The Society of Aviation and Flight Educators (SAFE) is asking all pilots to comment on the FAA’s new Notice of Proposed Rulemaking (NPRM) that proposes increasing loggable simulator time toward an instrument rating from 10 hours to 20 hours.  An earlier effort to implement the change with an FAA direct-to-final rule failed due to adverse comments from just two pilots.

The comment period on the Aviation Training Device Credit for Pilot Certification NPRM ends July 16.  Comments may be submitted to FAA Docket Number FAA-2015-1846  via the internet at, or by mail to the FAA, DOT, 1200 New Jersey Avenue SE, Room W12-140, West Building Ground Floor, Washington DC 20590-0001.

“Because the idea of additional simulator time is so widely supported in the flight instruction community, SAFE and the FAA had expected the direct-to-final rule to sail through and be in effect by now,” said SAFE interim executive director John Dorcey.  “Unfortunately, just two pilots out of all those who commented didn’t like the idea, and that’s why we’re urging pilots to comment favorably on this NPRM.”

Direct-to-final rules are commonly used when a change in regulations is not expected to generate any opposition.  Under Federal rulemaking regulations, though, even one adverse comment is enough to defeat a direct-to-final rule.  The NPRM issued last week is almost identical to the original proposal but is not subject to that limitation.

SAFE has for years pushed for extra simulator time to be loggable toward an instrument rating.  In its comments on the first implementation attempt, SAFE then-executive director Doug Stewart said “these devices can consistently enhance student retention of lesson material, increase student confidence and reduce accident…rates.  (Also), we must find a way to contain the training costs without sacrificing safety or operational utility.”

SAFE represents nearly 1,000 of the nation’s top flight instructors and aviation educators and works to create a safer aviation environment by supporting aviation educators with mentoring opportunities, educational resources, and other benefits; inspire professionalism through promotion and recognition of excellence and enhanced education; represents aviation educators through interaction with the aviation industry and government and promotes learning in all areas of aviation.

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