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NAFI Asks Members to Comment on FAA Simulator Training Change
KALAMAZOO, MI  (January 22, 2014) NAFI is asking its membership to contact the FAA to provide comments about the FAA's abrupt change to training standards regarding flight simulators for the instrument rating. FAA recently revised the standards to reduce the number of simulator hours that may be logged toward the rating. NAFI, along with other aviation advocacy groups, and manufacturers of FAA-Approved Training Devices, assert that simulators are useful and cost-efficient training tools.

Using your perspective as an instructor, a flight school employee or owner, an examiner or other educator, please take the time to send your comments to the FAA. Respectful, well-reasoned comments that express personal experience are most persuasive and carry more weight than invective or anger. You can comment by clicking here. When the page opens, you should see a green box on the right side of the page that says "comment here." You may find it easier to compose your thoughts in a word processor then copy and paste to the comment.

Here is background on the issue from NAFI's Vice President of Government and Industry Relations Phil Poynor:

On January 2, 2014 FAA unexpectedly published a Notice of Policy Change in the Federal Register affecting the use of FAA Approved Training Devices. The announcement addresses three areas that it is seeking to correct through the policy change.

1. All approved devices must be assessed using current standards for approval:
Over the years, FAA used a number of different methods of authorization or approval for the use of various types of ground (or synthetic) trainers. Local FSDOs, individual safety inspectors and FAA HQ and perhaps others issued approvals. Many of these were issued on an ad hoc basis by evaluating individual devices without a set of national standards. In addition, since authorizations and approvals were granted by numerous offices with little coordination, FAA has admitted that it really doesn't know how many or what authorizations have been granted. The issuance of AC-61.136 in 2008 provided a uniform set of standards applied by one office for the approval of these devices and standardized the naming of the various types of devices. Since AC-61.136 became effective, all approvals of training devices below Level 4 FTDs have been granted by AFS-800, so it is now attempting to inventory and catalog all outstanding LOAs that have been issued. This policy change seeks to bring all of these devices into a common approval and oversight system that is based upon the standards of AC-61.136.

2. Contains an expiration date:
Prior to publication of AC-61.136, many of the ground trainer and training device approvals did not include an expiration date. Most of these devices were subject to obligations on the manufacturers and operators to ensure that the device was properly maintained and that annual reports were submitted to the FAA regarding the status and continued use. FAA stated in the notice that it is unclear whether these requirements have been met. The FAA is addressing these issues by establishing a five year lifespan for all new LOAs and including a requirement that, as part of that renewal of the LOA, that the operator states that the device "continue(s) to maintain its performance and function without degradation." This requirement will assure that FAA is aware of all devices that are approved and that the device maintains continued efficacy for providing credited (loggable) flight training time.

3. Reflects current regulatory authorization:
This third item contains the most dramatic change of policy. As ATDs have developed technically, they have received greater allowance for credit for loggable flight instruction time. Since July, 2008 FAA has been approving devices in accordance with AC-61.136. Depending upon the capabilities and performance of an individual device, these approvals have included as many as 20 hours toward an Instrument Rating under Parts 61 and 141 (and 30 hours under Part 142). In a 2009 rulemaking, FAA included specific limits on the amount of flight time in an ATD that may be included toward an Instrument Rating. 14 CFR 61.65(i) now specifies that in Part 61 or 141 training, a maximum of 10 hours of instrument instruction is loggable. However, under Part 141, there is an additional limitation that we feel likely to apply to most operators: a Part 141 operator may only apply FTD time to a maximum of 10 percent of the total course time. Since we believe most part 141 schools have 35 hour instrument rating courses, that means that they would be limited to only 3.5 hours of loggable time using an ATD.

With the surprise issuance of this Policy Notice earlier this month and a comment period that closes February 2, we are very short of time to properly respond. Therefore, I want to thank all of you for taking the time to peruse this discussion and encourage you to get involved in the process by letting FAA benefit from your first-hand knowledge and experience with the effective use of aviation training devices.

Phil Poynor,
Vice President of Government and Industry Relations

About NAFI -

Founded in 1967 the National Association of Flight Instructors (NAFI) is an association of nearly 4,000 active flight instructors and is committed to developing excellence in member instructors and member flight training organizations (FTOs). NAFI serves as a voice for flight instruction within the flight training industry and with federal agencies. NAFI members influence active pilots daily; pilots training to advance their skills with new ratings or certificates and students working to become pilots. NAFI members work at FBOs, flight schools, universities, in corporate flight departments, in the military and as independent instructors. NAFI staff works with industry and government on a daily basis and NAFI staff and members help shape direction of flight instruction. For more information visit NAFINet.org or call 866-806-6156.