AC 61-136A

Historical

Advisory circular · FAA Approval of Aviation Training Devices and Their Use for Training and Experience

A newer version is currentThis is a historical version. AC 61-136B is the version in force, approved September 12, 2018.
Approved
November 17, 2014
Last reviewed
July 3, 2024
Cancels
AC61-136
Cancelled by
AC61-136B
Family
AC 61-136 · 3 versions
Revision
A
14 CFR parts
61, 60, 141, 91, 97

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: FAA Approval of Aviation Training Devices and Their Use for Training and Experience Date: 11/17/14 Initiated by: AFS-800 AC No: 61-136A Change:

1. PURPOSE. This advisory circular (AC) provides information and guidance for Aviation Training Device (ATD) manufacturers seeking Federal Aviation Administration (FAA) approval of basic aviation training devices (BATD) or advanced aviation training devices (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. CANCELLATION. AC 61-136, FAA Approval of Basic Aviation Training Devices (BATD) and Advanced Aviation Training Devices (AATD), dated July 14, 2008, is canceled.

3. RELATED 14 CFR REFERENCES (current editions).

• 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.

4. 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.

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

• Appendix 1, General Information,

• Appendix 2, Basic Aviation Training Device (BATD) Requirements,

• Appendix 3, Advanced Aviation Training Device (AATD) Requirements,

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• Appendix 4, Training Content and Logging Provisions, and

• Appendix 5, Evaluation and Subjective Test Criteria.

b. 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 currency). ATDs cannot be used for practical tests, aircraft type specific training, or for an aircraft 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 (AFS) General Aviation and Commercial Division (AFS-800) approving them as either a BATD or AATD. The LOA will be valid for a 5-year period with a specific expiration.

5. RELATED READING MATERIAL (current editions).

• FAA-S-8081-14, Private Pilot Practical Test Standards for Airplane.

• FAA-S-8081-4, Instrument Rating Practical Test Standards for Airplane, Helicopter, and Powered Lift.

• FAA-S-8081-12, Commercial Pilot Practical Test Standards for Airplane.

• FAA-S-8081-5, Airline Transport Pilot and Aircraft Type Rating Practical Test Standards for Airplane.

• FAA Order 8900.1, Flight Standards Information Management System (FSIMS), Volume 11, Chapter 10, Section 1, Approval and Authorized Use under 14 CFR Parts 61 and 141.

6. BACKGROUND. Significant developments in computer flight simulation and visual graphics capability have led to the increased use of advanced flight simulation training devices in General Aviation (GA). The GA community is using this evolving simulation technology to provide increasingly effective training capabilities at reduced cost. This AC reflects the FAA’s experience with simulation technology used to meet specific regulatory flight training and experience requirements of parts 61 and 141.

a. Flight Task Procedures and Operational Skills. Instructors have typically taught flight task procedural skills almost exclusively during in-flight training. However, the FAA has determined that instructors can successfully teach these procedural skills (such as performing a before landing checklist) during ground training using ATDs. In addition, the FAA recognizes that flight instructors can effectively teach operational skills (such as flying a proper traffic pattern or a stabilized approach) using ATDs. These procedural and operational skills can then be positively transferred to appropriate actions in the aircraft. Information on integrating ground training using an ATD with flight training can be found in Appendix 4, Training Content and Logging Provisions.

b. Evaluations of ATDs. The FAA has evaluated many computer hardware and software applications for ATDs. These evaluations determine whether the elements of pilot training, experience, and other requirements within part 61 or 141 can be provided using ATDs. Pilots and instructors may use ATDs in accordance with the LOA to meet the training and aeronautical experience requirements in part 61 or 141.

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7. ACTION. Manufacturers will use this AC as a method of compliance to satisfy the requirements to obtain approval of their ATD. Appendix 2 is exclusively for BATDs and Appendix 3 is for additional items required for AATDs. When the FAA determines that an ATD is satisfactory, an LOA will provide the applicable level of approval. All approvals for use in pilot training and experience, including approvals for use under parts 61 and 141, must be in accordance with this AC.

8. AUTHORIZATIONS FOR PREVIOUSLY APPROVED DEVICES.

a. Training Devices Not Approved by the National Simulator Program (NSP).

All FAA-approved training devices not evaluated or approved by the National Simulator Program in Atlanta, GA (AFS-205, under part 60) come under the evaluation, approval, and policy of AFS-800. All devices will require reauthorization on a 5-year schedule. This evaluation ensures current standards required by this AC continue to be met.

b. Authorizations Not Issued by AFS-800 or that Do Not Contain an Expiration Date.

All approvals for ground trainers, simulators (except Level A, B, C, and D), Level 1-3 FTDs, PCATDs, and ATDs with authorizations that were either not issued by AFS-800, or do not contain an expiration date, will terminate as described in FAA Notice of Policy Change for the Use of FAA Approved Training Devices in the Federal Register (Docket No.: FAA-2013-0809).

The manufacturer or operator must submit a request letter as described in this AC and the notice in order to ensure the FAA has time to evaluate the request for a new LOA. See Appendix 1, paragraph 9, of this AC for additional information.

ORIGINAL SIGNED by /s/ John Barbagallo Acting Deputy Director, Flight Standards Service

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Appendix 1 APPENDIX 1. GENERAL INFORMATION

1. DEFINITIONS.

a. 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. 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 advisory circular (AC) for the specific basic or advanced qualification level.

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

(1) Meets or exceeds the criteria outlined in Appendix 2, 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 Title 14 of the Code of Federal Regulations (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.

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

(1) Meets or exceeds the criteria outlined in Appendix 2.

(2) Meets or exceeds the criteria outlined in Appendix 3, 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.

(4) Provides an adequate platform and design for both procedural and operational performance tasks required for instrument experience, the instrument proficiency check, and pilot time.

(5) The FAA finds acceptable in a manner described in this AC.

d. Qualification and Approval Guide (QAG). The QAG is a required detailed description of the systems and design criteria for a BATD or AATD. The required design criteria for a

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Appendix 1 BATD are described in Appendix 2, paragraph 3. The additional design criteria for an AATD are described in Appendix 3, paragraph 3. This will include all the required elements of design and functionality.

e. Revised QAG Requirement.

(1) A manufacturer or operator who modifies an ATD in any manner must submit a revised QAG to the FAA in order for the letter of authorization (LOA) to remain valid. This requirement ensures that the standards of the initial approval are maintained, including model identification, design, system integrity, aerodynamic modeling, and other essential characteristics of the hardware/software components.

(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. The manufacturer should contact AFS-800 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.

2. PROCESS OVERVIEW. The manufacturers of a BATD or AATD are encouraged to incorporate the most advanced simulation technology and design available to represent a make, model, category, and class of aircraft. Manufacturers must provide the General Aviation and Commercial Division (AFS-800) with a suitable QAG describing the design and capability of the ATD.

a. 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 for approval.

b. The manufacturer first provides the QAG and separate letter requesting FAA evaluation and approval of their ATD at least 90 days in advance of proposed use for pilot training or experience requirements (see Figure 2, Example Letter Requesting Approval). A video of the ATD performing all of the required training device checklist items will be required to be submitted to AFS-800 in advance of the operational evaluation (see Figure 1, Aviation Training Device Checklist). This will provide the FAA and the manufacturer an opportunity to verify all of the functionality criteria of the ATD before the evaluation.

c. AFS-800 will conduct a review of the required QAG document and video, and the FAA will conduct an operational evaluation of the ATD for consideration and approval. If the evaluation is successful, AFS-800 will provide specific (LOA) approval of the ATD for use under the applicable rules in parts 61 and 141.

3. INFORMATION. Direct all inquiries regarding the evaluation, approval, and use of ATDs to FAA Flight Standards Service, General Aviation and Commercial Division, Airmen Training and Certification Branch, AFS-810, 800 Independence Avenue, S.W., Washington, DC 20591, or email to atdrecords@faa.gov. Contact information can be found at http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs800/afs810/.

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Appendix 1

4. CRITERIA FOR APPROVAL AND ACCEPTANCE OF AN ATD.

a. The FAA approves each configuration of an ATD. The approval will be valid for all aircraft that are listed in the QAG for that configuration.

b. 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.

c. To request FAA approval of an ATD, manufacturers should send a letter (Figure 2) with an accompanying QAG requesting approval to:

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

(2) By email: 9-AFS-800-Correspondence@faa.gov.

NOTE: Email, with attached word text format documents, is the preferred correspondence method.

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

(1) Contains a detailed list and description of all the hardware and software components that comprise the device configuration presented for approval. A detailed description should be submitted for each device configuration if approval for more than one device configuration is available. The description of the hardware and software components must include the manufacturer and model or version number of each component, or other such information necessary to correctly identify each component in the particular configuration.

(2) Contain a word-for-word listing of each title, number, and letter item listed in Appendix 2 for a BATD and Appendix 3 for an AATD and state the following information for each item.

(a) The operation or role of the item as appropriate to the aircraft or family of aircraft being represented.

(b) The value for each requirement that either meets or exceeds the minimum specified by that paragraph.

(c) If the aircraft or family of aircraft represented by the device does not have the referenced item, report it as in the following examples: “Carburetor Heat-N/A,” “Cowl Flaps-N/A,” or “Retractable Landing Gear-N/A.”.

(d) Performance chart for each aircraft configuration (make and model) that specifies:

max takeoff weight, max speed, cruise speed, stall speed (VSO), and best climb rate (VY) (feet per minute (fpm) at knots indicated airspeed (KIAS)). These should be specified for sea level performance and gross weight as appropriate. A center of gravity (CG) range allowed by the manufacturer for the specific make and model must also be included.

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Appendix 1

(3) Contain color photographs of the assembled unit in the intended device configuration.

The photographs should be of a quality that clearly shows the overall component arrangement, features, ergonomics, and operation of each hardware control item listed for the aircraft or family of aircraft being represented.

(4) The QAG must include a cover page with the company name, address, and contact phone number with the device picture, model name and number. The page following the cover page should include a table of contents. The following is an example of a QAG outline and contents:

(a) Detailed device description. Include what overall aircraft is represented and make/model details.

(b) Listed components (hardware, software, and capability statement) and color pictures. List any hardware that makes the device function (computer processors, projectors, screens, LCD screens, etc.)

(c) Design criteria. Word-for-word listing of required qualifying items (BATD items as described in Appendix 2 plus additional AATD items as described in Appendix 3, if applicable.)

(d) Aircraft configurations, performance table(s), and CG range.

(e) Visual system.

(f) ATD checklist (Figure 1). Indicating applicable items.

NOTE: Please include footers for each page to reflect when the page was last revised or is the original version of the document. This document should be formatted as one document and book-like in nature, with numbered pages.

(5) Provide operating instructions or manual including a detailed explanation of the device operating system, installation of components and/or modules, all commands and menus, system setup, operation, troubleshooting suggestions, and appropriate aircraft operating information. The device operating manual and installation materials may be sent separately.

Please include a checklist that a student and instructor would use from start to finish for the training session (aircraft make- and model-specific).

e. The requirements defined 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. The FAA will evaluate the configuration and function. The ATD must appropriately represent the aircraft cockpit instrument panel design flight controls, radio and navigation equipment, panels, switches, systems, and other controls.

f. If the review is acceptable, AFS-800 will approve the QAG and schedule an operational evaluation. The FAA may conduct the operational evaluation at the manufacturer’s facility or at another location agreeable to the manufacturer and the FAA. The evaluation will stress typical flight training scenarios, verify adherence to criteria stated for each item required by this

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Appendix 1 document, determine the acceptability of the device’s use for flight instruction in the procedural tasks listed in Appendix 4, and establish the acceptability of operating instructions for use of the device.

NOTE: Approval of the QAG in itself is not an authorization to use the device for pilot training or experience.

(1) If the operational evaluation is acceptable, the FAA will approve the QAG for the ATD configuration presented and provide a LOA to the manufacturer.

(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 deemed necessary, the FAA will conduct a followup evaluation.

(3) If the FAA evaluates a revision to the QAG that was previously found acceptable and validated by an operational evaluation, the FAA may conduct another evaluation of the revised ATD configuration.

g. Once 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 continue to meet the criteria stated in the associated QAG or in an FAA-approved revision to that QAG. The device then qualifies for use in pilot training and experience as provided in the LOA.

h. 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 for authorized use of the ATD;

• A copy of the ATD QAG for all aircraft configuration(s) represented;

• Performance information for the aircraft configurations being represented; and

• A copy or reference to this AC (recommended).

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

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

k. ATDs may be used without further approval per the contingencies 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 4 when using an ATD. The FAA may approve an ATD in a training course outline for use by a part 141 certificated pilot school as outlined in paragraph 8. 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.

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Appendix 1

5. COMPATIBILITY OF SOFTWARE AND HARDWARE COMPONENTS.

a. An approved ATD consists primarily of two components: software (programming) and hardware (central processor, monitor or display, appropriate flight and power controls, and avionics). 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.

b. 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 device. In these cases, the manufacturer must attest in writing (in the QAG) that all hardware technical requirements are compatible with the software used in the ATD. The manufacturer should obtain a compatibility statement from the software developer, which may, at the FAA’s discretion, be used to satisfy this requirement. The following is an example compatibility statement:

“This is to certify that [Name of Software Company or Developer] has demonstrated that the operating system software [Software part number and version/revision] is compatible with [Name of ATD Manufacturer, Make and Model] and can assure that the communications/transport data latency is not greater than 200 milliseconds and all analog and digital input signals meet the performance criteria established for software performance by the ATD manufacturer.”

c. Only the owner or co-developer can validate certification of the transport delay time stated in Appendix 2 and the correct analog and digital inputs necessary to ensure that the software performs adequately. Similarly, the software developer must determine the minimum computer requirements to effectively run the software.

6. MANUFACTURER RESPONSIBILITIES. Manufacturers of ATDs are responsible for providing all the required FAA documentation for each device model authorizing their use for airmen training and experience. This would include any revised LOA that may apply to the approved device. The manufacturer should provide 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 AFS-800 of the intended use as specified in Appendix 4, paragraph 4.

7. 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. 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 4.

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

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(1) The LOA for authorized use of the ATD.

(2) The approved QAG for the ATD being used.

(3) Performance information for the aircraft configurations being represented.

c. Successfully pass the startup self-test described in Appendix 2. If the device is being used in a course of training for a pilot certificate, experience, 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.

d. 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 the ATD malfunction and repeat the startup test described in subparagraph 7c before resuming authorized instruction.

8. 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). The POI is responsible for approving how the ATD will be used in the certificate holder’s part 141 curriculum and training course outline (TCO).

9. PREVIOUSLY APPROVED DEVICES. All previous approvals for ground trainers, simulators (except Level A, B, C, and D), Level 1-3 FTDs, PCATDs, and ATDs with authorizations that were either not issued by AFS-800 or do not contain an expiration date will terminate as described in FAA Notice of Policy Change for the Use of FAA Approved Training Devices in the Federal Register (Docket No.: FAA-2013-0809). The manufacturer or operator must submit a request letter as described in this AC in order to ensure the FAA has time to evaluate the new LOA request.

a. The FAA expects that in most cases the manufacturer of a previously approved device will submit the request for device approval, and that the request contains all of the supporting data required by the appropriate appendix 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.

b. In all instances, the applicant should provide as much data as is 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 a training device if insufficient data is received, or if the training device qualifications significantly deviate from the standards listed in this AC.