Sim-Time Shootdown: Let's Just Make It Harder

I was doing some video shooting at the Sport Aviation Expo on Saturday when an AVweb reader approached me to say hello. It wasn't long before our conversation devolved into an arm-waving, spittle-flying moment of high dudgeon. We weren't arguing, but agreeing that the FAA's baffling announcement that it was withdrawing the tiny little baby step it had granted to allow more credit for simulator time toward the instrument rating was, well, baffling.

The reader, recently retired from the bizjet world, mentioned that he had gotten a type rating in a Falcon some years ago entirely in the sim. The first time he got in the airplane, he flew it. What year? I guessed about early 1990s. Nope; 1978. So for at least 37 years, the jet community has been doing its training in simulators, right up to the type rating. (As an indicator of how long ago that was, we made about 18,000 airplanes that year and 100 million U.S. citizens alive now, weren't then.)

We're a long way from sim-only training in piston GA, but at least like a coelacanth slithering onto the warm mud of a primordial beach, we were crawling in that direction when … whoosh, the FAA reversed itself. It withdrew a final rule that granted up to 20 hours credit toward the instrument rating for training in an approved training device. Now I'm not meaning this blog to be a bashing of the FAA. This is too easy to do; we do it all the time and readers get as sick of reading it as I do of writing it. So the stupidity here isn't so much the FAA itself, but the archaic rules under which it operates. It's almost a system purpose-built to stymie progress and preserve the status quo, no matter how broken it is. And it is broken.

As we reported, the FAA went to a direct rule on this change, rather than the usual 90-day NPRM comment period. Under federal regulatory guidelines, that means - according to the agency - a single complaint against the rule requires it to be rescinded. Maybe the agency deserves credit for trying to get there in a hurry. But it got two complaints and reversed itself. I am reproducing one of these in its entirety as a means of illustrating how a combination of outdated rulemaking and hideboundedness conspire to doom progress. Here's the complaint. You can judge its merit for yourself. Who authored it is unimportant.

As a professional pilot, ATP, CFI, CFII, and MEI land and sea, I do not agree with the new rule. It is my experience that flight requires the use and correlation of all our senses in order to make a lasting impression. I believe the FOI agrees with this. Recognizing that our senses can sometimes deceive us in IMC, I nevertheless have still found that sounds and feel are vital to recognizing unusual attitudes, even when other senses fail us.

More importantly, our acclimation to IMC helps us relate these various inputs to the strategies to deal with them. ATDs are valuable as procedure trainers, but not as valuable as everyone seems to think. The rapid redeployment of a situation seems like an advantage, yet it diminishes the learning because it seems so easy to recover from a botched maneuver. Resetting the situation also diminishes the 'routine' that a pilot relies on to take him to a specific place.

For example: A failed approach followed by instantly reconfiguring the aircraft at the takeoff position for another flight, or even at the approach gate, removes all the preparatory steps a pilot normally follows to get there. This interferes greatly with the learning of each step.

ATD's are firmly on the ground and no amount of graphic imagery or display setup, even in full motion simulators, ever causes a pilot to lose consciousness of that fact. Consequently, pilots do not experience the fear that accompanies real-life emergencies, or the sensory inputs that come with icing and thunderstorm contact. I have seen pilots paralyzed by encounters with severe turbulence or a stalled aircraft. No ATD can begin to simulate these conditions, yet they are the most likely to end in a fatal crash.

Flight simulators are wonderful, but very limited devices. Instead of increasing a pilot's skill, however, they have come between real-world flying and desktop flying. They have increased reliance on screens and autopilots and diminished the pilots sense of being in charge of the aircraft and the flight. Stalls, thunderstorms, and Icing are the greatest dangers, yet ATDs cannot depict these accurately or realistically.

Furthermore, instructors rely less and less on real-world experience because they themselves have not regularly come into contact with them. I am disappointed at how often instructors are loathe to stall an aircraft or to enter turbulence. I think this is the wrong direction for training to go. There is generally no reset after a crash.

It seems to me that the industry at large always diminishes the importance of safety and increases the importance of costs whenever training requirements are considered. I believe one hour in any aircraft is worth ten in front of an ATD. The cost of a lost aircraft and all its crew is not worth the imagined savings gained from flying imaginary aircraft in imaginary environments.

Merit wise, I judge this to be weak at best, spurious at worst. You can apply this very same reasoning to the simulators used to train business and airline pilots and it will have about as much validity, since the commenter doesn't list flight dynamics fidelity as a factor. And I'd argue that a type rating for a pilot about to fly passengers for hire or professionally is a higher order of concern than a Part 91 pilot struggling to earn an instrument rating.

If the commenter's argument sounds familiar, it should. It has been used ad nauseam by people opposed to simulators, unaware of their value and capabilities and quite uninformed about how far small-scale simulation has come in the past 10 years. I think I probably made the same argument myself before I started using an old Link trainer I once had access to. After a few hours of sim work, I found myself wondering why I couldn't use it more and credit the student accordingly. That was 25 years ago.

While it is true that some instrument students don't get much or even any IMC experience, that shouldn't be reason to saddle them with requiring the use of an airplane as a classroom. Sims are just better teaching environments, allowing better transference of knowledge more effectively and at a lower cost. If you operate from the notion that we ought to stop nannying students and pilots with more training and experience requirements - that's my view - then let them have a vote in their own training and decide how much sim time they need or don't need.

If you can walk the walk on the ride, zap … you're empowered as a new instrument pilot. How about this? We unclutch our pearls over the idea that instrument students might actually get out there without so much as a stitch of IMC time and, concordantly, we relieve the government of its duty to assure that this can't be allowed to happen. If you're an instrument student and want IMC time, find an instructor who doesn't soil himself at the merest risk of a whisker of rime and go fly somewhere.

I view the FAA's decision as a bit of a tipping point. If it tipped forward, the rule would have stuck and instrument ratings might have been cheaper and more effective for some. But it tipped backward and, well surprise! Welcome back to 1985. Companies like Redbird have shown at least a glimmer of actually delivering on their promise to evolutionize flight training. I don't think this rule reversion back to the way it was helps that campaign. Redbird still hasn't fielded what it claims will be the new way of flight training and it may be a long way from doing so. Sliding back into the dark ages on sim credit won't help.

And I don't think this is all on the FAA, either. Somehow in this industry, we're capable of aiding and abetting the FAA in not just shooting ourselves in the foot, but taking both legs off at the knee.

Real estate values in the Village of the Damned where we all seem to live continue to crumble.

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