for ATDs and various levels of FTD.
For example, the standards in AC 61-136 note that:

(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.

As AC 61-136 also notes:

The GA community is using this evolving simulation technology to provide increasingly effective training capabilities at reduced cost…FAA has determined that instructors can successfully teach procedural understanding of certain flight tasks during training using the flight simulation devices described in this AC.

FAA has presented no evidence that the current system of LOAs and technical standards for ATDs and FTDs has led to significant issues in training or proficiency because the devices themselves are somehow technically deficient, obsolete, or poorly maintained. Indeed, competition and innovation in the industry continues to drive the introduction of improved and more capable training devices.

ATDs and FTDs have proven their value in training. They make it possible—safely, efficiently, and economically—to:

• Introduce new concepts and skills
• Help students overcome learning plateaus and maintain proficiency
• Allow trainees and instructors to explore realistic scenarios that may be impractical or unsafe in an aircraft.

Policy changes that discourage the use of training devices by making compliance and approval needlessly expensive and time-consuming (both for the industry and overworked FAA inspectors) run counter to FAA’s laudable goal of reducing accident rates, pilot deviations, and related issues. FAA should promote—not encumber—the use of ATDs and FTDs and, as always, rely on the professionalism of flight instructors, training providers, and the network of DPEs to ensure that pilots earning new certificates and ratings are prepared to be aviators.

Regards,
Bruce Williams
Certified Flight Instructor
FAASTeam Representative Seattle, WA

Author of:
Scenario-Based Training with X-Plane and Microsoft Flight Simulator (Wiley & Sons, 2012; ISBN 978-1-1181-0502-3)
Microsoft® Flight Simulator as a Training Aid: A Guide for Pilots, Instructors, and Virtual Aviators (ASA, revised 2013, ISBN 978-1-61954-049-1)

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.