First we had 20 hours, then 10, then back to 20, then 10 again, and finally back to 20. Confused? Yes, us too.
So what’s going on in the FAA? Actually, it’s kind of interesting. CRAFT had a Letter of Authorization (LOA) that allowed us to use the simulator for 20 of the required 40 hours of IFR instruction. In early 2014, the Legals people in the FAA made a determination that the sim could only be used for 10 hours. This new time restriction was supposed to go into effect on January 1, 2015.
But in October of 2015, we were told that the sim had been restored to the full 20 hours. Apparently, the FAA Standards people didn’t agree with the people in FAA Legals. Standards recognized the value of the simulator but Legals, even though they might agree on the value, pointed out that the regulations took precedence. This isn’t unusual in the FAA. Each FSDO seems to have more autonomy than you would expect from a federal institution. This time, Legals put their foot down: the regs would have to be followed to the letter.
Fair enough, said the Standards people, we’ll just make it a new rule, and in December 2014, they did exactly that. Because they felt it was important, they using an accelerated rulemaking process, instead of going through the 9 to 12 month process it normally takes for a new regulation to go into effect. There was a catch, though. The normal rule process allows for comments to be made before the rule is adopted, while the accelerated process allows for comments to be made after the rule goes into effect, and all it takes is for one credible adverse comment to stop the whole thing. From the entire United States of America, only two comments were made, and only one was deemed credible, largely because it wasn’t anonymous.
That one comment, by the way, was simply one pilot’s opinion with no empirical evidence or research, but all it takes is one adverse comment to derail the new rule. Because of that single comment, the original determination by Legals that the sim could only be used for 10 hours went back into effect, and now we are full circle. It’s important to note that this rule only applies to IFR instructional time and doesn’t affect any other simulator advantage.
This is not big deal for us and for a couple of reasons. Number one, this is a temporary situation. The FAA simply switched gears and used the normal rule-making process, which takes a little bit longer, a period of months instead of days However, the FAA is fully committed to the value of training devices, and they are going to get those 10 hours back.
The second reason goes back to what we at CRAFT have been saying from the very beginning: the value of the sim is not in the hours you can substitute but in the transfer of knowledge. The hours are a nice perk but the important thing is how thoroughly you can learn before you get into the actual airplane, and that can’t be taken away by anybody. We don’t teach in the airplane; we teach in the simulator and we practice in the airplane.
We are absolutely delighted that the allowed instrument time has been finalized at 20 hours, but it doesn’t really make a difference in our day-to-day operations here. Our basic goal is to train good pilots in as little time and cost as we can. Even if the FAA decided to remove all the hourly credit it now allows, the sim is still your best bet in making the most effective use of your time and money.