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:

Rulemaking, even for seemingly minor adjustments like simulator credit for pilot ratings, can be a lengthy and complex process.
The FAA's 2009 regulation limiting simulator (ATD) time for instrument ratings to 10 hours created a discrepancy with previously allowed amounts under individual authorizations.
Attempts to resolve this discrepancy by increasing the limit to 20 hours have been protracted, failing once due to objections and now requiring a new notice of proposed rulemaking, extending a simple update into a six-year regulatory 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.