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)
BruceAir, LLC 