AC 61-136A contains a complete list of the additional criteria for an approved AATD. These enhanced features allow the FAA to authorize an AATD for training and proficiency “credits” toward the private pilot, commercial, flight instructor, and airline transport pilot (ATP) certificate, as well as the instrument rating and instrument proficiency check. (See figure 1 for details on credit allowances)
Approved for Use
It’s important to note that before a pilot can use an ATD for flight training credit, specific to a certificate or rating, the device must first be issued an FAA letter of authorization (LOA). LOAs are valid for five years and specify the amount of credit a pilot may earn for training and experience requirements. This is important because the regulations do not specifically address airplane ATD allowances for all pilot certification requirements. The LOA will provide for this. (See 14 CFR section 61.4 (c))
To receive this LOA, all ATDs must go through a rigorous approval process. It starts with developing what’s known as an approved Qualification and Approval Guide or QAG. This QAG document serves as the basis for approval and includes a detailed description of all components, functions, capabilities, and possible configurations for the training device.
A manufacturer requesting an ATD approval will send this QAG along with a request letter to the FAA. If both are found acceptable and pass an initial audit, the FAA will then schedule and conduct an on-site operational evaluation of the device. If the ATD passes, the FAA will issue the LOA and an approved QAG to the manufacturer. If a manufacturer later modifies an approved ATD, a revised QAG must be resubmitted for approval.
Recognizing that technology continues to evolve and improve, the FAA is constantly on the lookout for ways to permit increased usage of ATDs in GA pilot training. Just last year a regulation change increased the maximum time that may be credited in an ATD toward experience requirements for an instrument rating under part 61 (20 hours for AATD and 10 for BATD) and provided an allowance of 25 percent and 40 percent of creditable time for BATDs and AATDs respectively toward an instrument rating under part 141. This revision also eliminated the need to wear a view-limiting device when logging instrument time in an ATD.
With another new rulemaking effort in the works, expected in December 2017, the FAA proposes to allow pilots to accomplish instrument currency pilot time in a FFS, FTD, or ATD without an instructor present to verify the time, as well as allow ATD time to accomplish instrument currency requirements to be identical to the tasks and requirements described for an aircraft, FFS, or FTD. Currently, pilots using an ATD to accomplish IFR experience (currency) requirements must perform additional tasks and must log three hours of time in addition to performing six approaches, holds, and intercepts within the previous two months before a flight as required under 14 CFR section 61.57 (c)(3). To see the proposed rule, go to go.usa.gov/xRt5Q.
“These changes are designed to help pilots save time and money, as well as take advantage of the unique training opportunities ATDs can offer,” says Marcel Bernard, an FAA aviation safety inspector with the General Aviation and Commercial Division and the ATD National Program Manager. But Bernard is quick to point out that there is no prohibition on additional use of these devices for training. “What few people realize is that although the maximum hours credited towards your certificate total is fixed, logging additional hours may in fact assist you with being more prepared for the aircraft portion of your training, and potentially allow you to finish closer to the actual minimum flight hours specified in the regulations for a particular certificate or rating.”
To help illustrate this point, let’s say you need 35 hours of flight training under a part 141 school to get a private pilot certificate. You can get credit for 5.25 of those 35 hours in a BATD. But let’s say you go beyond that. Maybe you even log 35 hours in the BATD. That might seem like a lot, but that extra time in a lower cost ground trainer may actually help you stay on target with the remaining 29.75 flight hours required. So even if you wound up having 35 hours of aircraft time and 35 hours of BATD time, that’s still way less total flight time (and cost) than what the average student pilot acquires while pursuing a private certificate — which is about 75 hours.
“Let’s not forget the advantages of using an ATD,” adds Bernard. “You can still ‘fly’ when the weather is bad, and practice emergency procedures and other difficult maneuvers that are risky to accomplish in the aircraft. Additionally, when a student is struggling with a particular concept or task, flight instructors in an ATD have the unique ability to hit the pause button, reset the trainer for the procedure or task, and provide extra guidance and encouragement which is difficult to do in the confines of a noisy, crowded, and busy aircraft.”
The Future of Flight Simulation
As with all things in aviation, change is inevitable, and the ATD arena is hardly an exception to that rule. “One of the features I’m most excited about — and which has shown significant improvement in recent years — is with cockpit visuals,” says Bernard. “The visuals in today’s ATDs have never been so good. They really put you in the zone of actually flying in the aircraft.”
Another up-and-coming area for ATD and FSTD technology is virtual reality, boasting much broader visuals and 3-D imaging. Evidence of VR’s growing popularity can be found at events like FlightSimCon, which at this year’s convention in Hartford, Conn., touted several trainers using VR goggles. While integrating VR technology into an approved ATD is still a ways off, its potential is extremely exciting for the industry.
Whether you’re an aviation novice, or experienced veteran, here’s the bottom line: Using aviation training devices is effective, efficient, and provides pilots and instructors with a superior learning and training environment. But more importantly, these instruments are proving themselves to be true catalysts for a safer NAS.
If you have questions on ATD regulations, policy, or guidance, or if you seek to incorporate an ATD into your flight training program, please read AC 61-136A and, as needed, contact your local Flight Standards Office for further assistance.
Tom Hoffmann is the managing editor of FAA Safety Briefing. He is a commercial pilot and holds an A&P certificate.
This article was originally published in the November/December 2017 issue of FAA Safety Briefing magazine.