U.S.

Department
of Transportation
Advisory
Federal Aviation
Administration Circular
Subject: FAA Approval of Aviation Training Date: 9/12/18 AC No: 61-136B
Devices and Their Use for Training Initiated by: AFS-800 Change:
and Experience

1 PURPOSE OF THIS ADVISORY CIRCULAR (AC). This AC provides information

and guidance for Aviation Training Device (ATD) manufacturers seeking Federal
Aviation Administration (FAA) approval of a basic aviation training device (BATD) or
advanced aviation training device (AATD) under Title 14 of the Code of Federal
Regulations (14 CFR) part 61, § 61.4(c). This AC also provides information and guidance
for those persons who intend to use a BATD or AATD for activities involving pilot
training and experience, other than for practical tests, aircraft-type-specific training, or an
aircraft type rating. This AC contains specific procedures regarding the evaluation,
approval, and use of an ATD under 14 CFR parts 61 and 141. The criteria specified in
this AC are used by the FAA to determine whether an ATD is qualified for approval as a
BATD or an AATD. These guidelines have developed from extensive FAA and industry
experience in determining methods of compliance with the pertinent 14 CFR regulations.
Applicable regulations are noted only for reference. This AC does not change regulatory
requirements; therefore, the provisions of the current regulation always control. This AC
applies only to the evaluation and use of BATDs and AATDs. This notice does not apply
to full flight simulators (FFS) and flight training devices (FTD) that are regulated under
14 CFR part 60.

2 AUDIENCE. ATD manufacturers, authorized instructors, flight training providers,

pilots, and others involved in flight training and operations under part 61 or 141 should
be familiar with the content of this AC.

2.1 ATD Assessment. A new ATD must be satisfactorily assessed in the areas essential to
airman training fundamentals to the extent described in:

• Appendix A, General Information;

• Appendix B, Basic Aviation Training Device (BATD) Requirements;
• Appendix C, Advanced Aviation Training Device (AATD) Requirements;
• Appendix D, Training Content and Logging Provisions; and
• Appendix E, Evaluation and Subjective Test Criteria.

2.2 Required Function, Performance, and Effective Use of ATDs. This AC provides
information and guidance for the required function, performance, and effective use of
ATDs for pilot training and aeronautical experience (including instrument currency).
ATDs cannot be used for practical tests, aircraft type specific training, or for an aircraft
9/12/18 AC 61-136B

type rating. Manufacturers of these devices meeting the guidance and standards provided
in this AC will receive a letter of authorization (LOA) from the FAA Flight Standards
Service’s (FS) General Aviation and Commercial Division approving them as either a
BATD or an AATD. The LOA will be valid for a 5-year period with a specific expiration.

3 WHERE YOU CAN FIND THIS AC. You can find this AC on the FAA’s website at
http://www.faa.gov/regulations_policies/advisory_circulars.

4 WHAT THIS AC CANCELS. AC 61-136A, FAA Approval of Aviation Training

Devices and Their Use for Training and Experience, dated November 17, 2014,
is canceled.

5 RELATED 14 CFR PARTS.

• Part 61, §§ 61.4, 61.51, 61.57, 61.65, 61.109, 61.129, and 61.159.
• Part 141, §§ 141.41, 141.55, and 141.57, and appendices B, C, D, E, F, G, I, K,
and M.

6 RELATED READING MATERIAL (current editions).

• FAA-S-ACS-6, Private Pilot – Airplane Airman Certification Standards.

• FAA-S-ACS-7, Commercial Pilot –Airplane Airman Certification Standards.
• FAA-S-ACS-8, Instrument Rating – Airplane Airman Certification Standards.
• FAA-S-8081-4, Instrument Rating Practical Test Standards for Airplane, Helicopter,
and Powered Lift.
• FAA-S-8081-5, Airline Transport Pilot and Aircraft Type Rating Practical Test
Standards for Airplane.
• FAA-S-8081-15, Private Pilot Practical Test Standards for Rotorcraft.
• FAA-S-8081-16, Commercial Pilot Practical Test Standards for Rotorcraft.
• FAA-S-8081-20, Airline Transport Pilot and Aircraft Type Rating Practical Test
Standards for Helicopter.
• FAA Order 8900.1, Volume 11, Chapter 10, Section 1, Approval, Oversight, and
Authorized Use Under 14 CFR Parts 61 and 141.

7 BACKGROUND. Continuing development in computer flight simulation and visual

displays have led to popular use of flight simulation training devices (FSTDs) and ATDs
in General Aviation (GA). The GA community is using this evolving simulation
technology to provide increasingly effective pilot training at reduced cost. This AC
reflects the FAA’s experience with ATD flight simulation technology used to meet
specific regulatory flight training and experience requirements of parts 61 and 141.

7.1 Flight Procedures, Tasks, and Operational Skills. Flight instructors have typically
taught procedural skills and tasks during in-flight training. However, the FAA has

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determined that instructors can successfully teach many of these procedural skills and
tasks during ground training using ATD simulation. The FAA recognizes that flight
instructors can effectively teach many operational skills (e.g., instrument flying, traffic
patterns, stabilized approaches, emergency procedures, etc.) using ATDs. These
procedural and operational skills can then be positively transferred to successful
operations in aircraft. Information on integrating ground training using an ATD with
flight training can be found in Appendix D.

7.2 Evaluations of ATDs. The FAA has evaluated many flight simulation systems and
applications for ATDs. These evaluations determine whether the elements and tasks of
pilot training and other experience requirements described within part 61 or part 141 can
be successfully accomplished using ATDs. Pilots and instructors may use ATDs in
accordance with the LOA to meet certain training and aeronautical experience
requirements listed in part 61 or part 141.

8 ACTION. Manufacturers can use this AC as a method of compliance to satisfy the

requirements to obtain FAA approval of their ATD. The criteria listed in Appendix B is
exclusively for BATDs and the criteria listed in Appendix C is for additional items
required for AATDs. When the FAA determines that an ATD qualifies, an LOA will be
provided to the manufacturer specifying the training credit allowances. All approvals for
pilot training and experience, including approvals for use under parts 61 and 141, must be
in accordance with criteria specified in this AC and the LOA.

9 AUTHORIZATIONS FOR PREVIOUSLY APPROVED DEVICES.

9.1 Training Devices Not Approved by the National Simulator Program (NSP) Branch.
All FAA-approved training devices not evaluated or approved by the NSP Branch in
Atlanta, GA (under part 60) come under the evaluation, approval, and policy of the
General Aviation and Commercial Division. All ATDs will require reauthorization on a
5-year schedule. This evaluation ensures that current standards and criteria identified by
this AC continue to be met.

9.2 Previous Authorizations Not Issued by the General Aviation and Commercial
Division or That Do Not Contain an Expiration Date. All approvals for ground
trainers, simulators (except for FFS Level A–D and FTD Levels 4–7), FTDs Level 1–3,
personal computer-based aviation training devices (PCATD), and ATDs with
authorizations that were either not issued by the General Aviation and Commercial
Division, or do not contain an expiration date, terminated on December 31, 2015 as
described in Federal Register (FR) Docket No. FAA-2013-0809, Notice of Policy Change
for the Use of FAA Approved Training Devices. A manufacturer or operator may submit
an application letter as described in this AC in pursuit of a new LOA. See Appendix A,
paragraph A.5, Previously Approved Devices, for additional information.

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10 AC FEEDBACK FORM. For your convenience, the AC Feedback Form is the last page
of this AC. Note any deficiencies found, clarifications needed, or suggested
improvements regarding the contents of this AC on the Feedback Form.

Michael Zenkovich
Deputy Executive Director, Flight Standards Service

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9/12/18 AC 61-136B
Appendix A
APPENDIX A. GENERAL INFORMATION

A.1 Information Requests. Inquiries regarding the evaluation, approval, and use of ATDs
should be directed to FAA Flight Standards Service, General Aviation and Commercial
Division, Airmen Certification and Training Branch (AFS-810), 800 Independence
Avenue, S.W., Washington, DC 20591. Contact information can be found at
https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs800/afs
810/.

A.2 Definitions.

A.2.1 Aviation Training Device (ATD). An ATD is a training device, other than a full flight
simulator (FFS) or flight training device (FTD), that has been evaluated, qualified, and
approved by the Administrator as a basic or advanced ATD (refer to 14 CFR part 61,
§ 61.1). In general, this includes a replica of aircraft instruments, equipment, panels, and
controls in an open flight deck area or an enclosed aircraft cockpit. It includes the
hardware and software necessary to represent a category and class of aircraft (or set of
aircraft) operations in ground and flight conditions having the appropriate range of
capabilities and systems installed in the device as described within this AC for the
specific basic or advanced qualification level.

A.2.2 Basic Aviation Training Device (BATD). A BATD is a device that:

1. Meets or exceeds the criteria outlined in Appendix B, Basic Aviation Training

Device (BATD) Requirements.
2. Provides an adequate training platform and design for both procedural and
operational performance tasks specific to the ground and flight training
requirements for Private Pilot Certificate and instrument rating per 14 CFR
parts 61 and 141.
3. Provides an adequate platform for both procedural and operational
performance tasks required for instrument experience and pilot time.
4. The FAA finds acceptable in a manner described in this AC.

A.2.3 Advanced Aviation Training Device (AATD). An AATD is a device that:

1. Meets or exceeds the criteria outlined in Appendix B.

2. Meets or exceeds the criteria outlined in Appendix C, Advanced Aviation
Training Device (AATD) Requirements.
3. Provides an adequate training platform for both procedural and operational
performance tasks specific to the ground and flight training requirements for
Private Pilot Certificate, instrument rating, Commercial Pilot Certificate, and
Airline Transport Pilot (ATP) Certificate, and Flight Instructor Certificate per
parts 61 and 141.

A-1
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Appendix A
4. Provides an adequate platform and design for both procedural and operational
performance tasks required for instrument experience, the instrument
proficiency check (IPC), and pilot time.
5. The FAA finds acceptable in a manner described in this AC.

A.2.4 Qualification and Approval Guide (QAG). The QAG is a detailed description of the
simulated aircraft systems, design criteria, and functionality for a BATD or AATD
trainer. The required design criteria for a BATD are described in Appendix B,
paragraph B.3. The additional design criteria for an AATD are described in Appendix C,
paragraph C.3. The QAG must include and verify all the required elements of design and
functionality identified in these appendices to facilitate FAA approval.

A.2.4.1 The QAG document must include a cover page with the company name,
address, and contact phone number with the training device picture, model
name, and number. The following page should include the table of contents.
The following is an example of the appropriate QAG contents:

1. Trainer Description. Include a detailed description of what aircraft

are represented and the model details. This is where quality
pictures of the trainer should be located. This will permit easy
identification of the approved trainer configuration(s).
2. Components List. List any hardware or software components that
make the device function (flight deck panels, avionics components,
computer processors, projectors, screens, LCD screens, operating
systems software, etc.).
3. Design Criteria. Word-for-word listing identifying the applicable
qualifying items (BATD criteria as described in Appendix B, plus
the additional AATD criteria as described in Appendix C,
if applicable.)
4. Aircraft Configurations. Provide a picture of the instrument panel
for each configuration. The performance table for all aircraft
available should be provided in this section.
5. Visual System(s). Provide pictures and descriptions of the visual
systems available for the trainer.
6. ATD Checklist (see Appendix E, Evaluation and Subjective Test
Criteria, Table E-1, Procedures and Tasks Test Checklist). Identify
the functions and tasks that can be accomplished in this trainer.

A.2.4.2 Please include footers for each page to reflect when the page was last revised,
or if it is the original version of the document. This document should be
formatted as one document and book-like in nature, with numbered pages.
Each content section should start at the top of a new page.

A-2
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Appendix A
A.2.5 Revised QAG Requirement.

A.2.5.1 A manufacturer or operator who modifies an ATD in any manner must submit
a revised QAG to the General Aviation and Commercial Division for
evaluation and approval. The manufacturer must also submit a new
application letter summarizing the changes that are reflected in the revised
QAG. This ensures that the standards of the approval are maintained,
including model identification, design, system integrity, aerodynamic
modeling, and other essential characteristics of the hardware/software
components.

A.2.5.2 The requirement to submit a revised QAG does not preclude minor changes
that have only minimal effect on the functional capability of the ATD, such as
new processors, new visual panels, software updates, etc. However, if the
change affects the interface with the operator such as new avionics equipment
or a physical panel change, that would require FAA evaluation and approval.
The manufacturer should contact the General Aviation and Commercial
Division if there is any question as to what constitutes a minor change.
Further, it does not preclude changes limited to specific hardware/software
“mix and match” elements that are clearly identified in an approved revision
to a QAG for the specific device developed by the manufacturer that provides
an optional ATD model configuration.

A.3 Process Overview. The manufacturers of a BATD or AATD are encouraged to

incorporate the most advanced simulation technology and design available to represent
category, class, and make and model (M/M) of aircraft. Manufacturers must provide the
General Aviation and Commercial Division with a detailed QAG describing the design
and capability of the ATD.

A.3.1 Each manufacturer ensures that all ground and flight performance attributes required by
this publication are met by performing the maneuvers, procedures, and operational
training tasks applicable to the ATD in advance of any requests for evaluation and
approval. The ATD should be fully functional prior to the initial application requesting
an evaluation.

A.3.2 The manufacturer then provides the QAG, an operations manual, and application letter
requesting FAA evaluation and approval of their ATD at least 90 days (120 days is
recommended) in advance of any proposed use for pilot training or experience
requirements (see Appendix E, Figure E-1, Example Application Letter Requesting
Evaluation). A video of the ATD performing all of the required training device checklist
items will also be required and submitted to General Aviation and Commercial Division
in advance of the operational evaluation (see Table E-1). This will provide the FAA and
the manufacturer an opportunity to verify all of the functional criteria of the ATD before
the official evaluation.

A.3.3 The General Aviation and Commercial Division will conduct a review of the required
QAG document and video, and the FAA will conduct an operational evaluation of the

A-3
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Appendix A
ATD for consideration and approval. If the evaluation is successful, the General
Aviation and Commercial Division will provide a letter of authorization (LOA) approval
of the ATD model for use under the applicable rules in parts 61 and 141.

A.4 Approval and Acceptance of an ATD.

A.4.1 The FAA approves each configuration of an ATD. The approval will be valid for all
aircraft configurations that are listed in the QAG for that specific model.

A.4.2 The FAA may provide a new approval based on a previously issued LOA if the device
meets the criteria for a basic or advanced ATD.

A.4.3 To request FAA approval of an ATD, manufacturers should send the application letter
(see Figure E-1) with an accompanying QAG and operations manual requesting
evaluation to:

• 9-AFS-800-Correspondence@faa.gov. Send request with documents attached in word

text format (preferred), or
• FAA Flight Standards Service, General Aviation and Commercial Division, Airmen
Certification and Training Branch (AFS-810), 800 Independence Avenue, S.W.,
Washington, DC 20591.

A.4.4 The request for approval must include a separate QAG that:

A.4.4.1 Contains a detailed list and description of all the hardware and software
components that makes up the training device presented for approval. This list
must include any optional equipment or features. The description of the
hardware and software components must include the manufacturer, model,
and version number of each component, or any other information necessary to
correctly identify each component or feature.

A.4.4.2 Contain a word-for-word listing of each title, number, and letter item listed in
Appendix B for a BATD, and additionally the items listed in Appendix C for
an AATD approval, and state the following information for each item.

1. The operation or role of the item as appropriate to the aircraft

being represented.
2. The value for each requirement that either meets or exceeds the
minimum specified for that item or criteria.
3. If the aircraft represented does not have the referenced item
by design, report it as follows: “Carburetor Heat-N/A,
Cowl Flaps-N/A,” or “Retractable Landing Gear-N/A.”
4. A performance chart for the aircraft configurations (M/M)
represented must be included in the QAG, appropriate to the
airplane or helicopter configuration. Performance should be
specified for sea level and 6,000 ft mean sea level (MSL) at

A-4
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Appendix A
gross weight. The QAG must contain color photographs of the
assembled unit in any of the configurations available.
The photographs must clearly show the overall component
arrangement, features, ergonomics, and operational role of each
hardware control or display item listed for the aircraft being
represented.

A.4.5 The requirements specified for the QAG are necessary so the FAA can determine the
acceptability of a device as an ATD by conducting a comprehensive in-office evaluation
and review of the QAG. The ATD must appropriately represent the aircraft cockpit
instrument panel design, flight controls, radio and navigation equipment, panels,
switches, systems, and other controls and be readily identifiable in the QAG.

A.4.6 If the review is acceptable, the Airman Certification and Training Branch will
preliminarily approve the QAG and schedule an operational evaluation. Approval of the
QAG in itself is not an authorization to use the device for pilot training or experience.
The operational evaluation can be conducted at the manufacturer’s facility or at any
location agreeable to the manufacturer and the FAA. The evaluation will stress typical
flight training scenarios and tasks, verify adherence to criteria stated for each item
required by this document, determine the acceptability of the device’s use for flight
instruction in the procedural tasks listed in Appendix D, Training Content and Logging
Provisions, and determine if the operating instructions for the trainer are adequate.

A.4.6.1 If the operational evaluation is acceptable, the FAA will approve the QAG for
the ATD configurations listed, and provide a LOA to the manufacturer.

A.4.6.2 If the operational evaluation is unacceptable, the FAA will advise the
applicant of the changes or corrections necessary for the FAA’s
reconsideration. If necessary, the FAA will conduct a followup functional
evaluation.

A.4.6.3 If the FAA evaluates a revision to the QAG that was previously approved,
the FAA may require another functional evaluation of the ATD trainer.

A.4.7 When the FAA finds the QAG acceptable and issues an LOA that approves use of the
device as an ATD, the manufacturer must ensure that all ATDs manufactured in that
configuration are identical and otherwise continue to meet the criteria stated in the
associated FAA-approved QAG, or approved revision to that QAG.

A.4.8 The ATD manufacturer must include copies of the following documents with each ATD
manufactured and delivered under an approved QAG:

• A copy of the FAA LOA approving use of the ATD;

• A copy of the FAA-approved QAG for all aircraft configuration(s) represented;
• Performance information for the aircraft configurations being represented; and
• A copy or reference to this AC (recommended).

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Appendix A
A.4.9 As noted in the contingencies of the LOA, an ATD may not be used for training and
experience unless the LOA and QAG accompany the trainer and are accessible for
viewing. It is acceptable for these documents to be available electronically.

A.4.10 A manufacturer or operator who changes an ATD design must send a revised QAG to the
FAA for a new approval. As noted in the contingencies of the LOA, any changes made to
the ATD without FAA review may terminate the approval.

A.4.11 ATDs may be used without further approval per the allowances specified in the LOA for
pilot training that is not conducted under part 141. However, such pilot training
operations should follow the information provided in Appendix D when using an ATD.
The FAA may approve an ATD in a training course outline (TCO) for use by a part 141
certificated pilot school as outlined in paragraph A.9. The FAA may withdraw its
acceptance and approval of any device for any type of pilot training or experience if the
device no longer maintains the ATD criteria specified in this AC.

A.4.12 For those trainers with an LOA that will expire within 120 days, the manufacturer can
apply for a new LOA. The manufacturer will need to reapply for FAA approval,
to include the submission of an application letter and QAG verifying that the trainer
model still meets the current criteria identified in this AC for ATD approvals.

A.5 Previously Approved Devices. All previous approvals for ground trainers, simulators
(except for FFS Level A–D and FTD Levels 4–7), FTDs Level 1–3, personal
computer-based aviation training devices (PCATD), and ATDs with authorizations that
were either not issued by the General Aviation and Commercial Division or do not
contain an expiration date have been terminated as described in Federal Register
(FR) Docket No. FAA-2013-0809. The manufacturer or operator can submit for a new
approval as described in this AC.

A.5.1 The FAA expects that in most cases the manufacturer of a previously approved device
will submit a request for a new approval, and that the request should contain all of the
information required by the appropriate appendixes in this AC. However, it is understood
that in some cases an operator (other than the manufacturer) will seek approval for a
device, and may not be able to obtain all of the technical information pertaining to
the device.

A.5.2 In this instance, the applicant should provide as much data as possible and should include
a copy of the previous LOA(s). The FAA will make a determination as to whether or not
the device can be approved as either a BATD or an AATD based on the information
submitted by the applicant. The application will be evaluated under the current criteria
listed in this AC. The FAA will have the discretion to deny approval of any training
device if insufficient data is received, or if the training device significantly deviates from
the standards listed in this AC.

A.6 Compatibility of Software and Hardware Components.

A.6.1 An approved ATD consists primarily of two major components: software (programming)
and hardware (central processor, monitor or display, appropriate aircraft systems, flight

A-6
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Appendix A
and power controls, avionics, etc.). The software and hardware components must be
compatible. Hardware and software compatibility is assured when the hardware
manufacturer and the software developer work in close cooperation to develop the correct
union of inputs for the ATD.

A.6.2 In some cases, the hardware manufacturer and the software developer do not work
together in developing the ATD. Instead, the software is “licensed for use” to the ATD
manufacturer and incorporated into the training device. In these cases, the manufacturer
must identify the software used and attest in the QAG that all hardware components are
compatible with the software used for the ATD construction.

A.7 Manufacturer Responsibilities. Manufacturers of ATDs are responsible for assuring

acceptable design and providing all the required FAA documentation for each model they
produce when authorized for airmen training and experience requirements. This would
include any new or revised LOAs and QAGs that apply to the approved training device.
The manufacturer should provide the current LOA, the FAA-approved QAG, and a copy
of this AC to the person or persons that purchase and use their ATD for pilot training and
experience. This would also include informing the user of the request to notify the
General Aviation and Commercial Division of the intended use as specified in
Appendix D, paragraph D.4.

A.8 Approval of ATD for Use Under Part 61. To be approved for use for pilot training and
experience requirements under part 61, an ATD should:

A.8.1 Be capable of providing procedural training in all areas of operation for which it is to
be used. Those tasks should be specified in an acceptable training curriculum or as
specifically authorized by the FAA and meet the description and suggested criteria
outlined in Appendix D.

A.8.2 Have the following documents available for review by the student and instructor (being
able to retrieve these documents electronically is acceptable):

1. The LOA for authorized use of the ATD.

2. The FAA-approved QAG for the ATD being used.
3. Performance information for the aircraft configurations being represented.

A.8.3 Successfully pass the startup self-test described in Appendix B. If the device is being
used in a course of training for a pilot certificate, experience requirement, or rating a
person authorized by the FAA to provide ground or flight instruction should observe this
test. The FAA expects that after the ATD self-test is complete, no software other than
that necessary for the operation of the ATD will be utilized on the computer running the
ATD software.

A.8.4 Remain in the approved configuration during the training session. Authorized ATD
instruction should not proceed after a malfunction of the ATD system has occurred
(e.g., failure of the visuals, flight controls, instruments, etc.). The operator should correct

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Appendix A
the ATD malfunction and repeat the startup test described in paragraph A.8.3 before
resuming authorized instruction.

A.9 Approval of ATD for Use Under Part 141. Notwithstanding the part 61 criteria listed
above, the jurisdictional Flight Standards District Office (FSDO) may approve an ATD
as part of an overall part 141 school curriculum approval and certification process. Pilot
schools that want to use an ATD as part of their training curriculum must notify their
principal operations inspector (POI) and otherwise receive FAA approval of their TCO
identifying the use of an FAA-approved ATD. The POI is responsible for approving how
the ATD will be used in the certificate holder’s part 141 curriculum and TCO.

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Appendix B
APPENDIX B. BASIC AVIATION TRAINING DEVICE (BATD) REQUIREMENTS

B.1 Purpose. This appendix describes how the FAA will evaluate a BATD for approval and
authorized use. A BATD incorporating specific design criteria will be evaluated for
approval as a BATD on the basis of meeting or exceeding the criteria outlined in
this appendix.

B.2 Authorized Use. Except for specific aircraft type training and testing, a BATD may be
approved and authorized for use in accomplishing certain required tasks, maneuvers,
or procedures as applicable under 14 CFR parts 61 and 141. The FAA will specify the
allowable credit in the BATD letter of authorization (LOA) for private pilot, instrument
rating, and instrument recency of experience.

Note 1: The flight experience allowance for the use of a BATD and the flight
experience allowance for an advanced aviation training device (AATD), a flight
training device (FTD), or a full flight simulator (FFS) towards obtaining an
instrument rating may be combined. However, that combination may not exceed
that allowed under part 61, § 61.65 and may not exceed that allowed under
part 141 appendix C, paragraph 4(b)(4) (50 percent maximum of the required
training).

Note 2: Part 141 certificated pilot schools must obtain a specific authorization
for the use of the BATD as part of that pilot school’s approved training course
outline (TCO). This authorization must come from the FAA Flight Standards
District Office (FSDO) assigned to that pilot school.

B.3 BATD Design Criteria. The Qualification and Approval Guide (QAG) is the initial
means for determining whether a BATD is acceptable for use in part 61 pilot training or
approved part 141 pilot school training curricula. The QAG will be used to determine if a
BATD meets or exceeds minimum FAA design criteria outlined in this appendix.
A BATD found acceptable for use will typically be used to train procedural tasks and
may also be used to meet instrument experience requirements when specifically
authorized. Each QAG submitted to the FAA for evaluation must state the make and
model (M/M) of aircraft being represented and is the basis for the following
requirements:

B.3.1 General Control Requirements. The following items are required for all ATD approvals.

B.3.1.1 The aircraft physical flight and associated control systems must be
recognizable as to their function and how they are to be manipulated solely
from their appearance. These physical flight control systems cannot use
interfaces such as a keyboard, mouse, or gaming joystick to control the
aircraft in simulated flight.

B.3.1.2 Virtual controls are those controls used to set up certain aspects of the
simulation (such as selecting the aircraft configuration, location, weather
conditions, etc.) and otherwise program, effect, or pause the training device.

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Appendix B
These controls are often part of the instructor station or independent
computer interface.

B.3.1.3 Except for the initial setup, a keyboard or mouse may not be used to set or
position any feature of the ATD flight controls for the maneuvers or training
tasks to be accomplished. See the control requirements listed below as
applicable to the aircraft model represented. The pilot must be able to operate
the controls in the same manner as it would be in the actual aircraft. This
includes the landing gear, wing flaps, cowl flaps, carburetor heat, mixture,
propeller, and throttle controls appropriate to the aircraft model represented.

B.3.1.4 The physical arrangement, appearance, and operation of controls, instruments,

and switches required by this appendix should closely model the aircraft
represented. Manufacturers are expected to recreate the appearance,
arrangement, operation, and function of realistically placed physical switches
and other required controls representative of an aircraft instrument panel that
includes at least the following:

• Master/battery;
• Magnetos for each engine (as applicable);
• Alternators or generators for each engine;
• Auxiliary power unit (APU) (if applicable);
• Fuel boost pumps/prime boost pumps for each engine;
• Avionics master;
• Pitot heat; and
• Rotating beacon/strobe, navigation, taxi, and landing lights.

B.3.1.5 When an FAA-approved ATD is in use, only the software evaluated by the
FAA may be loaded for use on that computer system. This does not preclude
providing software updates that do not otherwise change the appearance of the
systems operation.

B.3.2 Additional Controls and Functional Requirements. Physical flight and aircraft system
controls must be provided as follows:

B.3.2.1 For Airplane:

1. A self-centering displacement yoke or control stick that allows

continuous adjustment of pitch and bank.
2. Self-centering rudder pedals that allow continuous adjustment of
yaw and corresponding reaction in heading and roll.

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Appendix B
3. Throttle or power control(s) that allows continuous movement
from idle to full-power settings and corresponding changes in pitch
and yaw, as applicable.
4. Mixture/condition, propeller, and throttle/power control(s)
as applicable to the M/M of aircraft represented.
5. Controls for the following items, as applicable to the category and
class of aircraft represented:
• Wing flaps,
• Pitch trim,
• Communication and navigation radios,
• Clock or timer,
• Gear handle (if applicable),
• Transponder,
• Altimeter,
• Carburetor heat (if applicable), and
• Cowl flaps (if applicable).

B.3.2.2 For Helicopter:

1. A cyclic control stick that tilts the main rotor disk by changing the
pitch angle of the rotor blades in their cycle of rotation.
2. A collective pitch control that changes the pitch angle of all main
rotor blades simultaneously.
3. Throttle/power control that allows continuous movement from idle
to full power settings and which controls engine (rotor) revolutions
per minute (rpm).
4. Antitorque pedals used to control the pitch of the tail rotor that
allows continuous adjustment of the helicopter heading.
5. Mixture/condition control applicable to the helicopter model
represented.
6. Controls for the following items, as applicable to the helicopter
represented:
• Communication and navigation radios,
• Clock or timer,
• Transponder,
• Altimeter, and
• Carburetor heat (if applicable).

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Appendix B
B.3.3 Control Input Functionality and Response Criteria.

B.3.3.1 Time from control input to recognizable system response must be without
delay (i.e., not appear to lag in any way). The manufacturer must verify this
performance criteria in the QAG submitted for FAA approval.

B.3.3.2 The control inputs must be tested by the computer and software program at
each startup and displayed as a confirmation message of normal operation or a
warning message that the transport delay time or any design parameter is out
of tolerance. It should not be possible to continue the training session unless
the problem is resolved and all components are functioning properly.

B.3.4 Display Requirements.

B.3.4.1 The following instruments and indicators must be replicated and properly
located as appropriate to the aircraft represented:

1. Flight instruments in a standard configuration representing the

traditional “round” dial flight instruments. An electronic primary
flight display (PFD) with reversionary and backup flight
instruments is also acceptable.
2. A sensitive altimeter with incremental markings each 20 feet or
less, operable throughout the normal operating range of the M/M
of aircraft represented.
3. A magnetic direction indicator.
4. A heading indicator with incremental markings each 5 degrees or
less, displayed on a 360 degree circle. Arc segments of less than
360 degrees may be selectively displayed if desired or required,
as applicable to the M/M of aircraft represented.
5. An airspeed indicator with incremental markings as shown for the
M/M aircraft represented; airspeed markings of less than 20 knots
need not be displayed.
6. A vertical speed indicator (VSI) with incremental markings each
100 feet per minute (fpm) for both climb and descent, for the first
1,000 fpm of climb and descent, and at each 500 fpm climb and
descent for the remainder of a minimum ±2,000 fpm total display,
or as applicable to the M/M of aircraft being represented.
7. A gyroscopic rate-of-turn indicator or equivalent with appropriate
markings for a rate of 3 degrees per second turn for left and right
turns. If a turn and bank indicator is used, the 3 degrees per second
rate index must be inside of the maximum deflection of
the indicator.
8. A slip and skid indicator with coordination information displayed
in the conventional inclinometer format where a coordinated flight

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Appendix B
condition is indicated with the ball in the center position. A split
image triangle indication as appropriate for PFD configurations
may be used.
9. An attitude indicator with incremental markings each 5 degrees of
pitch or less, from 20 degree pitch up to 40 degree pitch down or
as applicable to M/M of aircraft represented. Bank angles must be
identified at “wings level” and at 10, 20, 30, and 60 degrees of
bank (with an optional additional identification at 45 degrees) in
left and right banks.
10. Engine instruments as applicable to the M/M of aircraft being
represented, providing markings for the normal ranges including
the minimum and maximum limits.
11. A suction gauge or instrument pressure gauge with a display
applicable to the aircraft represented.
12. A flap setting indicator that displays the current flap setting.
Setting indications should be typical of that found in an
actual aircraft.
13. A pitch trim indicator with a display that shows zero trim and
appropriate indices of airplane nose down and airplane nose up
trim, as would be found in an aircraft.
14. Communication radio(s) with a full range of selectable frequencies
displaying the radio frequency in use.
15. Navigation radio(s) with a full range of selectable frequencies
displaying the frequency in use and capable of replicating both
precision and nonprecision instruments, including approach
procedures (each with an aural identification feature), and a marker
beacon receiver. For example, an instrument landing system (ILS),
non-directional radio beacon (NDB), Global Positioning System
(GPS), Localizer (LOC) or very high frequency omni-directional
range (VOR). Graduated markings as indicated below must be
present on each course deviation indicator (CDI) as applicable.
The marking should include:
• One-half dot or less for course/glideslope (GS) deviation (i.e., VOR,
LOC, or ILS), and
• Five degrees or less for bearing deviation for automatic direction
finder (ADF) and radio magnetic indicator (RMI), as applicable.
16. A clock with incremental markings for each minute and second,
or a timer with a display of minutes and seconds.

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Appendix B
17. A transponder that displays the current transponder code.
18. A fuel quantity indicator(s) that displays the fuel remaining,
either in analog or digital format, appropriate for M/M of aircraft
represented.

Note: The minimum instrument and equipment requirements specified

under 14 CFR part 91, § 91.205 for day visual flight rules (VFR) and
instrument flight rules (IFR) must be functional during the training
session. This does not prohibit simulating failures for training
purposes.

B.3.4.2 All instrument displays listed above must be visible during all flight
operations. Allowances can be made for multifunction electronic displays that
may not display all instruments simultaneously. All of the displays must
provide an image of the instrument that is clear and:

1. Does not appear to be out of focus or illegible.

2. Does not appear to “jump” or “step” during operation.
3. Does not appear with distracting jagged lines or edges.
4. Does not appear to lag relative to the action and use of the
flight controls.

B.3.4.3 Control inputs should be reflected by the flight instruments in real time and
without a perceived delay in action. Display updates must show all changes
(within the total range of the replicated instrument) that are equal to or greater
than the values stated below:

1. Airspeed indicator: change of 5 knots.

2. Attitude indicator: change of 2 degrees in pitch and bank.
3. Altimeter: change of 10 feet.
4. Turn and bank: change of ¼ standard rate turn.
5. Heading indicator: change of 2 degrees.
6. VSI: change of 100 fpm.
7. Tachometer: change of 25 rpm or 2 percent of turbine speed.
8. VOR/ILS: change of 1 degree for VOR or ¼ of 1 degree for ILS.
9. ADF: change of 2 degrees.
10. GPS: change as appropriate for the model of GPS-based navigator
represented.
11. Clock or timer: change of 1 second.

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Appendix B
B.3.4.4 Displays must reflect the dynamic behavior of an actual aircraft (e.g., a VSI
reading of 500 fpm must reflect a corresponding movement in altitude, and an
increase in power must reflect an increase in the rpm indication or power
indicator.)

B.3.5 Flight Dynamics Requirements.

B.3.5.1 Flight dynamics of the ATD should be comparable to the way the represented
training aircraft performs and handles. However, there is no requirement for
an ATD to have control loading to exactly replicate any particular aircraft.

B.3.5.2 Aircraft performance parameters (such as maximum speed, cruise speed, stall
speed, maximum climb rate, and hovering/sideward/forward/rearward flight)
should be comparable to the aircraft being represented. A performance table
will need to be included in the QAG for each aircraft configuration for
sea level and 5,000 feet using standard atmosphere and gross weight
conditions. An alternate performance altitude for 6,000 feet can be used if the
manufacturer of that aircraft has a performance chart reflecting that altitude;
otherwise the ATD manufacturer will need to interpolate the performance for
the chart. Performance at altitude for turboprop or turbojet configurations
should reflect 18,000 ft.

Table B-1. Sample Airplane Performance Table

Rate of climb (fpm)

KTAS at Cruise Single Engine
Aircraft at best rate (Vy), at
Vso Vs1 Vx Vy Va Vne Vmc at 75% power Climb rate
Model full power or as
setting (at Vyse)
recommended
C172S N/A SL SL SL N/A
6,000 feet→ N/A
PA28 N/A SL SL SL N/A
6,000 feet→ N/A
BE58 SL SL SL
6,000 feet→

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Appendix B
Table B-2. Sample Helicopter Performance Table

Power setting
Helicopter required to lift off, KTAS at Cruise at Rate of climb (fpm) at best rate at Single Engine Climb
Model standard day at 75% power setting full power or as recommended rate
gross weight
R22 SL SL SL SL N/A
6K N/A
R44 SL SL SL SL N/A
6K N/A
EC135 SL SL SL SL
6K

Note: Use standard atmosphere and gross weight conditions for these
performance tables.

B.3.5.3 Aircraft vertical lift component must change as a function of bank comparable
to the way the aircraft being represented performs and handles.

B.3.5.4 Changes in flap setting, slat setting, gear position, collective control, or cyclic
control must be accompanied by changes in flight dynamics comparable to the
way the M/M of aircraft represented performs and handles.

B.3.5.5 The presence and intensity of wind and turbulence must be reflected in the
handling and performance qualities of the simulated aircraft and should be
comparable to the way the aircraft represented performs and handles.

B.3.6 Instructor Management Requirements.

B.3.6.1 The instructor must be able to pause the system at any time during the training
simulation for the purpose of administering instruction or procedural
recommendations.

B.3.6.2 If a training session begins with the “aircraft in the air” and ready for the
performance of a particular procedural task, the instructor must be able to
manipulate the following system parameters independently of the simulation:

• Aircraft geographic location,

• Aircraft heading,
• Aircraft airspeed,
• Aircraft altitude, and
• Wind direction, speed, and turbulence.

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Appendix B
B.3.6.3 The system must be capable of recording both a horizontal and vertical track
of aircraft movement during the entire training session for later playback
and review.

B.3.6.4 The instructor must be able to disable any of the instruments prior to or during
a training session and be able to simulate failure of any of the instruments
without stopping or freezing the simulation to affect the failure. This includes
simulated engine failures and the following aircraft systems failures:
alternator or generator, vacuum or pressure pump, pitot static, electronic flight
displays, or landing gear or flaps, as appropriate.

B.3.6.5 The ATD must have at least a navigational area database that is local
(25 nautical miles (NM)) to the training facility to allow reinforcement of
procedures learned during actual flight in that area. All navigational data must
be based on procedures as published per 14 CFR part 97.

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Appendix C
APPENDIX C. ADVANCED AVIATION TRAINING DEVICE (AATD)
REQUIREMENTS

C.1 Purpose. This appendix describes how the FAA will evaluate an AATD for approval and
authorized use. A BATD incorporating the additional specific advanced design
simulation criteria will be evaluated for approval as an AATD on the basis of meeting or
exceeding the additional criteria outlined in this appendix.

C.2 Authorized Use. Except for specific aircraft type training and testing, an AATD may be
approved and authorized for use in accomplishing certain required tasks, maneuvers, or
procedures as applicable under 14 CFR parts 61 and 141. The FAA will specify the
allowable credit in the AATD LOA for private pilot, instrument rating, instrument
recency of experience, IPC, commercial pilot, and ATP.

Note 1: The flight experience allowance for the use of an AATD and the flight
experience allowance for a flight training device (FTD) or a flight simulator
towards obtaining an instrument rating may be combined. However, that
combination may not exceed that allowed under part 61, § 61.65 and may not
exceed that allowed under part 141 appendix C, paragraph 4(b)(4) (50 percent
maximum of the required training).

Note 2: A part 141 certificated pilot school must obtain a specific authorization
for the use of the ATD as part of that pilot school’s approved TCO. This
authorization must come from the FAA FSDO assigned to that pilot school.

C.3 AATD Design Criteria. Devices presented for approval as an AATD must first meet or
exceed the requirements for BATD approval criteria contained in Appendix B, Basic
Aviation Training Device (BATD) Requirements. An AATD must display sufficient
aircraft cockpit design, ergonomic features, and performance characteristics beyond that
of the BATD approval criteria to qualify for the authorized uses appropriate for the
AATD simulation devices. Since it is highly desirable for the pilot to be mentally
immersed in a realistic aircraft cockpit when using an AATD, design features must
significantly exceed those of a BATD cockpit layout.

C.3.1 An AATD must include the following additional features and components:

C.3.1.1 A realistic shrouded (enclosed) or unshrouded (open) cockpit design and

instrument panel arrangement representing a specific model aircraft cockpit.

C.3.1.2 Cockpit knobs, system controls, switches, and/or switch panels in realistic
sizes and design appropriate to each intended functions, in the proper position
and distance from the pilot’s seated position, and representative of the
category and class of aircraft being represented.

C.3.1.3 Primary flight and navigation instruments appropriately sized and properly
arranged that exhibit neither stepping nor excessive transport delay.

C.3.1.4 Digital avionics panel.

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Appendix C
C.3.1.5 GPS navigator with moving map display.

C.3.1.6 Two-axis autopilot, and, as appropriate, a flight director (FD). This is only
required when an autopilot is original standard equipment from the aircraft
manufacturer.

C.3.1.7 Pitch trim (manual or electric pitch trim) permitting indicator movement either
electrically or analog in an acceptable trim ratio (airplane only).

C.3.1.8 An independent visual system, panel, or screen that provides realistic cues in
both day and night VFR and IFR meteorological conditions to enhance a
pilot’s visual orientation in the vicinity of an airport including:

• Adjustable visibility parameters; and

• Adjustable ceiling parameters.

C.3.1.9 A fixed pilot seat appropriate to the aircraft configuration, including an

adjustable height and an adjustable forward and aft seat position.

C.3.1.10 Rudder pedals secured to the cockpit floor structure, or that can be physically
secured to the floor beneath the device in proper relation to cockpit
orientation.

C.3.1.11 Push-to-talk switch on the control yoke.

C.3.1.12 A separate instructor station to permit effective interaction without

interrupting the flight in overseeing the pilot’s horizontal and vertical flight
profiles in real time and space. This must include the ability to:

1. Oversee tracks along published airways, holding entries and

patterns, and LOC and GS alignment/deviation (or other
approaches with a horizontal and vertical track).
2. Function as air traffic control (ATC) in providing vectors, etc.,
change in weather conditions, ceilings, visibilities, wind speed and
direction, light/moderate/severe turbulence, and icing conditions.
3. Invoke failures in navigation and instruments, radio receivers,
landing gear and flaps, engine power (partial and total), and other
aircraft systems (pitot, electric, static, etc.) by using either a
keyboard or mouse.

C.3.2 The following features and components are not required for the FAA’s approval of an
AATD, but are encouraged:

C.3.2.1 Multi-panel or wrap-around visual system providing a 120 degrees or more of

horizontal vision.

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Appendix C
C.3.2.2 Automated ATC communications, scenario-based training (SBT), or
line-oriented type training in which the instructor can evaluate pilot
performance without having to act as ATC.

C.3.2.3 Simulated loss of performance and aerodynamic changes from ice accretion.

C.3.2.4 Realistic aircraft engine sound appropriate to the aircraft configuration, power
settings, and speed.

C.3.2.5 A magnetic compass with incremental markings each 5 degrees, that displays
the proper lead or lag during turns, and displays incremental markings typical
of that shown in the aircraft.

Note: The FAA will allow touch screen functionality to be used in an

ATD for those functions or tasks executed in an aircraft that are simple
push-button actions (or similar) to replicate similar actions on the
instrument panel or flight deck, to control aircraft systems or avionics.
However, for actions that require a twisting or turning action of a
physical knob, and/or require a gripping or pulling action of a physical
lever or handle to actuate a system in the aircraft, the trainer must have
a similar physical knob/lever/handle representation in the AATD.

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Appendix D
APPENDIX D. TRAINING CONTENT AND LOGGING PROVISIONS

D.1 Integrated Training Curriculum.

D.1.1 This is a curriculum that can use an Aviation Training Device (ATD) for flight tasks
where an instructor teaches the required knowledge in the classroom and then follows
with procedural training. For example, in an integrated ground and flight instrument
training curriculum, an authorized instructor teaches the required knowledge for an
instrument landing system (ILS) approach through ground and classroom training.
The instructor adds flight procedures in the ground training environment. After the
student has gained the required knowledge and understands the procedures, the instructor
then adds practicing the psychomotor skills of the task. The instructor may do this by
providing a simulated flight environment in a specifically approved ATD, flight training
device (FTD), or full flight simulator (FFS). When the student becomes proficient with
the instrument procedure in the training device, then the instruction would transition to
the aircraft to verify proficiency.

D.1.2 The FAA recommends that an instructor who intends to use an ATD for training pilot
candidates obtain documented advanced training from the manufacturer (or person
proficient with its use) on all aspects of the training device operation. This indoctrination
should include a complete review of the available databases, aircraft configurations,
systems review (avionics and aircraft systems and performance), weather simulations,
systems failure capabilities, instructor station use, and support available from the
manufacturer. This would be similar to someone becoming familiar and proficient in a
new aircraft as described for transition or differences training.

Note: The FAA recommends that instructors use an ATD in an integrated training
curriculum because of the benefits that a structured training course provides.

D.2 Course Content. The FAA expects the instrument tasks below to be incorporated into an
integrated ground and flight training curriculum in which an ATD is used. Procedural
training for visual flight rules (VFR) operations can also be included in a syllabus or
training course outline (TCO) for primary flight training. Procedural tasks might include
traffic pattern operations, navigation, slow flight and stalls, control and maneuvering of
an aircraft solely by reference to instruments, and emergency operations. Preparation for
a flight review could also be incorporated. Training should include FAA-approved TCOs
for 14 CFR part 141 flight schools and FAA/Industry Training Standards (FITS). These
training tasks would be taught to the proficiency requirements of the certification
standards appropriate for the pilot certificate or privilege sought.

D.2.1 Flight by Reference to Instruments.

• Basic attitude flying;

• Straight and level flight;
• Change of airspeed;
• Constant airspeed climbs;

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Appendix D
• Constant airspeed descents;
• Constant rate climbs;
• Constant rate descents;
• Level turns, including standard rate turns;
• Climbing turns;
• Descending turns; and
• Steep turns.

D.2.2 Abnormal and Emergency Procedures.

• Partial panel;
• Timed turns;
• Compass turns and associated errors (if installed);
• Instrument failures;
• Automation failures (primary flight display (PFD), Global Positioning System (GPS)
navigation, systems management, etc.);
• Flight automation failures (such as autopilot failure) including recovery from
potential loss of control;
• Encountering unexpected weather conditions;
• Electrical, systems or equipment failures;
• Procedures for turbulence;
• Loss of control procedures (due to weather radar (WX) conditions, equipment failure,
flight automation, etc.);
• Unusual attitude recovery;
• Engine failure(s) (partial or complete); and
• Hydraulic or boost failures.

D.2.3 Radio Navigation Procedures.

• Use of very high frequency omni-directional range (VOR), Localizer (LOC), ILS, and
Area Navigation (RNAV) including GPS;
• Holding patterns (VOR, ILS, LOC, GPS, Intersection, and waypoints (WPT));
• Use of distance measuring equipment (DME);
• Use of automatic direction finder (ADF)/non-directional radio beacon (NDB)
(optional); and
• Use of autopilot/flight director (FD) (optional).

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Appendix D
D.2.4 Instrument Approach Procedures (IAP).

D.2.4.1 Precision:

• ILS,
• Wide area augmentation system (WAAS) with vertical navigation
(VNAV) (optional), and
• GPS Landing System (GLS).

D.2.4.2 Nonprecision:

• VOR,
• LOC,
• RNAV (including GPS),
• WAAS (optional),
• ADF/NDB (optional),
• ILS/LOC back course (LOC BC), and
• Missed Approach Procedures (MAP) for all of the procedures above.

D.2.5 Communications Procedures.

• Air traffic control (ATC) clearances;

• Taxi clearance and instructions (emphasis on runway incursion prevention);
• Departure clearance (DCL);
• En route clearances;
• Holding instructions;
• Arrival clearances;
• Missed approach instructions and clearances;
• Radio advisories and warnings;
• Automatic Terminal Information Service (ATIS) and common traffic advisory
frequency (CTAF); and
• Significant meteorological information (SIGMET), Airmen’s Meteorological
Information (AIRMET), Notices to Airmen (NOTAM), Flight Service Station (FSS),
communications, and flight plan changes.

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Appendix D
D.2.6 Cross-Country Procedures.

• Departure,
• En route,
• Diversion to alternate,
• Arrival, and
• MAPs.

Note: Training requirements for pilot certification that require cross-country,

solo, night, or takeoff and landings cannot be accomplished in ATDs. Some
training requirements specify that they must be accomplished in an aircraft.
For example, the 3 hours of control and maneuvering of an airplane solely by
reference to instruments described in 14 CFR part 61, § 61.109(a)(3) for a private
pilot must be accomplished in a single-engine airplane. Authorized instructors
may teach such maneuvers and tasks in an FAA-approved training device (to the
Airman Certification Standards (ACS)), and then transition to the aircraft for
those same maneuvers and tasks necessary to meet the aeronautical experience
requirements required for pilot certification.

D.3 Logging Training Time and Experience. Authorized instructors utilizing an

FAA-approved ATD for airmen training, pilot time, and experience requirements are
required to log the time as dual instruction and as basic aviation training device (BATD)
or advanced aviation training device (AATD) time appropriately. Any columns that
reference flight time should remain blank when logging ATD time. ATD time can only
be logged as Instruction Received (Dual), Instrument Time, or Total Time as reflected on
the pilot time section of FAA Form 8710-1, Airman Certificate and/or Rating
Application. Simulated instrument time can be logged in an ATD, but only during the
time when the visual component of the training session is configured for instrument
meteorological conditions (IMC) and the pilot is maintaining control solely by reference
to the flight instruments. Logging time in this fashion will allow a pilot to credit this time
towards the aeronautical experience and instrument experience requirements as specified
in part 61 or part 141. It is required under § 61.51(b)(1)(iv) that the type and
identification of the ATD be included when logging pilot time as described in the letter of
authorization (LOA). It is the responsibility of the flight instructor, student, or certificated
pilot to verify the device is qualified and approved for training or experience
requirements. It would be appropriate for the person using the ATD to retain a copy of
the LOA. Evaluators such as Designated Pilot Examiners (DPE) are instructed to request
a copy of the LOA from applicants logging ATD pilot time, to verify the time acquired in
the trainer qualifies for the minimum experience requirements for a certificate or rating.

Note: There are no restrictions on the amount of training accomplished and

logged in training devices. However, the regulatory limitations on maximum
credit allowed for the minimum pilot certification requirements are specified by
parts 61 and 141 and in the LOA. No approvals or authorizations are provided for
aircraft type ratings using ATDs.

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Appendix D
D.4 Reporting ATD Use and Training Data. Pilot schools, flight instructors, and owners
using an FAA-approved ATD for airmen training or experience requirements are
requested to notify the General Aviation and Commercial Division annually that would
include the information listed below. This information is voluntary and will be used to
continually validate the authorized use of the ATD and to determine whether additional
uses or regulatory amendments are necessary. The information provided should be sent to
atdrecords@faa.gov. The letter should contain:

• The name, address, and phone number of the individual, organization, and pilot
school certificate number (if applicable) providing the training or experience;
• Address and location of the ATD;
• The courses for pilot certification in which the ATD will be used;
• The make and model (M/M) of the ATD being used for training and the LOA
expiration date,
• Notice of sale, change of location, or discontinued use of the ATD; and
• Any information considered helpful in determining the level of effectiveness of
the device.

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Appendix E
APPENDIX E. EVALUATION AND SUBJECTIVE TEST CRITERIA

E.1 General Requirements and Evaluation.

E.1.1 Devices eligible as an Aviation Training Device (ATD) must conform to an acceptable
aircraft cockpit configuration and instrument panel design. (See Appendix B, Basic
Aviation Training Device (BATD) Requirements, and Appendix C, Advanced Aviation
Training Device (AATD) Requirements.) The simulated systems and subsystems
should be able to perform operational functions and performance maneuvers that closely
mimic the represented aircraft. Specific attention should be given to ergonomic and
human factors.

E.1.2 ATDs must be designed to readily facilitate training, practice, and improving piloting
skills. This should include both the procedural and operational performance tasks
specified in the Airman Certification Standards (ACS). The criteria listed in
Appendices B and C and the checklist shown in Table E-1 below will be used to
determine whether the design and performance of the training device qualifies for FAA
approval as an ATD. The FAA will use the following checklist during the evaluation of
an ATD and must be included in the Qualification and Approval Guide (QAG):

Table E-1. Procedures and Tasks Test Checklist

Maneuvers and Tasks Yes/No/NA

a) Pretakeoff
1) Engine start
2) Taxi and brake operation

b) Takeoff
1) AIRPLANE Takeoff
i) Run-up and powerplant checks
ii) Acceleration characteristics
iii) Nosewheel and rudder steering
iv) Effect of crosswind
v) Instrument
vi) Landing gear, wing flap operation

2) HELICOPTER Takeoff
i) Powerplant checks
ii) From hover
iii) From ground

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Appendix E

Maneuvers and Tasks Yes/No/NA

iv) Vertical
v) Running

c) In-Flight Operation
1) AIRPLANE In-Flight Operation
i) Climb
(a) Normal and max. performance
(b) One-engine-inoperative procedures (multiengine)
ii) Cruise
(a) Performance characteristics (speed vs. power)
(b) Normal and steep turns
(c) Approach to stalls (i.e., stall warning), stalls, and
recovery.
Execute from takeoff, cruise, and approach and landing
configurations.
(d) In-flight engine shutdown (multiengine)
(e) Fuel selector function
(f) In-flight engine start
iii) Approach
(a) Normal (with and without flaps) (check gear warning,
if applicable)
(b) Best glide no power
iv) Landings

2) HELICOPTER In-Flight Operation

i) Hovering and air taxi
(a) Forward
(b) Rearward
(c) Sideward
(d) Turns
ii) Climb
iii) Cruise
(a) Performance characteristics (speed vs. power)

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Appendix E

Maneuvers and Tasks Yes/No/NA

(b) Turns
(i) Recovery
(ii) Skidding
(iii) Slipping
(iv) Steep turns
(c) In-flight engine shutdown and start (multiengine)
(d) Descents
(e) Straight in and 180º autorotation
(f) Landings

d) Instrument Approaches
1) Nonprecision
i) GPS and LPV
ii) GPS-WAAS (optional)
iii) All engines operating
iv) One or more engines inoperative
v) Approach procedures (VOR, VOR/DME, LOC procedures
on an ILS, LDA, RNAV (RDP) or RNAV (GPS) to LNAV,
LNAV/VNAV or LPV)
2) Precision
i) ILS
ii) GLS (optional)
iii) Effects of crosswind
iv) With engine inoperative (multiengine)
v) Missed approach
(a) Normal
(b) With engine(s) inoperative (multiengine)

e) Surface Operations
1) AIRPLANE Surface Operations (Post Landing)
i) Approach and landing roll
ii) Braking operation

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Appendix E

Maneuvers and Tasks Yes/No/NA

iii) Reverse thrust operation, if applicable

2) HELICOPTER Surface Operations

i) Landings
ii) Landing area operations

f) HELICOPTER Emergency Operations

1) Power failure at hover
2) Power failure at altitude
3) System and equipment malfunctions
4) Settling with power (optional)
5) Low rotor RPM recovery (optional)
6) Antitorque system failure
7) Dynamic rollover (optional)

g) Any Flight Phase

1) Aircraft and Powerplant Systems
i) Electrical, mechanical, or hydraulic
ii) Flaps (airplane)
iii) Fuel selector and oil temp/pressure
iv) Landing gear (if applicable)
2) Flight Management and Guidance Systems
i) Autopilot (if standard equipment)
ii) Flight director (AATD only)/system displays (if installed)
iii) Navigation systems
iv) Stall warning systems avoidance (airplane)
v) Multi-function displays (if applicable)
3) Airborne Procedures
i) Holding
ii) Uncoordinated turns – slipping and skidding demo

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Appendix E

Maneuvers and Tasks Yes/No/NA

iii) Configuration and power changes and resulting
pitch changes
iv) Compass turns and appropriate errors (if installed)

4) Engine Shutdown and Parking

i) Systems operation
ii) Parking brake operation (if installed) (airplane)

h) Can simulate engine failure, including failures due to simulated

loss of oil pressure or fuel starvation.

i) Can simulate the following equipment or system failures:

1) Alternator or generator failure.
2) Vacuum pump/pressure failure and the associated flight
instrument failures.
3) Gyroscopic flight instrument failures.
4) Pitot/static system malfunction and the associated flight
instrument failures.
5) Electronic flight deck display malfunctions.
6) Landing gear (if retractable) or flap malfunctions.

j) Independent Instructor Station Requirements (AATD Only)

1) Displays published airways and holding patterns.
2) Displays aircraft position and track.
3) Displays aircraft altitude and speed.
4) Displays NAVAIDs and airports.
5) Can record and replay aircraft ground track history for entire
training session.
6) Can invoke instrument or equipment failures.

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Appendix E
E.2 Requesting FAA Approval of ATD. The manufacturer of an ATD must include this
completed checklist in the QAG and indicate that maneuver or function is executable in
the trainer. In some instances, it can be indicated as not applicable (NA) such as
multiengine or helicopter requirements. The letter of application signed by the
manufacturer must be submitted to the General Aviation and Commercial Division
(per Appendix A, General Information), along with a complete QAG describing how the
training device meets basic aviation training device (BATD) approval criteria listed in
Appendix B, and if applicable the additional advanced aviation training device (AATD)
approval criteria listed in Appendix C. The manufacturer must also submit at the time of
application an operations manual for the trainer.

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Appendix E
Figure E-1. Example Application Letter Requesting Evaluation

Dear [Name of FAA ATD Program Manager]: Date:

[Name of manufacturer] requests an evaluation of its [ATD model name] [basic or

advanced] aviation training device for approval by the Federal Aviation Administration
(FAA) at:

[Location and address where the functional evaluation is requested].

This training device is fully described in the accompanying Qualification and Approval
Guide (QAG) and is completely operational and available for FAA evaluation. The [model
name] has been evaluated and tested by [manufacturer name] and appears to meet the
minimum criteria for approval as a (BATD or AATD).

The following [manufacturer’s name] personnel have assessed this training device
as compliant:

Name
Qualification & Title

Pilot Name
Qualification & Title

And attest that:

This training device effectively represents a [category, class, and model aircraft] and the
associated systems and subsystems found in that aircraft. Additionally, the performance and
handling qualities have been evaluated and adequately represent the category, class, and
model of aircraft. The [model name] contains the minimum design features required for a
basic aviation training device (BATD), or advanced aviation training device (AATD),
as described in Advisory Circular (AC) 61-136, FAA Approval of Aviation Training
Devices and Their Use for Training and Experience.

Sincerely,

[Signature of Manufacturer or Authorized Representative]

[Printed Name of Signatory and contact information, including address, phone number,
and email]

Enclosures – QAG and Operations Manual for [manufacturer, model name of

training device]

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Appendix E
E.3 ATD Approval Process Summary.

E.3.1 The manufacturer provides the General Aviation and Commercial Division an application
letter, QAG, operations manual, and demonstration video for evaluation, via email with
text files attached at least 90 days in advance (120 days recommended). Email is the
preferred correspondence method. Videos should be provided via YouTube link. Send
correspondence and documents to the General Aviation and Commercial Division at
9-AFS-800-Correspondence@faa.gov.

E.3.2 If the application letter and QAG are found to be initially incomplete or inadequate, then
the FAA will contact the manufacturer describing the needed revisions.

E.3.3 When a qualifying QAG is submitted and found adequate, the FAA will request that a
video be submitted to the FAA accomplishing tasks identified in the task table (see
Table E-1). After FAA review of the demonstration video, if it appears that the trainer
qualifies, an aviation safety inspector (ASI) will be scheduled to conduct an on-site
functional evaluation of the training device.

E.3.4 If the functional evaluation results are successful, the FAA will issue a letter of
authorization (LOA) to manufacturer in approximately 30 days.

E.3.5 If the evaluation results are found unacceptable, the FAA evaluator will notify the
manufacturer of the discrepancies for correction, and will plan to accomplish a followup
inspection when the manufacturer has resolved those discrepancies.

E.3.6 When a successful functional evaluation is accomplished, the General Aviation and
Commercial Division will issue an LOA along with the FAA-approved QAG to the
manufacturer via FedEx envelope, regular mail, and/or email.

E.4 Previously Approved Training Devices Seeking a New LOA.

E.4.1 The manufacturer sends a QAG and a separate formal letter requesting evaluation and
approval via regular mail or as text word files attached to an email to the FAA (General
Aviation and Commercial Division) using the normal evaluation request procedures
described by this AC. The request should include a copy of the previous LOA, as well as
a contact phone number and email address.

1. Email is the preferred correspondence method at

9-AFS-800-Correspondence@faa.gov.
2. See Appendix A, paragraph A.5, Previously Approved Devices, for
information concerning devices that have not previously been approved as
either an AATD or BATD.

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Appendix E
E.4.2 The FAA receives the previous LOA, revised QAG, and application letter requesting
evaluation and approval of the manufacturer’s previously approved training device. The
general procedures listed in paragraph E.3 will apply. The FAA will consider previous
applications, evaluations, and reviews conducted for the training device in determining
whether an additional operational evaluation is necessary.

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 Advisory Circular Feedback Form

If you find an error in this AC, have recommendations for improving it, or have suggestions for
new items/subjects to be added, you may let us know by contacting the General Aviation and
Commercial Division at 9-AFS-800-Correspondence@faa.gov or the Flight Standards
Directives Management Officer at 9-AWA-AFS-140-Directives@faa.gov.
Subject: AC 61-136B, FAA Approval of Aviation Training Devices and Their Use for Training
and Experience

Date: _____________________

Please check all appropriate line items:

An error (procedural or typographical) has been noted in paragraph ____________

on page _______.

Recommend paragraph _____________ on page __________ be changed as follows:

______________________________________________________________________

______________________________________________________________________

In a future change to this AC, please cover the following subject:

(Briefly describe what you want added.)

______________________________________________________________________

______________________________________________________________________

Other comments:

______________________________________________________________________

______________________________________________________________________

I would like to discuss the above. Please contact me.

Submitted by: Date: ______________________