In official comments submitted July 8 to FAA NPRM Docket FAA-2015-1846, Notice 15-03, the Society of Aviation and Flight Educators (SAFE) supported the Agency’s proposal to increase the maximum time allowed in an Aviation Training Device (ATD) toward an instrument rating.

The Society cited research showing that use of such advanced simulators actually speed up the learning process by allowing students to concentrate on areas where more understanding and practice is required.  It said that ATDs provide the opportunity to learn procedures first in a benign situation, then move into an aircraft where they will experience not only the normal cockpit environment but real flight variables as well.

SAFE also supported the FAA proposal to amend FAR 61.65(i)(4) to eliminate the requirement for use of a view limiting device (hood) in modern simulators. “Modern ATDs simulate the cockpit environment very well,” said SAFE interim Executive Director John Dorcey.  “Most students quickly become so immersed in the ATD experience that there is no need for a view limiting device to further focus them on the instrument panel.”

SAFE was the first GA organization to raise the alarm in December 2013 when the FAA rescinded multiple waivers allowing increased simulator time and rallied pilot and instructor support for the current NPRM that would once again allow the extra 10 hours of ATD time.

The comment period on FAA-2015-1846, Notice 15-03 ends July 16.  SAFE has urged pilots to support the change.