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 encountered a discrepancy between older, more permissive authorizations for simulator time towards an instrument rating and a 2009 regulation limiting it to 10 hours.
Attempts to increase the allowable simulator time to 20 hours via a 2014 direct final rule failed due to public objections.
What started as a straightforward regulatory adjustment has evolved into a complex, six-year rulemaking process for the FAA, highlighting the challenges of regulatory change.

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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.