Rulemaking is a Pain

Although Ive never been involved in rulemaking, I can understand why it is a thorn in the side for a regulatory agency. Recently proposed changes for use of simulator time towards an instrument rating make a perfect example.

Editorial Staff

Wednesday, September 09, 2015 at 12:00 AM ET

Verified

Key Takeaways:

The FAA has been engaged in a six-year process to adjust the amount of simulator time credit allowed for an instrument rating, beginning with a 2009 regulation that limited it to 10 hours.
A 2014 attempt to increase this limit to 20 hours through a direct final rule failed due to objections, requiring the FAA to re-propose the change in 2015.
This prolonged effort to resolve a seemingly minor regulatory discrepancy highlights the significant complexities and challenges inherent in the rulemaking process.

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Although I’ve never been involved in rulemaking, I can understand why it is a thorn in the side for a regulatory agency. Recently proposed changes for use of simulator time towards an instrument rating make a perfect example.

Since the 1980’s, the amount of time an applicant could use in an aviation training device (ATD, although that is not what they were called at the time) towards an instrument rating was included in the letter of authorization (LOA) approving the device. This was based on guidance in advisory circulars.