Regulatory Compliance8 min read

Aviation Training Devices in Flight Schools: How BATDs and AATDs Earn Instrument Credit Under Part 61

How flight schools use BATDs and AATDs for instrument rating credit under 14 CFR 61.65 and 61.57, why the FAA letter of authorization controls whether the device time counts, and how to log and schedule ATD sessions so the credit holds at the checkride.

A pre-checkride instrument student arrives at the DPE oral with 51 hours of total time, 16 of them logged on the school's BATD as instrument training. The DPE asks to see the FAA letter of authorization for the device. The school had one in 2019. Nobody renewed it after the device moved benches. The DPE applies the rule as written, the 16 hours come off the experience tally, and the student walks back to the front desk needing five more hours of dual before the application is legitimate. The airplane never failed. The device never failed. The paperwork connecting the device to the rule did.

A flight school can spend six figures on a Redbird and still hand the credit back to the FAA if the LOA, the logging, and the instructor signoff do not line up with what 14 CFR 61.65 and AC 61-136B actually require. The cost is paid by the student, who absorbs the extra hours, and by the school, because the next time a renter asks whether the BATD hours count, the front desk has to hesitate.

What an ATD Actually Is

The FAA recognizes three tiers of ground-based training device below a full flight simulator: the basic aviation training device (BATD), the advanced aviation training device (AATD), and the procedure trainer that meets neither. The distinction matters because the credit available under Part 61 depends on the qualification tier, and the qualification tier depends on a specific FAA approval letter issued to the manufacturer for that exact device model.

The qualification is granted under AC 61-136B. The manufacturer applies, the FAA reviews the device against the standards in the AC, and the FAA issues a qualification approval letter naming the device model. The school that buys a qualified BATD or AATD then has to obtain its own letter of authorization tied to the school and to the device's serial number, because the LOA is what permits the school to credit time on that device toward an FAA certificate or rating under 61.65, 61.57, or the relevant Part 141 course outline.

Without the LOA the device is still useful. It is just not credit-eligible. Students can practice procedures on it all year as ground training the school can charge for, but none of it counts toward the instrument rating aeronautical experience or toward the IPC.

Credit Caps Under 14 CFR 61.65

14 CFR 61.65 is the paragraph schools care about for the instrument rating. A maximum of 10 hours on a BATD or 20 hours on an AATD may be credited toward the 40 hours of instrument aeronautical experience required for the rating. Time on a procedure trainer that is not qualified as a BATD or AATD does not count under 61.65 at all, regardless of how realistic the simulation feels in the seat.

The credited hours have to be conducted with an authorized instructor present. The instructor signs the device session entry and the student's logbook entry the same way they would sign a dual flight. The signoff names the device by serial number, the time on the device, the tasks practiced, the instructor's certificate number, and the device tier as BATD or AATD. The shorthand of writing "sim" in the student logbook with no further detail is the entry the DPE will reject at the oral.

A Part 141 school can use ATD credit beyond the Part 61 cap if the approved training course outline provides for it, but the same LOA logic applies and the same logging discipline holds. If anything the documentation burden is higher under 141 because the ATD use is built into the syllabus and subject to surveillance.

IPC and Recency Credit

The same devices show up in two more places in Part 61 that matter for a flight school's renter base. 14 CFR 61.57(c) allows a pilot to maintain instrument recency by performing the required tasks in an ATD with an authorized instructor present. The device that earns credit toward the rating also earns credit toward keeping a rated pilot current, which compresses the recency burden when a renter has been away from IFR for four months.

The instrument proficiency check under 61.57(d) is the other use. Most of the IPC tasks can be performed in a qualified ATD, with the airplane portion held to the tasks the device cannot fly. A school using its BATD to absorb the procedure-heavy half of an IPC turns a two-airplane-hour event into one airplane hour plus an ATD session, which is the margin that makes IPCs worth scheduling rather than a favor the chief instructor does on a Saturday afternoon.

The Logging Discipline That Holds Up

A logbook entry the DPE will accept names the device serial number, the qualification tier, the date, the duration, the tasks practiced, and the instructor's name, certificate number, and signature. The duration belongs in the ground training column or in a dedicated ATD column the school sets up, never in the dual or PIC airplane columns. A student who logs ATD time as airplane time is logging a problem a DPE catches in three seconds with a calculator and the billing record next to the logbook.

The other half is the school's own device logbook. The device itself keeps a record of each session with the instructor, the student, the LOA in effect, and the cumulative use. That is the record the FAA inspector asks for during a Part 141 surveillance visit and the record the school relies on when the LOA comes up for renewal. The discipline is the same one that runs through logging flight time under 61.51: one source per fact, captured when it happens.

Where the ATD Fits in the Syllabus

The schools that get the most out of a BATD or AATD use it for the parts of instrument training where repetition matters more than airplane time. Holds, approach procedures, partial panel, unusual attitudes, and missed approaches all benefit from the kind of repetition an airplane lesson cannot afford. A student can fly the same VOR approach four times on the device in 30 minutes, twice the way it should be flown and twice with a failure the instructor injected, and arrive at the next airplane lesson with procedural muscle the airplane was previously being asked to build at full burn rate.

The cost lever is real. A BATD session at $40 an hour with an instructor at $60 stands against a wet airplane rate that touches $200 for a 172. A school willing to teach the procedure on the device and reserve the airplane for the integration is teaching the same rating for less money and less calendar time, and the student finishes the rating sooner.

Surfacing the ATD on the Schedule

A device nobody books is a device that does not pay for itself. The schedule has to treat the ATD as a resource on the same calendar that holds the airplanes and the instructors, with its own utilization view and its own booking rules. A BATD sitting idle every Tuesday afternoon while two students are on the instrument waiting list is a school whose scheduling system does not surface the device cleanly. A platform that ties devices, instructors, and aircraft into one scheduling view like HangarOS makes the ATD a first-class booking object rather than an asset somebody has to remember to mention.

The same view should expose the LOA expiration date and the cumulative device hours so the chief instructor sees the LOA approaching renewal before the credit eligibility lapses. An expired LOA is the failure mode the opening scene describes, and it is the one the scheduling system can prevent without anybody having to remember the date.

The Device Is Only as Good as the Documentation Around It

A qualified BATD is a serious training asset. The credit it earns is real, and the rating it shortens is the same rating the airplane would have produced more slowly. The school that lets that asset earn its keep is the one whose LOA is current, whose instructors write logbook entries the DPE accepts on sight, and whose schedule books the device the same way it books the airplane. The school that bought the device and then runs it the way it runs the dusty procedure trainer in the back room ends up paying for the airplane time anyway.