FAA Recends AATD Direct Final Rule

flyslow_va

Well-Known Member
The FAA withdrew a direct final rule January 15, 2015 which would have permitted up to 40% of flight training towards an instrument rating be conducted in an aviation training device due to two comments received that were negative against the rule.

One was from “Anonymous” and the other from a CFI. Both comments can be read at regulations.gov. Here links to the two negative comments.

http://www.regulations.gov/#!documentDetail;D=FAA-2014-0987-0017

http://www.regulations.gov/#!documentDetail;D=FAA-2014-0987-0007

SO what does this mean for us? We are limited to 10% of the flight time required per part 141. So we are back to 3.5 hours permitted per regulation for 141 students (reference appendix C which states "Credit for training in an approved aviation training device cannot exceed 10 percent of the total flight training hour requirements of the course or of this section, whichever is less."

For part 61 students, it's not so terrible, you can use up to 10 hours of training with an instructor in an AATD towards your instrument rating per 61.65(i)

It also means we have to continue to use a view limiting device when using an AATD for flight training credit per 61.65(i)(4). You have been doing this right!

Needless to say, we are very disappointed that this was withdrawn but it goes to show that one person really can make a difference as the final rule was withdrawn because of a comment by a CFI who voiced concern that students did not receive adequate "sounds and feel" that he said are "vital to recognizing unusual attitudes.

Here is the link to the Federal Register Notice.

http://www.gpo.gov/fdsys/pkg/FR-2015-01-15/pdf/2015-00553.pdf

The FAA will now go into a prolonged rulemaking process and this will take several years to change the rule.
 
This is ridiculous. If you saw our two students soloing today, you'd understand sim-focused training WORKS.

This guy needs to get the "sounds and feel" of the 21st century...or even the 20th.
 
I agree 100% with the feds on this. An airplane is way more dynamic than a sim. Sims are great for later on when you are learning procedures/ getting a type or what not, but for basic instrument work, uh uh. And that goes double for a kmart sim instead of a level D.
 
The rule wasn't going to eliminate airplane training, just decrease the amount needed.

When you're learning something new, its great to focus on JUST that new skill, get good at it, then take it to the airplane. Leaning something new in the airplane first is a waste of fuel, money, airspace, stress...
 
The rule wasn't going to eliminate airplane training, just decrease the amount needed.

When you're learning something new, its great to focus on JUST that new skill, get good at it, then take it to the airplane. Leaning something new in the airplane first is a waste of fuel, money, airspace, stress...
I don't doubt it. I just do not want 40% of the time accredited to it. Maybe the initial 5 hours.
 
This looks like it's rescinding the Part 141 requirement.

They are still allowing 20 hours of sim for Part 61, aren't they? We just discussed this on another thread and I have the link here somewhere...
 
Well our LOA still allows better anyway. I think part of what the FAA was trying to do was weed out all the crappy old sims that technically qualified as AATD, then rewrite the rules in light of higher quality standards.

Out of curiosity, Itchy, have you ever used an FMX sim?
 
Well our LOA still allows better anyway. I think part of what the FAA was trying to do was weed out all the crappy old sims that technically qualified as AATD, then rewrite the rules in light of higher quality standards.

Out of curiosity, Itchy, have you ever used an FMX sim?
No idea what an FMX sim is. Various sims from FS and other vendors. Some level D. Oh, and a frasca sim back in the early 80's.
 
Until you take the guy and put him in real IMC for the first time. I've yet to see a sim simulate that.

I dunno - honestly, the sim has always been way freaking harder for me to fly than the real thing when it comes to instrument flying. The sims are always twitchy and unstable, if you can fly the medallion box to minimums I think you can probably actually fly in the clouds just fine.
 
I dunno - honestly, the sim has always been way freaking harder for me to fly than the real thing when it comes to instrument flying. The sims are always twitchy and unstable, if you can fly the medallion box to minimums I think you can probably actually fly in the clouds just fine.
..and most sims don't provide bodily sensation feedback. That has both a positive and negative result. The positive is that the scan has to be better; the negative is that you are not fighting your bodily sensations.

The point of the sim, though, is that, as the saying goes, an airplane is a pretty bad classroom. Having trouble keeping the needles centered on the ILS? In 5-10 minutes, with a sim, the CFII can stop the sim, discuss error with you, "rewind" your position to the last turn before intercept and you can work on it multiple times. In the same amount of time in an airplane, you can fly around and, depending on the airspace, maybe get all the way up to that last turn before intercept.

I'm not sure why the "anti" group is acting like a sim is a replacement for the airplane (actually I do, but that's off-topic). The sim is a training supplement to the airplane. It's not about flying nothing but a sim and then going solo into IFR flight. It's about having a more effective training environment.
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The FAA will now go into a prolonged rulemaking process and this will take several years to change the rule.
Maybe not. The FAA clearly wants the rule. They can republish it as a proposed rule fairly quickly) it and the supplementary material is already written) and give it an acceptably small comment period (say, 30-60 days). Assuming there are not a bunch of solid negative comments that convince the FAA it's a bad idea, the most time-consuming part will be writing up the responses to the negative comments.
 
Been teaching Instrument students for almost 10 years. 3000+ dual given in an airplane, and probably another 500 dual given in a Simulator. The letters above are bogus. How can you simulate a failing gyro in an airplane, Icing or thunderstorms, Shoot approaches all over the world, let students do something that will actually kill them that in an airplane you will never see, or let a student run an airplane into the ground because they forgot their minimums.

The airplane is a poor trainer for real IFR experience. (Up north here we cant get IMC time due to ice) so its always VFR, under the hood where your brain can still receive sensory information without realizing it.

to say a simulator does not feel real? I actually had students in the airplane reach up to find the pause button after being in the Sim for a while and had a student cover his face and go in the brace position in the Sim when he forgot to turn at the FAF resulting hitting a mountain.

Also you can shoot 10 approaches in an hour in the Sim, vs 2 or three in the airplane if chasing the needles is the problem.


I could go on and on. But sounds like the two people who wrote these letters never had real quality sim time and is taking it out on the rest of us!
 
Until you take the guy and put him in real IMC for the first time. I've yet to see a sim simulate that.

How many of the puppy mills don't even allow for flights in IMC? I know when I did my instrument ticket at riddle in 2008, only a handful of instructors would even consider taking a student in IMC.
 
Even in the late '90s the aversion to allowing students (even with instructors) in actual IMC was starting to become prevalent. Most of the Part 141 schools were starting to prohibit it (along with other stupid rules like providing a list of only a few approved airports for cross countries). So you won't let them practice in a sim, and you won't let them practice in real IMC, so the only thing left is foggles or a hood? Yeah, that's ideal. :rolleyes:
 
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