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“Adverse comments” have derailed a final rule that would have permitted wider use of aviation training devices for instrument flight training in the U.S.

On Jan. 15, the U.S. Federal Aviation Administration (FAA) announced that it is withdrawing a direct final rule that was intended to “relieve burdens on pilots seeking to obtain aeronautical experience for an instrument rating.” Published on Dec. 3, 2014, the rule would have allowed pilots to credit up to 20 hours of instrument time in an ATD toward an instrument rating under part 61 of the Federal Aviation Regulations. Pilots in part 141 instrument programs would have been able to complete up to 40 percent of their required training hours in an ATD. The rule also would have eliminated the requirement for trainees to wear a view-limiting device while training in an ATD.

ATDs are simulation training devices that, while approved by the FAA, are less complex than either full flight simulators or flight training devices (FTDs). Consequently, they’re also less expensive and more readily available than simulators and FTDs — and are particularly cost-effective for helicopter instrument training.

The FAA received a total of 20 comments on the rule, the majority of which were strongly supportive. However, because the agency issued its proposals as a direct final rule, rather than through the normal rulemaking process, it was obligated to withdraw the rule if it received adverse comments. The adverse comments that derailed the rule appear to have come from one commenter in particular, an Airline Transport Pilot-rated instrument flight instructor who described simulators as “very limited devices” that “have come between real-world flying and desktop flying.”

“ATD's 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,” the commenter stated.

The Society of Aviation and Flight Educators (SAFE) and the Aircraft Owners and Pilots Association (AOPA) both submitted lengthy comments in response to the dissenting commenter.

“We respect [the commenter’s] 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,” stated SAFE.

“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 proven very 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,” SAFE added.

“The comment offers a solitary opinion that is demonstrably inconsistent with significant and longstanding practical experience that has established as fact the economic, environmental, and safety value of allowing a maximum of 20 hours of instrument time in an approved aviation training device toward the requirements for an instrument rating,” stated AOPA, urging the FAA to consider the dissenting comment as “‘insubstantial’ and, accordingly, not ‘adverse’ under the criteria that govern this type of rulemaking.”

However, the FAA did accept the comments as adverse, also noting another commenter’s concerns that the increases in time/percentage of training contained in the direct final rule were too great. As a result of this withdrawal, the current regulations remain in effect, which permit pilots to credit up to 10 hours of instrument time in an ATD toward an instrument rating under part 61, or up to 10 percent of their total required flight time under part 141.

The FAA notes that withdrawal of the direct final rule does not preclude the FAA from issuing rulemaking on the subject in the future. It also notes that the regulations do not place a limit on the amount of time that a person may actually train in an ATD, allowing operators to continue to use ATDs to improve pilot proficiency and potentially reduce the overall time required in an aircraft.

The complete statement of withdrawal and associated documents are available online at regulations.gov.

I totally agree about real world, but saying you are going to allow more computer devices, and then backtracking isnt a good policy. The FAA already makes things difficult for everyone. Fixed wing vs Rotary is still pretty crazy when it comes to the FAA.

After renewing my CFI for the 5th time today, I FINALLY have been asked helicopter specific stuff (in an elective).

Haha. It was a quote from the source article