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.

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Microsoft Flight Simulator X: Steam Edition

Microsoft shut down development of the long-running Flight Simulator franchise in 2009 (details here). But the simulation lives on through an agreement with Dovetail Games that allows that company to release FSX on its online Steam platform (see this item from July 2014).

Dovetail released the Steam edition this month, and the company has opened a discussion board to answer questions about the product. That online forum is the best source for details about this release of FSX and the company’s plans for future development.

If you own the disc-based version of FSX and have questions about the new online product, you should start at this page. Here’s Dovetails’s answer to the most common question about what’s new about this version:

We have made some functional changes to FSX in the development of FSX: Steam Edition, but in terms of content nothing new has been added at this time…

This is a re-release of FSX Gold Edition so you should not expect dramatic differences. However, we have updated it to include all standard Steam functionality, we’ve removed CD checking and combined the components of Gold Edition into a single installation. The major change we’ve made is in replacing the now-defunct GameSpy multiplayer systems with Steam features, enabling multiplayer to work seamlessly once again. Our aim in this first instance has been to ensure that the software will run for as many people as possible rather than radically improving or updating it.

You can find a log of significant changes that Dovetail made to the FSX code here.

The company’s discussion board is also the best source for information about add-ons, hardware compatibility, and related questions.

Microsoft Flight Simulator: Revived?

Microsoft and Dovetail Games have struck a deal that will bring Microsoft Flight Simulator X (released in 2006) to the Steam online gaming platform in 2015. The sketchy details are outlined in a July 9 press release, which you can read here. Excerpt:

The award-winning creators of the best-selling Train Simulator franchise have today announced a global licensing deal with Microsoft, granting them the rights to develop and publish all-new flight products based on Microsoft’s genre-defining flight technology. The company is currently investigating new concepts in this area and is expecting to bring a release to market in 2015.

In addition to this licensing agreement, Dovetail Games is pleased to announce that it has also acquired the rights to distribute the multi-award winning Microsoft Flight Simulator X: Gold Edition via Valve’s popular digital retail channel, Steam, entitled Microsoft Flight Simulator X: Steam Edition.

Gamespot published a report on the deal, here. Excerpt:

Unfortunately, it doesn’t sound as if the Steam Edition of Flight Simulator X will feature any improvements. Dovetail told GameSpot, "We have the license to re-release FSX on Steam and this does not extend to making product improvements. However, we will include all possible bug fixes we can. One area that will require some work is the use that FSX made use of GameSpy for multiplayer features. As you may know, GameSpy is no longer available and so we are looking for alternate ways of providing this functionality including using features in Steam."

Additionally, Dovetail says the new game it’s working on won’t actually be called Microsoft Flight Simulator; it will simply be using Microsoft’s technology. As of yet, there is no title for the new game coming next year.

Simulations, Flight Simulators, FTDs, and ATDs

Pilots and flight instructors often debate the value of using flight simulation to complement flight training. We casually use the phrase flight simulator when referring to non-flying gizmos that re-create, at varying levels of fidelity, the experience of being in an airplane cockpit. Simulator is a handy shortcut, but can lead to confusion about how such devices can be used during training and to maintain currency. Equally important, misunderstanding the differences among simulations, flight simulators, flight training devices (FTD) and aviation training devices (ATD) often means these tools aren’t used most appropriately or effectively.

The following discussion is based on Chapter 3, “Using PC-Based Simulations Effectively” in my last book, Scenario-Based Training with X-Plane and Microsoft Flight Simulator: Using PC-Based Flight Simulations based on FAA and Industry Training Standards (ISBN: 978-1-1181-0502-3); more information at my website, here.

For additional information about how the FAA classifies flight simulators and flight training devices, see the November/December 2017 issue of FAA Safety Briefing. That entire edition is devoted to flight simulation.

Simulators, FTDs, and Simulations

Technological leaps have blurred the lines that just a few years ago distinguished the capabilities of full-motion simulators from the features of the home cockpits that hobbyists set up in their basements and garages. Recent changes to the definitions of and the regulations governing the use of FAA-approved simulators have added to the aviation community’s confusion about these tools.

Key Categories

The FAA recognizes four general categories of flight simulation systems:

  • Full Flight Simulator (FFS)
  • Flight Training Device (FTD)
  • Advanced Aviation Training Device (AATD)
  • Basic Aviation Training Device (BATD)

The first two categories are described in 14 CFR 60: Flight Simulation Training Device Initial and Continuing Qualification and Use. ATDs are discussed in AC 61-136A – FAA Approval of Aviation Training Devices and Their Use for Training and Experience.

Each category of simulator and training device includes levels that describe the increasing sophistication, capability, and fidelity of the systems.

Full Flight Simulators

The term Full Flight Simulator (FFS) replaces airplane simulator, previously defined in AC 120-45A. According to the current FAA regulations, an FFS is a

…replica of a specific type, make, model, or series aircraft. It includes the equipment and computer programs necessary to represent aircraft operations in ground and flight conditions, a visual system providing an out-of-the-flight deck view, a system that provides cues at least equivalent to those of a three-degree-of-freedom motion system, and has the full range of capabilities of the systems installed in the device….(14 CFR 60, Appendix F)

The core of that definition remains “replica of a specific type, make, model, or series aircraft.” In other words, a flight simulator duplicates the performance and flying characteristics of a particular airplane, and it must re-create an airplane’s cockpit with great fidelity, including exact reproductions of the real aircraft’s physical controls, instrumentation, and switches. It must reproduce the aircraft’s flight characteristics with high fidelity. The photo below shows a typical modern full flight simulator made by CAE.

CAE

Flight Training Devices (FTDs)

The same regulations update the definition of a Flight Training Device (FTD) to:

…a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft flight deck replica. It includes the equipment and computer programs necessary to represent aircraft (or set of aircraft) operations in ground and flight conditions having the full range of capabilities of the systems installed in the device…for a specific FTD qualification level. (14 CFR 60, Appendix F)

That description drops the requirement that an FTD must mimic a specific make or model of an aircraft. The degree to which a particular FTD must emulate an aircraft’s controls, instruments, and switches depends on the device’s certification level, but in general, an FTD doesn’t have to duplicate every switch. The photo below shows an FTD manufactured by Precision Flight Controls.

105023 f0302

For example, a Level 4 FTD, the least sophisticated type:

…may have an open airplane-specific flight deck area, or an enclosed airplane-specific flight deck and at least one operating system. Air/ground logic is required (no aerodynamic programming required). All displays may be flat/LCD panel representations or actual representations of displays in the aircraft. All controls, switches, and knobs may be touch sensitive activation (not capable of manual manipulation of the flight controls) or may physically replicate the aircraft in control operation. (14 CFR 60, Appendix F)

Level 5 and 6 FTDs must replicate the cockpits and flight characteristics of aircraft with increasing precision.

Basic and Advanced Aviation Training Devices

In 1997, the FAA published AC 61-126, Qualification and Approval of Personal Computer-Based Aviation Training Devices, which, as the title implies, discussed the use of PC-based simulations. PCATDs, as the devices were known, included software like Microsoft Flight Simulator, hardware (usually one or more consoles that incorporated a flight yoke and other controls and switches), and a display (typically an off-the-shelf computer monitor). Because the technology was new, the FAA restricted the use of PCATDs to a few basic tasks required during primary and instrument flight training.

Technological advances and the aviation community’s experience with PCATDs led the FAA to update the definition and expand the use of PC-based simulations. AC 61-136A – FAA Approval of Aviation Training Devices and Their Use for Training and Experience, first issued in 2008, retired the PCATD category and described the PC-based training devices that the FAA now approves for use in aviation training.

The core requirements for BATDs and AATDs are more general than those specified for flight simulators and FTDs. For example, according to AC 61-136A, a BATD “Provides a training platform for at least the procedural aspects of flight relating to an integrated ground and flight instrument training curriculum.”

The photo below shows a typical ATD made by Precision Flight Controls.

105023 f0303

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.”

The hardware specifications for BATDs and ATTDs are similar. For example, a BATD “must provide certain physical controls and may provide some virtual controls,” described as follows:

(1) Physical flight and aircraft system controls should be recognizable as to their function and how they are to be manipulated solely from their appearance. Physical flight and aircraft system controls eliminate the use of interfaces such as a keyboard, mouse, or gaming joystick to control the represented aircraft model in simulated flight.

(2) For the purposes of this AC, virtual control is any input device to control aspects of the simulation (such as setting aircraft configuration, location, and weather) and to program, pause, or freeze the device. Virtual controls should be primarily for the instructor’s use…

(4) The physical arrangement, appearance, and operation of controls, instruments, and switches…should model at least one aircraft in the family of aircraft represented as closely as practicable. Manufacturers are expected to use their best efforts to recreate the appearance, arrangement, operation, and function of realistically placed physical switches and other required controls representative of a generic aircraft instrument panel. (FAA Advisory Circular AC 61-136A)

The Deeper Distinction

It’s as easy to distinguish superficially between an FFS and a BATD as it is to see the differences between a single-engine trainer and an airliner. But there’s more than technology behind the differences between types of simulation devices. They’re intended for fundamentally different uses.

Simply put, an FFS is a substitute for a specific aircraft, and in many circumstances, pilots using an FFS can receive all the training required to operate the simulated airplane and earn a type rating for that aircraft without ever leaving the ground. In fact, airline pilots who have completed training for a new type in an FFS, and who may never have been in the cockpit of the real aircraft that the simulator emulates, often make their first flights in that airplane in regular revenue service with passengers on board.

To achieve the level of fidelity necessary to meet that goal, the specifications for an FFS are extensive, detailed, and stringent. As noted earlier, they require that a simulator duplicate a specific cockpit. The FFS must also have a wide-view, high-resolution display; “flying” characteristics that closely mimic those of the real airplane throughout its normal flight envelope; a sophisticated sound system; and motion that accurately re-creates the feel of flying.

Level 4, 5, and 6, FTDs are by definition less comprehensive representations of specific aircraft or broad types of airplanes, and as such, the requirements they must meet are less stringent. They also can’t be used to complete all of the training pilots must receive. To earn type ratings or similar approvals to act as the pilot in command of an aircraft simulated by an FTD, pilots eventually must fly the real airplane—or train in an appropriate FFS.

A BATD or AATD, however, is not intended to be a replacement for a specific aircraft, or even a series of related aircraft—it’s not a simulator. In fact, as their full names imply, BATDs and AATDs are not even flight training devices.

Instead, BATDs and AATDs are Aviation Training Devices (ATDs) intended to complement aircraft—and ground-school classrooms—throughout a training program. The FAA explains the distinction this way:

Instructors have typically taught flight task procedural skills almost exclusively during in-flight training and aeronautical knowledge during ground training. However, based on the available data, the FAA has determined that instructors can successfully teach procedural understanding of certain flight tasks during ground and flight training using [BATDs and AATDs]….(FAA Advisory Circular AC 61-136)

In other words, ATD aren’t intended—primarily at least—to help pilots develop and hone stick-and-rudder skills. They’re essentially procedural and part-task trainers to help pilots understand and apply important concepts and to practice and master general procedures that apply to a variety of aircraft.

Simulations

Finally a simulation, flight or otherwise, is just a representation—these days typically a virtual representation—of something. That something can be a physical object or a process.

The key to using PC-based simulations effectively, then, is understanding that like BATDs and AATDs, they are tools to help pilots grasp general principals and practice basic procedures through hands-on experience.

Where X-Plane and Microsoft Flight Simulator Fit In

You may have noticed the discussion of BATD and AATD hasn’t mentioned X-Plane or FSX. The reason is straightforward—neither product by itself meets the FAA standards for a “training device,” which by definition must include software and hardware, such as flight controls and cockpit switches.

Physical flight and aircraft system controls [of an ATD] should be recognizable as to their function and how they are to be manipulated solely from their appearance. Physical flight and aircraft system controls eliminate the use of interfaces such as a keyboard, mouse, or gaming joystick to control the represented aircraft model in simulated flight. (FAA Advisory Circular AC 61-136)

The only significant physical difference between X-Plane or FSX configured as described in Chapter 1, “What You Need to Use this Book,” and a BATD is the use of a “gaming” joystick for primary flight control and a mouse to operate the virtual switches and other controls depicted on the cockpit display. The FAA requirements for a BATD restrict the use of a mouse and keyboard as follows:

Except for setup and/or fault mode entry, neither the keyboard nor the mouse may be used to set or position any feature of the BATD in the represented aircraft for the maneuvers or flight training to be accomplished…The pilot must operate the additional equipment needed in order to accomplish a training procedure…in the same manner in which it would be operated in the represented aircraft. For example, [by using] landing gear, wing flaps, cowl flaps, carburetor heat control, and mixture, propeller, and throttle controls. (FAA Advisory Circular AC 61-136)

The latest flight yokes, throttle quadrants, and other accessories developed for hobbyists, however, meet the FAA requirement that they be “recognizable as to their function and how they are to be manipulated solely from their appearance.”  Many BATDs use such off-the-shelf cockpit controls.

Flight Dynamics

No issue generates more heated debated among users of PC-based simulations—including pilots and flight instructors—than the perceived realism of the “flight” characteristics (also known as the “flight models,” or, more formally, the “flight dynamics”) of different simulations.

Because BATDs and AATDs are aviation training devices, not flight simulators, the FAA lays out only general standards for the flight models that drive them. Note that throughout the following descriptions, there is no requirement that a flight model replicate the characteristics of a specific airplane:

(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…

(2) Aircraft performance parameters (such as maximum speed, cruise speed, stall speed, maximum climb rate, hovering/sideward/forward/rearward flight) should be comparable to the aircraft or family of aircraft being represented.

(3) Aircraft vertical lift component must change as a function of bank, comparable to the way the aircraft or family of aircraft being represented performs and handles.

(4) Changes in flap setting, slat setting, gear position, collective control or cyclic control must be accompanied by changes in flight dynamics, comparable to the way the aircraft or family of aircraft represented performs and handles.

(5) The presence and intensity of wind and turbulence must be reflected in the handling and performance qualities of the simulated aircraft and should be comparable to the way the aircraft or family of aircraft represented performs and handles. (FAA Advisory Circular AC 61-136, Appendix 2)

Put in more familiar terms, the virtual airplane inside an ATD must bank left when you move the yoke to the left. The nose must pitch up when you pull back on the flight controls. Changing power should make the aircraft speed up or slow down (or affect its rate of climb or descent). The rates at which the airplane rolls, pitches, and yaws should be “comparable” to the way a given airplane or family of similar aircraft responds to a pilot’s actions.

For the purposes of this book, then, there’s no meaningful distinction between the “blade element theory” at the core of X-Plane and the classic “6-degree-of-freedom” model employed in FSX. (If you’re interested in the technical details of each approach, see the links to more information at this book’s website.) Both simulations, in fact, exceed the general requirements for the flight model at the heart of an ATD. The choice of which PC-based simulation to use depends largely on personal perception of how the virtual aircraft respond and on other considerations, as described in Chapter 5, “Choosing a PC-Based Simulation: X-Plane or FSX?”

Additional Information

‘Flights of fancy: Inside the intense world of virtual pilots’

The December 20 edition of the Washington Post included this feature about virtual aviation. It’s a good overview of the history of PC-based flight simulations and the world-wide community of virtual aviators:

…[O]ver the past couple of decades the flight simulation community has grown to more than 70,000 members, spawned a cottage industry of software makers, developed most of the trappings of the commercial aviation industry, and created a complicated system of self-governance — it’s the biggest fantasy league you’ve never heard of.

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.

The draft AC 61-136A will supplant AC 61-136 when it is adopted. FAA is accepting comments on the new document until October 8, 2013. You can learn more about the AC and how to comment here.

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.

Interview about PC-Based Simulation

The friendly folks at the Hangar 49 podcast (produced in the Pacific Northwest) have posted their latest installment (mp3), which includes an interview with me about using PC-based flight simulations to complement flight training.

This is one of several interviews and webinars that I’ve done recently on this topic. You can watch the webinar, hosted by EAA, here. Another interview is available as a podcast at PilotSafetyRadio.

For more information about my two books about PC-based flight simulation, visit my website.