Instrument Currency, Reg Interpretation
 

Hello Everyone,

I'm sure there's a lot out there about this topic, mostly about the 6 month stuff. I'm wondering about simulators. I recently did 3 approaches, holding procedures, tracking/intercepting, etc. in a C172 (last month). I'm now working at a flight school that has an approved FAA simulator for instrument work (I don't mean simulator; it's really a FTD, no motion - but you are allowed to log approaches/sim inst. time). I'd like to do my other 3 approaches in the FTD to make up the 6 total that I need. After double checking the regs, it seems that I can't do this? I feel like I should be able to, but I'm not sure the regs are allowing me to do this.

Lets start with 61.57 (c)(1). This states all the things you do if you want to use an airplane to remain instrument current. I think we're all pretty familiar with this.

Next, we go to 61.57 (c)(2). This is all the same stuff, as in (1) but you're using a simulator or FTD rather than an aircraft (6 approaches, holding, intercepting, tracking, etc...)

Okay, now on to 61.57 (c)(3). Same idea as before, but now you're remaining current using an ATD (aviation training device). I understand these are like personal computers and FAA approved hardware/software. There's other things listed in this section to complete to become current (in addition to the 6 approaches), but the bottom line is that this is the section only for ATD's.

61.57(c)(4) and 61.57(c)(5) is where I have questions, because they sounds like they pertain to my situation, mainly (c)(4): This lists what you have to do if you want to complete your instrument experience requirements using an aircraft, simulator or FTD, AND ATD. There are 3 subsections (i), (ii), and (iii) listed that you must have completed within the preceding 6 calender months. (i) basically says use an aircraft, do approaches (just some...doesn't specify a number), and do your holding/tracking/intercepting. (ii) says the same thing, just using a simulator. (iii) says to do 6 approaches, holding, tracking, intercepting courses, etc. using an ATD. See the thing I'm wondering is that prior to these 3 sections, I interpret it saying you must complete (i) (ii) and (iii) if you want to use a combination of aircraft/simulator...but not really cause you can't just use an aircraft and simulator, you must also go find yourself an ATD?

There is no section for completing instrument experience requirements using only an aircraft and simulator/FTD. There is a section (c)(5) for using a Simulator or FTD along with an ATD.

Am I interpreting this correctly? I feel that my interpretation is not the intention of the reg, but I think that's how it's written. Even though the requirements for your instrument stuff in an airplane is exactly the same as a simulator/FTD, I can't combine only the two of those? Seemed strange to me so I'm just looking for some clarification!

Thanks!

Sometimes the left hand and the right hand don't talk. When the rule came out in 2009, the intro in the Federal Register (74 FR 42516) said,

"Under new § 61.57(c)(4), a person could combine use of the aircraft and FS, FTD, and ATD to obtain instrument experience. When a pilot elects to combine use of an aircraft and simulation device, we will require, under new § 61.57(c)(4), completion of one hour of instrument flight time in the aircraft and three hours in the FS, FTD, or ATD within the preceding 6 calendar months."

Sounds like you have two places to get current, aircraft and "other." Granted, I would have used "or" between FTD and ATD but I think the intent is clear later on. And yet nothing about 1 hour in flight and 3 hours on the ground is in the reg published at the end of that section of FR (74 FR 42550). There have been two technical admendments to 61.57 since 2009 but they were relating to IPCs. Call a FSDO, ask them to explain it to you. They'll most likely scratch their head and call Washington.

If you are working at the flight school, and if you are an instructor, you should be using their planes on their dime to maintain currency. If you are not instructing, but still work there - try to get the 172 at the rate of the FTD...its worth a shot if you havent tried.

The regulation is indeed confusing. Why won't you just complete 6 approaches on the simulator? For instance 6 vectors to final for certain ILS approach, shouldn't take you more than 1 hour?
In any case your best bet would be to send an email to the FSDO or to one of the Inspectors.
Good luck

Why don't you just make it easy on yourself, go grab a CFI-I where you work, do an IPC, and be done with it. Pay for the plane, offer to reciprocate to the instructor if you are a double I. I just can't believe everyone makes it so difficult for themselves. The flight school where I work perks me the airplane, mainly because I have been there for so long. That IPC makes you current for the next 6 months, and then you still have another 6 months to get in your approaches to stay legally current. Not so difficult. Rant over.

Not so Wisepilot....because he dose not need to waste money when there is a free FTD at his disposal. Check to make sure your FTD has been issued a letter of approval for use as an approved FTD. Your chief pilot would know. Have another II vector you on a few approaches and do a hold and you should be set!

Whatever. Who said anything about wasting money? My IPC's don't cost me a dime. Like I said, I am perked the airplane. Much rather do it in the airplane anyway. The school I am at has two FTD's. Nothing against them, learned to fly a 145 at FS. Next time, spell my handle name correctly, thank you.

You're reading the words correctly. That's what it says. A lot of people noticed this when the new language became final (except, apparently, the FAA).

I discussed it by email with some folks at the FAA Airman Certification branch about a year ago. They informed me that there was no intent to remove the ability to combine an airplane and a sim/FTD to maintain currency. But that's small comfort until they actually change the reg to say what they mean.

This is one of an unfortunate number of problems caused by the re-write of 61.57.

Not so wisepilot. It went right over your head lad.
;)

Might want to consider who is the "lad" here my friend. I think I have a few more years on you than you think.:cool: