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FAA Reforms Several Flight Training Rules: Agency removes instructor requirement when using ATDs for instrument currency and addresses complex airplane availability, among other certification and reforms.

The FAA on June 27 issued a long-awaited final rule revising several of its familiar regulations on pilot certification, training and currency. The new rules stem from a May 2016 set of proposals and are designed "to reduce or relieve existing burdens on the general aviation community," the FAA said. One batch of the new rules are current as of July 27, 2018, and another becomes effective on August 27, 2018. Other changes are slated to go into effect on November 27, 2018, and December 24, 2018.

One of the biggest and most beneficial changes for many pilots will allow them to use a flight simulator to log instrument currency without the need to have a flight instructor present. The new rules allow an instrument-rated pilot to use any combination of aircraft, full-flight simulator (FFS), flight training device (FTD) or aviation training device (ATD) to satisfy the recent experience requirements. Another change accommodates using technically advanced airplanes (TAA) as alternatives to complex single-engine airplanes for the commercial pilot training and testing requirements. That change also adds a new definition of TAA. Other new rules expand the ability of second-in-command pilots to log time in both Part 91 and 135 operations and address sport pilot training.

The new rules on using a simulator will reduce the cost of pilot maintaining IFR currency, the FAA says. The agency made three basic changes to the instrument currency rules in FARs 61.51 and 61.57: First, it removed the requirement to have an instructor present when accomplishing flight experience requirements for instrument recency in a simulator. A second change reduces the frequency of instrument recency flight experience accomplished exclusively in ATDs from every two months to every six months. The third change removes the threehour flight time requirement when accomplishing instrument recency flight experience in ATDs.

As discussed in our June 2018 issue, the FAA earlier this year changed its policy to no longer require a complex airplane--one with controllable-pitch propeller, flaps and retractable landing gear--for the commercial pilot-airplane or flight instructor-airplane certificates. That policy change created the need to amend the underlying regulations on a commercial pilot applicant's aeronautical experience, which the FAA has addressed in the new rules by adding the TAA to the allowable mix.

To do so, the FAA amended FAR 61.129, dealing with commercial pilot-airplane applicants and required aeronautical experience, to allow any combination of complex airplane, turbine-powered airplane or TAA. The agency's definition of TAA, reproduced in the sidebar above, expands the previous understanding of what a TAA is, perhaps to eliminate steam-gauge airplanes--even if they are equipped with a two-axis autopilot, IFR-approved GPS and a moving map display, the three items formerly required. The new definition is designed to "provide flexibility by allowing the FAA to accommodate future technologies that do not necessarily meet the confines of the regulatory requirements for a TAA, the FAA said in its rulemaking.

The new rules also make changes in the sport pilot arena. Under existing regulations, training provided by a sport pilot instructor might not be applicable toward a higher certificate or rating. Under the new rules announced in June, however, FAR 61.109 is amended to add a new subsection, (1), Permitted credit for flight training received from a flight instructor with a sport pilot rating. Under the new subsection, a sport pilot may credit flight training "received from a flight instructor with a sport pilot rating toward the aeronautical experience requirements" of the private pilot certificate when the flight training is accomplished in the same category and class of aircraft for which the rating is sought and the flight instructor with a sport pilot rating was authorized to provide the flight training.

The flight training must include either "[draining on areas of operation that are required for both a sport pilot certificate and a private pilot certificate" or, for airplanes with a VH (maximium level-flight cruising speed) greater than 87 knots CAS, "training on the control and maneuvering of an airplane solely by reference to the flight instruments, including straight and level flight, turns, descents, climbs, use of radio aids, and ATC directives." To be eligible to apply this instrument training, it must be provided by a flight instructor with a sport pilot rating (CFI-S) who holds an endorsement required by FAR 61.412(c), which is another new rule.

As you might expect, aviation organizations lauded the FAA's new rules and their potential to help save pilots money in meeting their training and currency needs. "Making aviation less costly is fundamental to AOPA's mission, which is why we pursued these changes that will save the general aviation community more than $100 million over the next five years alone and help to make pursuing and advancing a pilot's certificate more accessible to everyone," said AOPA President Mark Baker.

"This is a long-anticipated rulemaking package with many important fixes and updates for GA flight training," said Experimental Aircraft Association Government Relations Director Tom Charpentier. "We are especially pleased that the FAA accepted our recommendation to allow nearly all time with a CFI-S to count toward higher levels of pilot certification. This will greatly enhance the value of the CFI-S rating."

A copy of the FAA's final rulemaking document, in Adobe's Portable Document Format (PDF), is available online at


In Advisory Circular AC 61-136A, the FAA defines an aviation training device (ATD) as "... a training device, other than a full flight simulator (FFS) or flight training device (FTD), that has been evaluated, qualified, and approved by the Administrator. In general, this includes a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit. It includes the hardware and software necessary to represent a category and class of aircraft (or set of aircraft) operations in ground and flight conditions having the appropriate range of capabilities and systems installed in the device as described" by the AC. They come in two basic flavors: basic and advanced. Approval of an ATD like the Redbird LD pictured at right is at the FAA's discretion. (Redbird's LD is FAA-approved as an Advanced ATD.)

An ATD often can be distinguished from an FFS or FTD by what it doesn't feature. Motion is one characteristic an ATD usually does not have. It usually is a fixed device; although ATDs with motion exist, that portion of their capabilities isn't FAA approved.



FAR 61.51 Pilot Logbooks--Logging Instrument Time

(g)(4) A person may use time in a full flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate or rating provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

(5) A person may use time in a full flight simulator, flight training device, or aviation training device for satisfying instrument recency experience requirements provided a logbook or training record is maintained to specify the training device, time, and the content.

FAR 61.57(d) Instrument proficiency check.

(1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of at least the following areas of operation:

(i) Air traffic control clearances and procedures;

(ii) Flight by reference to instruments;

(iii) Navigation systems;

(iv) Instrument approach procedures;

(v) Emergency operations; and

(vi) Postflight procedures.


FAR 61.129(a)(3)(ii) Aeronautical experience.

10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

(b)(3)(ii) 10 hours of training in a multiengine complex or turbinepowered airplane; or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine seaplane that has flaps and a controllable pitch propeller, including seaplanes equipped with an engine control system consisting of a digital computer and associated accessories for controlling the engine and propeller, such as a full authority digital engine control;

(j) Technically advanced airplane.

Unless otherwise authorized by the Administrator, a technically advanced airplane must be equipped with an electronically advanced avionics system that includes the following installed components:

(1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;

(2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving map using Global Positioning System (GPS) navigation with the aircraft position displayed;

(3) A two axis autopilot integrated with the navigation and heading guidance system; and

(4) The display elements described in paragraphs (j)(1) and (2) of this section must be continuously visible.
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Title Annotation:QUICK TURNS
Publication:Aviation Safety
Date:Aug 1, 2018
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