Logging IFR currency in a simulator
#1
Logging IFR currency in a simulator
So I've past the 6 months for my currency, so I have another 6 months before an IPC. 1. Can I get in a simulator to get those approaches and 2. Does it have to be done with a CFII in a simulator?
#2
Simulator time, by definition, requires the presence of an appropriate instructor. There is no such thing as solo sim time. For almost all instrument work the instructor must be a CFII, and he will need to sign your logbook for it to count.
#3
New Hire
Joined APC: Feb 2011
Posts: 1
I recently received this regarding the need to have an instructor present on the simulator. Do you have any comments?
The following is a recent notice from Lance Nuckolls of the FAA Office of Aviation Safety addressing use of flight simulators.
What is particularly interesting is the part where he states that a authorized instructor is not required to be present when a pilot is logging time to maintain instrument recency experience.
************************************************** ********************************
Pursuant to our conversation this morning regarding the authorized (Approved) use of a Basic Aviation Training Devices (BATD) and an Advanced
Aviation Training Device (AATD):
Approved Uses-
As stated in AC 61-136, BATDs and AATDs are approved for use in accordance with 14 CFR section (§) 61.4(c). In essence, § 61.4(c) states that the
Administrator may approve a device, other than a flight simulator or flight training device, for specific purposes. BATDs and AATDs are essentially
devices approved by the Administrator for specific purposes by way of a Letter or Approval/Authorization (LOA). Therefore, § 61.4(c) and the LOA
are the regulatory basis for the authorized use of a BATD or an AATD.
Authorized Flight Instructor-
An authorized flight instructor only needs to be present and certify the use of a BATD or an AATD when the time being logged is for training (instruction) towards a pilot certificate or rating. 14 CFR § 61.51(g)(4) states- "A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session." The operative term is "training session". Therefore, if a person is logging the time and experience necessary to maintain instrument recency experience [§ 61.57(c)(2)] and is not applying that time and experience towards a pilot certificate of rating, then an authorized instructor is not required to be present and certify same. The preamble to the August 2009 Part 61 Final Rule states-"An authorized instructor (See § 61.1(b)(2)) must be present in the FS, FTD, or ATD when instrument training time is logged for training and aeronautical experience for meeting the requirements for a certificate, rating, or flight review (See § 61.51(a)). The instructor must sign the person's logbook verifying training time and session content.
That being said... as stated above, approved uses for a BATD and an AATD are governed by § 61.4(c) and the LOA. The LOA states that an authorized
instructor must certify the instructional use. Simply satisfying the requirements of § 61.57(c)(2) is not considered instructional use, therefore an authorized instructor does not need to be present.
I hope that this provides the clarity you are seeking.
Regards,
Lance
R. Lance Nuckolls
Aviation Safety Inspector - Flight Operations
FAA Office of Aviation Safety
General Aviation & Commercial Division
Certification and General Aviation Operations Branch, AFS-810
202-267-9374
202-267-5094 (fax)
The following is a recent notice from Lance Nuckolls of the FAA Office of Aviation Safety addressing use of flight simulators.
What is particularly interesting is the part where he states that a authorized instructor is not required to be present when a pilot is logging time to maintain instrument recency experience.
************************************************** ********************************
Pursuant to our conversation this morning regarding the authorized (Approved) use of a Basic Aviation Training Devices (BATD) and an Advanced
Aviation Training Device (AATD):
Approved Uses-
As stated in AC 61-136, BATDs and AATDs are approved for use in accordance with 14 CFR section (§) 61.4(c). In essence, § 61.4(c) states that the
Administrator may approve a device, other than a flight simulator or flight training device, for specific purposes. BATDs and AATDs are essentially
devices approved by the Administrator for specific purposes by way of a Letter or Approval/Authorization (LOA). Therefore, § 61.4(c) and the LOA
are the regulatory basis for the authorized use of a BATD or an AATD.
Authorized Flight Instructor-
An authorized flight instructor only needs to be present and certify the use of a BATD or an AATD when the time being logged is for training (instruction) towards a pilot certificate or rating. 14 CFR § 61.51(g)(4) states- "A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session." The operative term is "training session". Therefore, if a person is logging the time and experience necessary to maintain instrument recency experience [§ 61.57(c)(2)] and is not applying that time and experience towards a pilot certificate of rating, then an authorized instructor is not required to be present and certify same. The preamble to the August 2009 Part 61 Final Rule states-"An authorized instructor (See § 61.1(b)(2)) must be present in the FS, FTD, or ATD when instrument training time is logged for training and aeronautical experience for meeting the requirements for a certificate, rating, or flight review (See § 61.51(a)). The instructor must sign the person's logbook verifying training time and session content.
That being said... as stated above, approved uses for a BATD and an AATD are governed by § 61.4(c) and the LOA. The LOA states that an authorized
instructor must certify the instructional use. Simply satisfying the requirements of § 61.57(c)(2) is not considered instructional use, therefore an authorized instructor does not need to be present.
I hope that this provides the clarity you are seeking.
Regards,
Lance
R. Lance Nuckolls
Aviation Safety Inspector - Flight Operations
FAA Office of Aviation Safety
General Aviation & Commercial Division
Certification and General Aviation Operations Branch, AFS-810
202-267-9374
202-267-5094 (fax)
#5
Gets Weekends Off
Joined APC: Nov 2008
Posts: 826
But the language of the regulation does NOT say that. I and some others noticed the discrepancy shortly after the Final Rule was published. I wrote to John Lynch, who was with FAA for many years and one of the primary authors of the revised rule, who confirmed that this was what they meant to do.
Unfortunately, they didn't. And the FAA Chief counsel said so:
http://www.faa.gov/about/office_org/...0/Keller-1.pdf
IOW, depending on how old your letter is, at least until the Chief Counsel's office and Flight Standards get together on this, the regulation and the Chief Counsel both say a CFI needs to be present in order to log anything in a simulator.
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