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IMC Club News

Statement of the president of IMC Club on the FAA’s reduction of time allowed in Approved Training Devices (ATDs)

09 Jan 2014 3:13 PM | by IMC News Service (Administrator)
Statement of the president of IMC Club on the FAA’s reduction of time allowed in Approved Training Devices (ATDs)

By Radek Wyrzykowski - On January 2nd, the Federal Aviation Administration (FAA) posted a Notice of Policy Change in the Federal Register for the use of FAA Approved Training Devices (ATDs). This unexpected change in a policy for GA flight simulators may harm aviation safety by discouraging the use of flight simulators in instrument training.

GA simulators affected by the FAA change in policy will include virtually all FAA approved Personal Computer Aviation Training Devices (PCATD), Flight Training Devices (FTD) level 1-3, Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD). The change will limit pilots to the maximum of 10 hours of simulator time loggable toward an instrument rating. Some ATD simulators currently are allowed to be used as many as 20 hours to count toward an instrument rating.

Since flight education should not be about reaching minimums but rather gaining knowledge and skill as necessary, I would like to appeal to all instructors to incorporate ATD’s in their flight educational activities regardless of the ability to log the time.

Although FAA is not preventing any flight instructor from using an ATD in their flight training as much as it is needed, the IMC Club International, Inc. is seeing this - time allowed reduction - as a potential step in a wrong direction. We strongly believe that setting appropriate minimums rather than limiting the maximum use should encourage use of modern simulators, especially with today’s complex cockpit environment.

It is our responsibility, as the pilot community as whole, to respond, comment and stop any regulatory changes that may impact the growth, and safety of General Aviation community regardless if we are affected directly by it or not.

I would like to appeal to all our members and all pilots who are reading this to post their comments on the FAA’s website. Our power to influence positive outcomes is in numbers. Be brief and to the point in your opinion to allow real possibility of review by the agency. Please click here to post your comment.

Comments

  • 09 Jan 2014 3:57 PM | Daniel Everette
    While leaning slightly against the FAA's direction, I will say I've always been a proponent of using any ATD (even home-based simulators).

    My personal belief is that an instrument rating and proficiency isn't as much about the mechanics of working the cockpit, but of situational awareness and solid ADM. Gaining a solid ADM foundation is based on experience and exposure to many more environmental stimuli than most flight school FTD's can provide.

    I've always advocated simulation to help reinforce/train the mechanics, allowing flight time to build the risk management experiences, leading into solid ADM. IMCClubs is another incredibly valuable tool in this puzzle, and why I've recommended it often. Reviewing/discussing scenarios, or "best-practices" along with case studies, and a local pool of experience/resources with like minded pilots is another input into the safety equation.

    Thank you for the heads up on the Notice. We'll see what the FAA finally does.
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  • 09 Jan 2014 4:53 PM | by IMC News Service (Administrator)
    By Tom Gilmore - I hereby strongly suggest that the FAA not implement any changes to the current use of the flight simulators as outlined in the Policy Change that is being considered. It will not only cause financial harm to those pilots wishing to take instrument training, but setback the proven safety track record of the use of the already approved flight training devices. The General Aviation economy has already suffered enough without this added bureaucratic change that is being proposed.
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  • 12 Jan 2014 7:05 AM | Bill Castlen
    Hmmmmm. I actually read the FAA's policy statement in the Federal Register and found it to be not unreasonable. It seems reasonable to me to have Letters of Authorization with an expiration date. In light of the fact that computer hardware and software in our airborne and ground environments continue to evolve with time, it seems reasonable to me that some of the early PCATDs - for instance - may no longer be representative of the current IFR and NAS environment. ATDs serve an important purpose in our training and basic currency requirements but in no way can fully substitute for experience in the plane, in IMC, and in the real NAS. So, it is my view that the new FAA policy on ATDs will be a bureaucratic annoyance like cleaning out the garage or hangar to get rid of stuff we really don’t need anymore. Every change the Federal government makes is not necessarily bad; I choose to save my angst for something more substantial than this one.
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