Full Flight Simulator Exemption Request for Pilot Training

The FAA released a notice on October 29, requesting comments on a request for exemption filed by Orbital Sciences Corporation.  Specifically, Orbital asked for relief from the FAA’s regulation

§ 61.64(a)(2) to allow a pilot applicant, employed by Orbital, to utilize an FAA Approved (Level C) Full Flight Simulator (FFS) for a L–1011 type rating practical test when the applicant has been trained in accordance with Orbital’s § 125 accepted training program.

Orbital uses its L-1011 as a carrier aircraft to carry its Pegasus rocket aloft for launch.  It explained its request as follows:

Currently under §61.64(a)(2), Orbital L-1011 type rating applicants do not qualify to use our Level C FFS for the L-1011 type rating practical flight evaluation because we operate our FFS under a §125 certificate with an “accepted training curriculum”, not as an Approved Flight School (§141/§142) or provider of public transportation (§121/§135). Our primary mandate for all flight operations is maximizing safety through the mitigation of risk. Although §125 allows for the use of our FFS for all required training, currency and proficiency events, it [§125] is silent on the use of an Approved Full Flight Simulator for the purpose of completing a type rating practical check ride. The only alternative under §61 for the same applicant, with the same training is to apply for and complete the same practical check-ride “inflight” using an aircraft [heavy jet].The same maneuvers (i.e. engine failure at V1, go around with failed critical engine, flight control non-normal(s), missed approach with critical engine failed, approach to stall) many which are close to the ground in a heavy jet (Southern California airspace) involve preventable risk to persons and property, both inflight and on the ground easily mitigated by performing the same evaluation in an approved FFS. Decades of industry experience with training and evaluating transport category airman have validated that the depth and breadth of evaluations conducted in a FFS are a more comprehensive test of pilot skills compared to the risk associated with same events performed in a transport aircraft. It is in direct conflict with our internal risk management policy to not use every risk mitigation tool available, in this instance utilizing a FAA Approved Full Flight Simulator versus a heavy jet for the same purpose.

You may find a full copy of Orbital’s request for exemption here, where you have to scroll down to the attachments.

Comments due:  November 18, 2020

Exoplanets.  Terrorists.  Lawyers. 

Check out Mercenary Calling for your next science-fiction, legal procedural craving.