The new rule, which doubles the amount of approved ATD time currently allowed, was strongly advocated for by AOPA and much of the flight training industry.
The final rule published April 12 restores the amount of approved ATD time pilots counted toward the instrument rating until early 2014, when an FAA policy statement cut the hours to 10.
In December 2014, the FAA fast-tracked a rulemaking proceeding to restore the 20-hour limit—but that process ran into procedural obstacles when two adverse comments required that the FAA withdraw the rule, which it revised and resubmitted last June.
The rule allows instrument trainees to credit a maximum of 10 hours using a basic ATD (BATD) and a maximum of 20 hours using an advanced ATD (AATD). Credit, using a combination of the two, however, may not exceed 20 hours.
Allowances have been increased for Part 141 programs as well—something that will be appreciated by schools and students alike. Students training for an instrument rating in a Part 141 program may credit no more than 40 percent of training toward total time requirements in an AATD. The limit for using a BATD will increase to 25 percent of total time requirements, and the limit for the combined use of both types is 40 percent. Previously, Part 141 training time was limited to 10 percent for either type, or both combined.
The now-final rule drops a requirement for students to wear a view-limiting device when logging instrument time in an approved ATD, if the student is operating solely by reference to the instruments and the device is representing instrument meteorological conditions.
“AOPA pushed strongly for all of these changes,” said David Oord, AOPA vice president of regulatory affairs. “The new provisions will benefit the safety of training while significantly reducing the costs associated with it. Training using simulation has proven to be safe, effective, and economical for commercial aviation and we support its increased use in GA flight training.”
The FAA said it gave weight to comments stressing the importance of instrument-rating students being able to learn emergency procedures “using meaningful repetition” until mastery of the skills can be confirmed.
“AOPA supported this view, stating that simulator training for an instrument rating allows instructors to provide a safer, more effective training experience,” the final rule notes.
The FAA added that persons who use the new provisions “will do so only if the benefit they will accrue from their use exceeds the costs they might incur to comply.” Given the high use of ATDs in the training industry, “the change in requirements is likely to be relieving.”
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