Two negative comments have felled a regulation that would have allowed aspiring IFR pilots to log more training time in an approved aviation training device (ATD).
The FAA has withdrawn a final rule that would have authorized instrument pilot trainees to obtain credit for up to 20 hours of instrument time in an approved ATD under Part 61 or no more than 40 percent of total training hour requirements for an instrument rating under Part 141. The final rule was published on December 3 last year and would also have eliminated the requirement that pilots logging instrument time in an ATD wear a view-limiting device.
Because FAA regulations allow a final rule to be issued instead of a notice of proposed rulemaking, any negative comments on the final rule prevent its implementation. Two of the 20 comments were negative.
One ATP and CFII wrote: “ATDs are firmly on the ground and no amount of graphic imagery or display setup, even in full-motion simulators, ever causes a pilot to lose consciousness of that fact. Consequently, pilots do not experience the fear that accompanies real-life emergencies, or the sensory inputs that come with icing and thunderstorm contact.” This commenter also wrote: “Flight simulators are wonderful but very limited devices. Instead of increasing a pilot’s skill, however, they have come between real-world flying and desktop flying. They have increased reliance on screens and autopilots and diminished the pilot’s sense of being in charge of the aircraft and the flight. Stalls, thunderstorms and icing are the greatest dangers, yet ATDs cannot depict these accurately or realistically. Furthermore, instructors rely less and less on real-world experience because they themselves have not regularly come into contact with [the real world]. I am disappointed at how often instructors are loath to stall an aircraft or to enter turbulence. I think this is the wrong direction for training to go. There is generally no ‘reset’ after a crash.
“It seems to me that the industry at large always diminishes the importance of safety and increases the importance of costs whenever training requirements are considered. I believe one hour in any aircraft is worth ten in front of an ATD. The cost of a lost aircraft and all its crew is not worth the imagined savings gained from flying imaginary aircraft in imaginary environments.”
The other negative comment stated: “Highly recommend the use of such devices, but in dealing with pilots and humans from both a CFII and an air traffic controller [perspective], I caution too much of a reduction. Proceed with appropriate caution and understand the risk involved. As a quality control manager, [I see] an increase in poor piloting skills and decisions.”
Support for Rule
The Society of Aviation and Flight Educators (Safe) rebutted the first negative comment: “We respect [his] right to opposing opinions regarding the proposal but we must point out that all of his comments reflect personal opinion, lack substantiation and are contrary to current adult education doctrine regarding the use of training devices. In fact, several of his points are well contradicted by the extensive body of current research into the use of aviation training devices.”
The society noted that modern ATDs such as those made by Redbird “replicate sensory inputs with an incredible degree of accuracy” and that instructors do need to incorporate all of a student’s senses in learning. But instructors also have to teach students to “ignore sensory inputs,” for example, at night, on narrow or sloping runways, landing on glassy water and in IMC. “We believe ATDs can provide the student with excellent opportunities to focus on learning the correct procedures for these kinds of operations without interference from conflicting or adverse sensory inputs before being exposed to them in the live flight environment where confusion can occur between the ‘butt’ and the brain until training and experience overcome the sensory input.”
Simulation has been proven to speed learning, enhance student retention, boost confidence and reduce accidents, both during training and in normal operations. The commenter claims that “ATDs fail to convey fear associated with real-world flying,” Safe wrote, adding: “Scaring students should never be the goal of flight training whether on an ATD or in the air. We would point out that ATDs have proved effective in practicing certain emergencies that are simply too dangerous to practice in the air and building pilot confidence in being prepared to handle such ‘worst case’ situations should they occur for real.”
As to the commenter’s statement that the aviation “industry is willing to trade safety for cost savings,” Safe added, “This is outlandish and unsubstantiated. Successful industries value safety highly, understanding that it has a major impact on public perception and on the bottom line. If ATDs did not result in better trained, safer pilots, and in a cost-effective manner, they would not be used extensively by the military, the airlines, corporate operators and flight schools.”
Jerry Gregoire, founder of Redbird Simulations, told AIN, “We believe any action that restricts students from taking full advantage of training technologies is a serious mistake. It is hard to believe that inadvertent language followed by this botched effort to solve the problem inside the FAA leaves us where we are today. The fact is that the major flight training organizations across the country and around the world are using Redbird and other simulators because they work.”
Gregoire is dismayed that just one negative comment could slay the FAA’s final rule. “The notion that one named flight instructor who teaches without using simulators created a procedural reversal is just unimaginable.”
The only way now for the FAA to adopt the training times in the rescinded final rule is to go through the rulemaking process, which could take years. And the industry will have to go back to the previous unwieldy system of FAA inspectors issuing waivers for additional loggable training time in ATDs. “I hope the FAA will expedite the solution to this problem it created,” Gregoire said.
The Aircraft Owners and Pilots Association has asked the agency to expedite the rulemaking process. “We believe that ATD training is a critical component of earning an instrument rating because it creates a more efficient and effective training experience,” said AOPA director of regulatory affairs David Oord. “Through simulation, students can fly many more approaches of all types, safely experience critical instrument failures and emergencies and practice decision-making under challenging conditions set by their instructors. At the same time, ATD training is far less expensive than equivalent time in an airplane, and reducing the cost of training and certification is vitally important to our members and the growth of general aviation.”
According to an FAA spokesman, “Withdrawal of the direct to final rule was necessary to comply with 14 CFR part 11, which governs the FAA’s rulemaking procedures. The withdrawal of the rule was an administrative requirement and not reflective of a change in philosophy concerning the use of aviation training devices. The FAA is in the process of a rulemaking project titled Aviation Training Devices; Pilot Certification, Training, and Pilot Schools; Other Provisions. Any future rulemaking activity would need to take into account the withdrawal of the direct to final rule. However, the FAA is still actively engaged in rulemaking that would amend crediting provisions for ATDs as described above.”