Friday, July 6, 2018

Recent FAA Revisions

Finally got around to reviewing the recent finalized changes to the FARs.  Lots and lots of stuff in there, particularly around ATDs, FTDs, and Full Flight Simulators, but it looks like the impacts on MyFlightbook and MyFlightbook users will be essentially limited to two areas.

The first is the change to 61.57(c) (Instrument currency).  This is an area that I've complained about for a while, because the changes introduced here a few years ago in an attempt to make them more flexible actually had the opposite result: 61.57(c)(4), which was supposed to allow mix-and-match of aircraft and training devices actually made it so that you had to do approaches and holding in an aircraft, and ATD, AND a full-simulator or FTD.  And 61.57(c)(5) was a complete superset of 61.57(c)(2), rendering it utterly pointless.

The new rule, in summary, now reads pretty simply: 61.57(c)(1) now says you need to do 6 approaches and holding within the preceding 6 months (yeah, yeah, and intercepting/tracking too), and (c)(2) explicitly says that you can do (c)(1) in whatever combination of aircraft, ATD, FTD, or Full Simulator you like.  Much simpler, much more in line with what I'm sure was the original intent.  And super easy to implement (and to reverse engineer how MyFlightbook arrives at a particular IFR expiration date).

This rule is effective on November 26; I'm coding up MyFlightbook to automatically cut over to the new rules on that day.

The updates clarify the definitions of what counts as an ATD/FTD/FFS, but this doesn't result in any changes to MyFlightbook, since I've always simply relied on you to tell the system what a device is certified as.  The updates also say that you don't need an instructor while using a training device to maintain curency.  This is very welcome news!  It also, though, does not impact MyFlightbook because it's always been something "out of band" - you had to do it in order to log it, but there was nothing to enforce in the logging process itself.

The other change that may have a noticeable impact on Myflightbook is the new rules for training towards a complex rating.  Specifically, 61.129(a)(3)(ii) now says that in addition to complex or turbine aircraft, you can count time in a technically advanced airplane (TAA) towards the 10 hours of complex time, and it also removes the requirement for seaplanes to be in a complex seaplane (i.e., a complex or turbine or TAA seaplane can now count toward the seaplane requirement).

Two interesting artifacts here:
  • You can apply time in a complex multi-engine airplane towards the SEL commercial rating requirement (that's actually unchanged)
  • Both the MEL and MES ratings do NOT adopt the TAA option; these must still be complex.
The regs also now provide a formal definition of "TAA", which essentially comprises three things:
  • A continuously visible PFD (i.e., replacing the "6-pack")
  • A continuously visible MFD (i.e., GPS with moving map, showing your position)
  • An autopilot capable of 2-axis control, integrated with navigation and guidance.
While I do have the notion of glass models (steam gauges never an option) and glass aircraft (may be the result of an upgrade), this is not a level of detail that I currently support on the system.  I am coding up my commercial ratings progress to account for TAA, but at the moment I have no way to determine if a given aircraft qualifies, so essentially all aircraft are not TAA (and thus you must have complex or turbine)...for now.  I'll need to address this, but it does mean that you'll probably need to update your aircraft to indicate whether or not it is TAA.  Also note that since the TAA substitution is only for commercial SEL, and it really only applies to piston aircraft (since turbine counts towards the requirement), I really only need to do a TAA option for single-engine piston aircraft.

The TAA definition and the use of TAA towards SEL commercial ratings goes live on Aug 27; I am coding this so that MyFlightbook cuts over on that date.

Interestingly, one of the biggest changes doesn't actually impact MyFlightbook: the 

Most of the other changes fall into one of the following three categories, none of which directly affect MyFlightbook functionality:
  • Operational rules - i.e., you need to have a certain rating to perform a certain operation, or have a certified instructor or PIC in the cockpit with you, etc.
  • Definitional rules - like the aforementioned definitions of ATD/FTD/FFS.
  • Experience Substitutions - for example, for ATP ratings there are new options for credit towards flying experience that you can use based on previous military or flight engineer experience.  MyFlightbook has not supported these alternatives historically because it doesn't generally have access to enough information to do so; as a result, these changes don't really impact MyFlightbook.
  • Renumbering.  E.g., with the (welcome) deletion of 61.57(c)(3)-(5), 61.57(c)(6) (Glider IFR currency) is now 61.57(c)(3). 

No comments:

Post a Comment