If you have ever used the Practical Test Standards (PTS) to train, teach, or evaluate in connection with certification activities, you might recall that the PTS for certain qualifications includes an Appendix called “Task vs. Simulation Device Credit.” In addition to some basic instructions, this Appendix includes a chart that describes which Flight Areas of Operation/Tasks qualify for simulation credit and specifies the required flight simulation device level.
Now take a look at the Airman Certification Standards (ACS), which have replaced the PTS for the private pilot and commercial pilot certificates and the instrument rating for the airplane category. In these documents, as well as in future PTS-to-ACS conversions, the chart is no more. Instead, you will find that Appendix 8 (standard across all ACS documents) offers a detailed text explanation of using flight simulation training devices (FSTDs) and Aviation Training Devices (ATDs) for pilot certification for airplane single-engine, multiengine land and sea.
Why the change? Simply stated, the FAA realized that the PTS-style chart approach is a good example of providing information, but it wasn’t sufficient to fully address the issues at play in using FSTDs and/ or ATDs in training, testing, and checking events.
When reviewing the ACS to determine the task and standards that pilot applicants must accomplish, there is no substitute for reading the entire document to ensure that you fully understand the requirements and limitations when using FSTDs and/or ATDs. We cover this topic in detail elsewhere in this issue, but here’s a quick overview of the information you’ll find in ACS Appendix 8.
Use of Flight Simulator Training Devices
According to 14 CFR part 60, a Flight Simulator Training Device is either a full flight simulator (FFS) or a Flight Training Device (FTD). This rule provides specific definitions for FFS and FTD, and prescribes the initial and continuing qualification and use of all FSTDs used for meeting training, evaluation, or flight experience requirements for flight crewmember certification or qualification.
Another regulation, 14 CFR section 61.4, states that each FFS and FTD used for training and credit for any training, testing, or checking requirement must be qualified and approved by the FAA for three things: (a) the training, testing, and checking for which it is used; (b) each maneuver, procedure, or crewmember function; and (c) its representation of the aircraft. To accomplish the requisite FSTD qualifications, the FAA’s National Simulator Program (NSP) qualifies them as Level A-D FFSs and Level 4‒7 FTDs.
In general, FSTDs are used in the air carrier world or for training that is type specific. The FAA permits use of an FSTD for completion of the practical test only when it is accomplished in accordance with an FAA approved curriculum or training program.
Use of Aviation Training Devices
Now let’s look at devices you are more likely to see in the GA training environment. 14 CFR section 61.4(c) states that the Administrator may approve a device other than an FFS or FTD for specific purposes.
Under this authority, the FAA’s General Aviation and Commercial Division approves aviation training devices (ATD) by issuing a letter of authorization (LOA) to an ATD manufacturer. The LOA, which is valid for five years, approves an ATD as a basic aviation training device (BATD) or an advanced aviation training device (AATD). The LOA also specifies the amount of credit a pilot may take for training and experience acquired in the device. Any pilot using ATD time to meet experience or certification requirements should retain a copy of the LOA.
For the definitions, please read Advisory Circular (AC) 61-136A, FAA Approval of Aviation Training Devices and Their Use for Training and Experience. AC 61-136A also provides information and guidance for the required function, performance, and effective use of ATDs for pilot training and aeronautical experience (including currency). Please note, however, that ATDs cannot be used for practical tests or to meet minimum experience or training requirements for an aircraft type rating. (FAA Safety Briefing NovDec 2017)