I was recently asked by a flight training facility whether they could provide aircraft simulator training to foreign students for large, civil aircraft (over 12,500 lbs) without the necessity of the students obtaining TSA approval. They also asked whether associated ground school training would require TSA approval.
As you may know, 49 C.F.R. 1552 governs flight training for aliens and dictates that aliens obtain TSA approval before they may begin flight training. Under 49 C.F.R. 1552.1, training in an aircraft simulator is considered flight training. According to a TSA Interpretation, this includes training that “could be used” for a certificate or rating. However, it does not include recurrent training or ground training. Ground training includes classroom or computer-based instruction in the operation of aircraft, aircraft systems, or cockpit procedures, but does not include instruction in an aircraft simulator. Further, with respect to small, civil aircraft (less than 12,500 lbs.), an earlier TSA Interpretation states that flight training only applies to training for a recreational, sport pilot, private pilot certificate, a multi-engine rating, or instrument rating and does not include recurrent training such as flight reviews, proficiency checks, or other checks whose purpose is to review rules, maneuvers, or procedures, or to demonstrate a pilot’s existing skills.
Based upon these regulations and the TSA’s interpretations, the flight school would not be able to provide aircraft simulator training to foreign students until the students obtain TSA approval. However, they would be able to provide ground instruction to the students pending receipt of TSA approval.