The Sim Credit Debate

“What’s in a name?” If it weren’t for the fact that Shakespeare asked the question more than four centuries ago, one might be tempted to think he was a pilot asking for clarification on an obscure FAA rule.

Take simulators, for example. Though we often refer to them by that name — an entirely reasonable act when you consider that they, you know, simulate flight — only the most high-end, multi-million dollar boxes meet the Fed’s definition of a true “full flight simulator”.

Unless you’re training to fly a high-end turboprop or jet, the infernal machine that’s making you sweat is probably not a bona fide simulator. More likely it fits into the FAA definition of either a “flight training device” or an “aviation training device”.

Confused yet?

FAA-certified simulators come in four levels, A through D, with D representing the most high-fidelity experience available. Most Level D sims cost as much, if not more, than the jet they’re simulating.

One thing all FAA-approved simulators have in common is that they are “full-size replicas of a specific type or make, model, and series airplane cockpit, including the assemblage of equipment and computer programs necessary to represent the airplane in ground and flight operations, a visual system providing an out-of-the-cockpit view, and a force cueing system which provides cues at least equivalent to that of a three degrees-of-freedom motion system.”

If you want the full scoop on certified simulators, Advisory Circular 120-40B has enough detail keep even the nerdiest among us busy.

The next step down is a Flight Training Device. Detailed in AC 120-45A, there are seven levels of FTDs, based on capability and equipment. These are the FAA-approved devices you’ll see used by general aviation training outfits. Below that are the Basic and Advanced Aviation Training Devices (see AC 61-136A). Though this is the lowest rung on the ladder, you’ll find some amazingly capable equipment in this category. The Redbird MCX, a motion-base product in the $100,000 range, is certified as an AATD.

I bring this up because for the past few months, the FAA has been trying to raise the number of approved aviation training device (ATD) hours that can be credited toward an instrument rating. The current rules allow for ten hours and the FAA is attempting to double that. The Feds published a Notice of Proposed Rulemaking, but had to withdraw it when a single negative comment was received.

The final rule would have become law, but under the FAA’s rulemaking process a single adverse comment negates a direct final rule; the agency did receive one such comment. In the adverse comment, the author claimed that pilots need correlation of all senses and use of sounds and feel to recognize unusual attitudes. The FAA pointed out that pilots need to disregard sensory perceptions and rely on instruments. “The FAA believes that training in ATDs and FSTDs, when used in conjunction with training in an aircraft, teaches an instrument student to trust the appropriate sense, vision, to successfully operate an aircraft in low visibility conditions.”

Aside from the absurdity of a single adverse comment derailing the entire process, I found myself wondering who was right, the commenter or the FAA?

I believe the answer is “both”. The Feds are correct in stating that instrument flight is based upon the notion that humans cannot keep an airplane upright in non-visual conditions using kinesthetic senses, therefore one of the most important things an instrument student must learn is to trust the instruments over his or her own feelings and senses. Simulators are very effective at that task.

D is for "darn expensive".  You know your training experience is going to cost a lot of money when the instructor is wearing a suit...
D is for “darn expensive”. You know your training experience is going to cost a lot of money when the instructor is wearing a suit…

The commenter is also right, though. Even the best Level D simulators do not fully replicate the feeling of flying a real aircraft. There’s something vaguely artificial about the way the box moves. I’m perfectly comfortable in actual instrument conditions, but there are times when the motion of the G-IVSP simulator almost gives me vertigo, even when the sim’s visuals are on and I’m flying in clear skies. For that reason, I understand the commenter’s protest. Pilots need the experience of being in the real world environment, and every hour allowed in a training device like the Redbird is one less hour a student might have exposure to actual flying.

AOPA and other GA advocacy organizations are keen to see the 20 hour rule adopted because it will lower the cost of learning to fly, and they know what I’ve been saying for years is true: the biggest hurdle to growing aviation is the cost. Fix that and everything else will fall into line.

At the end of the day, none of this should matter because every instrument rating candidate must perform to the minimum testing standards in order to pass the checkride. In reality, things are driven by money, and while I’m all for reducing the cost of training, I’ve found there are benefits both tangible and intangible to be gained by flying in a real airplane that you don’t get in even the best Level D simulators. The crowded frequencies, controller idiosyncrasies, marginal vectors, sensory overload, heat, vibration, and yes, even the unique motion of flying through actual air if not actual IMC.

When you consider that a newly minted instrument pilot’s first time in actual conditions might be (and often is) when they’re alone, it’s important that we tread carefully when it comes to changing the balance between simulated and actual flight.

  19 comments for “The Sim Credit Debate

  1. chazlloyd
    July 13, 2015 at 4:49 am

    There are abnormal conditions that can be created in all of the sims described above that cannot safely be done in an actual airplane. FTD force the student to develop a good scan. Twenty hours is a real airplane is enough to develop a instrument student”‘s sense of motion.

    Less cost is a plus but the ability the create more scenarios is even a greater benefit.

    • Graeme Hatzkilson
      July 13, 2015 at 9:25 am

      What is great about the sim is that you can set up failures, but isn’t that what the sticky note does? When I was training, and my school had no sim of any kind, my CFII used stickies to cover up the “middle” of the six pack, namely the HI and the AI. She also shut down one set of radios. At the time I was training, 10 years ago the PA28 at my club cost about $15 more than simulators cost today. What is the argument to NOT go flying?

      • July 13, 2015 at 11:07 am

        The ground-based training devices do have some advantages over real world flying. Covering instruments with a sticky note is nothing like having one wind down slowly. They’re great for procedural training, and you can put the flight on pause to discuss things while they’re still fresh. You can take stations off the air, change their ident, induce turbulence, and work in a less frenetic environment than the actual airplane. No ATC disruptions or delays, etc.

        On the other hand, the whole reason we do this stuff is to be able to fly an actual airplane in IMC. At the end of the day, the goal is not to fly a simulator but an aircraft. Can you get by without a FTD/ATD/simulator? Sure. As C McEwan said below, the real question is, what balance of simulators and actual aircraft experience will yield the best training at the lowest cost? I think the proposed changes are significant because they alter the sim-to-flight ratio from 1:4 to 1:1. I’m not saying it’s good or bad, just that it’s significant. There’s no doubt that the simulation technology has improved by leaps and bounds over the past decade.

        • Graeme Hatzkilson
          July 13, 2015 at 11:29 am

          Good point Ron. The slowly winding down and other “real world like” scenarios are critical and that 90 degree bank simulation is key too.
          most agree to the increase and value of sim. Its too bad I have a total of 0.0 hours of sim in my log book.

  2. C McEwan
    July 13, 2015 at 4:53 am

    And last but not least, there is the student. What works best for one student is not necessarily true for another. All of which adds another level of complexity to the question of which program will yield the best training at the lowest possible price.

    • July 13, 2015 at 11:10 am

      Great observation. The FAA rules are just minimums. Ultimately it’s up to the instructor to ensure the student has the skills and experience to fly safely in actual instrument conditions. If the issues are procedural or the training is something that cannot be done safely in a real airplane, a FTD might be the perfect prescription. But sometimes the issues are workload related and don’t present themselves until the stresses of real-world flight are present. A good CFI makes all the difference.

  3. July 13, 2015 at 7:50 am

    Great debate, Ron!

    Flying my A320, I’ve always been amazed at the near-reality experience of “The Box.” The only place for me where the artificial feel comes in is in taxiing, as well as the blocky CG graphics. Otherwise, the experience is quite real.

    I’m just now editing my final video interview with Qantas A380 Captain Richard de Crespigny (out at the end of this month on my blog and The 3-part transcript of his interview appears in Airways Magazine’s July, August, and September issues.) Captain de Crespigny had fascinating things to say on this very subject. He believes that, in the future, as training costs skyrocket for airlines, it will be incumbent upon pilots to train themselves using Oculus-B virtual reality headsets at home.

    Another fun project is my new novel, “Jihadi Hijacking,” which attempts to answer the virtual sim-gamers age-old question: could a sim pilot land a real airliner? It’s turned out to be quite a hoot to write and read!

    Great debate, and in the end, I agree: regardless of minimum requirements, you need as much sim as it takes to safely pass your checkride!


    • Graeme Hatzkilson
      July 13, 2015 at 9:19 am

      It would be very interesting to hear the debate about these arm chair sim pilots being able to land a real A320. While I’ve never been on the business end of an A320, I don’t believe I could do it without extensive training.

      From your novel, there really is no way to test this, is there? I suppose we can put one of these Arm Chair pilots in a level D. Has there been any experience or history with this?

      • July 13, 2015 at 11:29 am

        Good question, Graeme. To my knowledge, no. But, it’s been a very enlightening experience writing the scene from the perspective of an “armchair sim pilot” who knows nothing about actual aviation. So many little “gotchas” that happen in real life but not on sim, any one of which could mean Game Over!

      • July 13, 2015 at 11:30 am

        I bet you could land an A320 or Gulfstream a lot easier than you think, especially given a long runway. They’re stable and have a lot of automation. But honestly at the end of the day it’s still just an airplane. Put the gear and the flaps down and land it.

        Now, could you get it started? Deal with abnormalities? Program systems? Diagnose problems? No. But if someone put a Level D sim into cruise, dropped you — an instrument rated glass panel pilot — into the seat and had a “controller” vector you to a long runway, I bet you could find the gear, flaps, and visually fly it down.

  4. Graeme Hatzkilson
    July 13, 2015 at 9:14 am

    So that app on my Samsung Galaxy S6 phone called “Airline Pilot Simulator”… how many hours can I use from that to apply to my instrument addition to my certificate? Joke of course.

    Its kind of remarkable how uncomfortable I was in IMC until how very recently. I obtained my Instrument privileges in 2007 and only JUST started feeling comfortable flying IMC recently. It was a real rush and I was happy everything worked out well. Of course I was in very familiar territory and I was using a G1000 moving map display.

    Now, I did ALL my Instrument training in an actual airplane. I had zero sim time and still have zero sim time in my log book because the school I went to didn’t have a sim, at all. Not just a non approved sim, no simulator, or flight training device or anything. The older PA-28 was a great instrument platform. Really got to learn about radials, NDB approaches, and I didn’t have the luxury of AHRMS or HSI Had to deal with and understand with precession, and of course single needle VORs.

    Now the debate about the sim. I find that we can learn how to use VOR’s and navigate on the Sim. All the skills will translate over from sim navigation to real world, I feel. But what the pilot will experience in real world IMC vs sim IMC is very different. Real Life terrain avoidance, unexpected vectors, managing aircraft performance and of course the aircraft feel.

    I remember my first time in actual IMC was horrific. Over the Grand Canyon, in solid IMC, when I got carb icing in a single engine aircraft. I knew if I lost the engine, and it was sputtering good by this point, I’d lose my gyros and I’d be in the giant ditch, 2000 feet below me. Carb heat did save the day that day (Thank you checklists!). I am wondering if I would have gotten that same carb icing in the sim? I think not.

    • July 13, 2015 at 11:32 am

      The FTDs I’ve flown can simulate carb ice via a slow loss of RPM. On the other hand, they cannot duplicate the vibration, and that’s often what gets your attention in the real world.

      • Graeme Hatzkilson
        July 13, 2015 at 12:56 pm

        Interesting to note. I’ve flown the app on my ipad and thats as much Sim time as I have. I really do have 0.0 in the sim in my log book so I don’t know what they entail.

        What about Pilots who learned from 1903 – 1979 before sims? Where cost and safety any more of an issue then?

        • July 13, 2015 at 1:11 pm

          1979? Flight simulation goes almost as far back as powered flight. The first Link Trainer was put into service in 1929. There may have been simulators even before that. You might even say the Wrights simulated their first flight using kites and gliders.

          • Graeme
            July 13, 2015 at 1:24 pm

            That’s so cool. I had no idea

  5. July 13, 2015 at 9:27 am

    Great thoughts (and thanks for explaining the FAA hierarchy on “sims”. But let us remember simulation devices are king when it comes to injecting unexpected (on the students part) interruptions that result in the pilot being startled which then cause an aircraft upset leading to a loss of aircraft control in flight (LOC-I). In short there are flight conditions that are on the edge which are not taught in the actual aircraft -e.g. an upset that causes a roll past 90 degrees of bank because of safety issues. That is where the simulated aircraft machine is king.

    • July 13, 2015 at 11:42 am

      There are definitely areas where a simulator is superior. Upsets in IMC, low level windshear, V1 cuts, and many other things either cannot or should not be attempted in a real aircraft. But for basic instrument training, at some point the sim has to be traded for a real airplane. Question is, where is that balance point?

      P.S. LOVE your Gravatar image — almost looks like the bear is pumping out the floats for you… 🙂

  6. Jonathan Lacy
    July 13, 2015 at 10:28 am

    Good post Ron.

    With respect to the instrument rating, relatively inexpensive training devices are excellent. My opinion is when learning to intercept, track, and hold on various NAVAIDS the device allows a focused training moment. At Embry-Riddle in the 141 training curriculum I was allowed more than the 10 hours accredited PCATD time. At the time it saved me money. Now when I’m flying in some third world remote location without radar coverage and have to fly a complicated procedure I’m remembering those early situational lessons and always backing up the FMS with raw data and ready to cross-check. Being scan proficient and able to quickly interpret procedure turns, DME arcs etc. is paramount. Especially when the unexpected off route or approach procedure surprises us. We all love the ILS but when the only available approach is a non-precision NDB or VOR with an ARC and procedure turn with mountains, low visibility etc we have to be prepared. Fly safe.

    • July 13, 2015 at 10:29 am

      So true! ATDs and FTDs are much better than an actual airplane for some things. Just the ability to hit the “pause” button is worth its weight in gold. Besides, it’s hard to even find a DME arc or NDB approach to fly in the United States anymore. And who would want to try a V1 cut, low altitude engine failure, or simulate a microburst in a real aircraft? They’re excellent for working procedural stuff. My only concern is that we ensure pilots get adequate exposure to flying instruments IRL — either simulated or actual — before trying it on their own. As a practical matter, most of the people I train take more than the 61 or 141 minimum anyway, owning to the busy SoCal airspace. In a quiet midwest locale, though, their training times might be naturally lower and closer to the FAA minimums. Happy flying!

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