Use of Aviation Training Devices (ATD)

Objective

The CFI candidate will demonstrate instructional knowledge of Aviation Training Device (ATD) requirements and limitations per ACS task HI.18.D, including regulatory definitions, approval processes, time credit allowances, and proper documentation verification. Upon completion, the candidate will teach students to correctly apply ATD training credit toward certificate and rating requirements while ensuring compliance with current LOA limitations.

Content

ATD Definition and Regulatory Framework

An Aviation Training Device (ATD) is defined in 14 CFR 61.1 as a training device other than a full flight simulator or flight training device that has been evaluated, qualified, and approved by the Administrator. Think of ATDs as sophisticated training tools that bridge the gap between ground study and actual flight experience - they’re like the “practice court” before the “championship game.”

ATD Limitations - What They Cannot Do

Per 14 CFR 61, applicants cannot use an ATD to accomplish:

• Practical tests (checkrides)
• 14 CFR 61.58 proficiency checks
• The flight portion of 14 CFR 61.57 flight reviews

Remember this limitation with the acronym “PPC” - no Practical tests, no Proficiency checks, no flight review Credit. ATDs are training tools, not evaluation platforms.

ATD Approval Process

The FAA’s General Aviation and Commercial Division evaluates and approves ATDs under 14 CFR 61.4(c) and FAA Order 8900.1. This process ensures consistent standards and reliable training value across different devices and manufacturers.

Letter of Authorization (LOA) System

Each approved ATD receives an FAA Letter of Authorization valid for 60 calendar months. The LOA specifies:

• Pilot time credit allowances
• Associated limitations
• Approved training tasks
• Equipment-specific restrictions

Think of the LOA as the ATD’s “license” - it defines what the device can and cannot do for training credit.

Flight Time Credit Limitations

Both 14 CFR Part 61 and Part 141 specify maximum ATD flight training time that can be applied toward experience requirements. These limitations vary by certificate level and training pathway:

• Private pilot: up to 2.5 hours
• Instrument rating: up to 10 hours (20 hours under Part 141)
• Commercial pilot: up to 50 hours
• ATP: varies by specific requirements

Documentation Requirements for Evaluators

When applicants use ATD flight training time credit to meet minimum experience requirements, evaluators must request a copy of the manufacturer’s LOA. This verification ensures the training was conducted on properly certified equipment within approved parameters.

Risk Management - LOA Currency Verification

The primary risk management element involves verifying the ATD LOA is current and applicable before applying ATD flight time toward experience requirements. An expired or invalid LOA renders the training time unusable for certification credit - imagine showing up to a checkride with training that doesn’t count!

Practical Application for Flight Instructors

As a CFI, you must understand these requirements to:

• Properly advise students on ATD training benefits and limitations
• Ensure ATD training programs comply with regulatory requirements
• Verify LOA currency before endorsing students for practical tests
• Maintain proper documentation of ATD training provided

Schedule

Equipment

• 14 CFR Part 61 (current edition)
• 14 CFR Part 141 (current edition)
• FAA Order 8900.1 (current Flight Standards Information Management System)
• Sample ATD Letter of Authorization documents
• Helicopter Instructor’s Handbook (FAA-H-8083-4)
• Aviation Instructor’s Handbook (FAA-H-8083-9)
• Whiteboard/markers or presentation slides
• Calculator for time computation examples
• Current ACS for CFI Helicopter (FAA-S-ACS-29)

Instructor Actions

The CFI candidate will:

• Present clear definitions of ATD per 14 CFR 61.1 using appropriate references
• Demonstrate knowledge of ATD limitations using the “PPC” memory aid
• Explain the FAA approval process and LOA system with concrete examples
• Show how to calculate maximum allowable ATD time for different certificates
• Display proper technique for verifying LOA currency and applicability
• Provide a sample manufacturer’s LOA and explain its components
• Use analogies to clarify complex regulatory concepts (training tools vs. evaluation platforms)
• Demonstrate risk management through LOA verification scenarios
• Answer student questions with specific regulatory references
• Maintain professional teaching demeanor throughout instruction

Student Actions

The student will:

• Define ATD according to regulatory standards
• List the three prohibited uses of ATDs (practical tests, proficiency checks, flight reviews)
• Explain the LOA system and its 60-month validity period
• Calculate maximum ATD time allowances for various certificate levels
• Demonstrate proper LOA verification procedures
• Identify risk management elements in ATD training credit application
• Ask relevant questions about regulatory requirements
• Participate in case study discussions
• Show understanding through practical examples and scenarios

Completion Standards

The CFI candidate demonstrates instructional competency in ACS task HI.18.D when they:

• Accurately explain ATD definition per 14 CFR 61.1 with complete regulatory context
• Clearly identify all three ATD limitations (practical tests, proficiency checks, flight reviews) with appropriate regulatory citations
• Describe the FAA approval process under 14 CFR 61.4(c) and FAA Order 8900.1 with sufficient detail for student understanding
• Explain LOA system including 60-month validity and content requirements with practical examples
• Correctly state maximum ATD time limits under both Part 61 and Part 141 for relevant certificates
• Demonstrate proper LOA verification procedures meeting ACS skill standard HI.18.D.S1
• Address risk management element HI.18.D.R1 through effective LOA currency verification instruction
• Present information using clear teaching techniques with appropriate analogies and memory aids
• Respond to student questions with accurate regulatory references and practical applications
• Maintain teaching standards consistent with professional flight instruction throughout the lesson