aopa.orgWhile the proposed changes are wide ranging, the most significant for the general aviation community include increased use of aviation training devices (ATDs) for maintaining instrument currency, the option to use new technically advanced aircraft instead of older complex or turbine aircraft for single-engine commercial pilot training, and giving credit for hours accumulated during sport pilot training toward earning a recreational or private pilot certificate. The NPRM also includes many clarifications of existing regulations.

The proposal reduces the number of tasks pilots must perform to meet instrument recency requirements in an ATD. It also removes the requirement to have an instructor present when using an FAA-approved simulation device to meet requirements for instrument recency. That brings ATD recency requirements into alignment with in-aircraft recency requirements, where no instructor is needed. It also builds on the FAA’s recent decision to allow pilots to complete more of their instrument training in an ATD. In the NPRM, the FAA noted that “ATD development has advanced to an impressive level of capability.”

The NPRM also would make changes to flight instructor certification and renewal of Part 141 certificates for flight schools. Under the proposed rule, instrument-only instructors would no longer be required to have category and class ratings on their flight instructor certificates to provide instrument training. In addition, a flight instructor rating based on military competency could simultaneously qualify for the reinstatement of an expired FAA flight instructor certificate, benefiting veterans whose certificates lapse while they are serving on active duty. For Part 141 flight schools, the NPRM would make it possible to count the graduates of “special curricula” courses toward certificate renewal requirements.

I have to wonder if this proposed new rule offers any insights to how Part 107 will set up training requirements. In particular, I think that a tremendous amount of UAS training could be done with simulators. There a lot of pluses for that approach:
  • Standardized
  • Proven learning strategy
  • Self-paced
  • Web-based so geographically agnostic
  • Useful for both content and physical competency
  • Easily administered
  • Scalable
Definitely something that the insurance industry should consider getting behind.



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