FAA IR: CFI required for "6 HITs" in sim during grace period?

[Captain Olimar]

Can anybody tell me with certainty whether or not I will need a CFI at my side when doing my "6 HITs" according to the FARs

in a sim

while in the grace period?

Background:

I got my FAA ASEL instrument rating on 2018-05-01. That means, my intrument currency lapsed on 2018-11-30, and I have now until 2019-05-31 before I'll need an IPC to "re-activate" my rating. I'm currently in Europe, and after some digging, I found a sim company with a SEP-configured Redbird. However, they do not have instructors holding an FAA license. So I wondered, do I even need a CFI or even CFII for that kind of training (when still instrument-current, I know one doesn't), and if so, will someone holding an EASA instructor's license do? I went through §61.57(c)(1) and §61.57(c)(2) time and again, but keep coming away none the wiser. Or are there other regs governing this?

Thanks for your help!

[LTCTerry]

CO,

Not sure what a "HIT" is, but I'm assuming you are referring to the six required approaches, intercepts, and holds required to regain/retain instrument currency...

Previously if you did all six approaches/etc. in a "simulator" then that was valid for only two months of currency. This changed to six months (61.57(c), 26 Nov 18). Previously an instructor was required. This recently changed (61.51.(g), 27 July 18). Not everything counts as a "simulator" for instrument training/logging purposes. Assuming the Redbird is configured to match your rated aircraft, then you should be good to go.

So, an FAA CFII is not required. Find an local instructor who knows the Redbird and local IFR flying to give you a bit of a challenge.

The above info is from the AOPA's news from June 27 last year: https://www.aopa.org/news-and-media/all-news/2018/june/27/faa-cuts-cost-of-training-proficiency

You are in the first year of being instrument rated. Work on good habits!

[custardpsc]

You don't. You can actually do it on MS Flight Sim on your own,as long as you make the relevant logbook entry.. Unbelievable but true. Not smart if you are newly certificated though. In fact probably not smart in general but ... details here:

https://bruceair.wordpress.com/2018/06/26/new-ifr-currency-rules/

https://www.govinfo.gov/content/pkg/FR-2018-06-27/pdf/2018-12800.pdf

LTC Terry - The definition of "simulator" - is actually ATD ( aviation training device) ( google the definitions or refer to links above) as opposed to FTD

[ahwalk01]

An ATD has a letter of authority from the FAA. Always keep a copy for your records. Microsoft Flight Simulator is clearly not an ATD.

You can do it unsupervised. Make sure you meet all the requirements and log it.

Alex.

[Captain Olimar]

Thanks, everybody! :ok:

(LTCTerry, yep, "6 HITs" is a mnemonic for the involved currency requirements.)

That's great news! While I'd prefer doing it all in an airplane, I just lack the opportunity for that, currently. So this gives me the option to at least do something to keep me from getting rusty.

I see, new §61.51(g)(5) leaves off the instructor. What always confuses and leaves me unsure is that there seems to be no difference between currency training while instrument-current and currency training while not instrument-current (in the grace period), with the sole [albeit admittedly huge] exception of being required to have a CFII at one's side for real flying in actual IMC during the latter period (as one is not legal to fly in actual IMC anymore).

I struggle to understand why one gets to legally "fly" IMC in a sim alone during the grace period, even though one is not instrument-current anymore. Yeah, I know, it's not really flying (but strangely counts the same as real flying...) and there's no real danger for anyone involved, but still, it's weird to me.

As for the question of what sim qualifies, does anyone know the process/time/money involved in setting up an approved/authorized/recognized home sim?

1) Can one "just" prepare one's own custom solution and then somehow (how?) apply with the FAA for a letter of authorization?

2) Can one simply buy a ready-made solution, something like a Redbird TD (a BATD, starting at $6,995 – as a newbie, I'm not allowed to post the link to the product page), for private use? (stressing private use)

3) And Redbird listing a sim as "FAA-approved", does that mean the LOA is already "baked in", the sim ready to go, without any extra steps to be taken, or would one still have to jump through some additional bureaucratic hoops?

[custardpsc]

ahwalk - thanks for clarifying, you are of course dead right. I hadn't dug into the subject hard enough. An ATD does need a letter of approval from the FAA. X-plane, MSFS etc all can be approved, but only as part of a set up with a yoke etc and not keyboard based. As for getting a letter of approval - one can't imagine that to be a simple process and virtually impossible outside the USA. Much easier just to go and fly 6 approaches etc with a safety pilot if you are in the grace period.

[B2N2]

I think you should probably be more concerned about your real world level of safety then the legality of the sim.
You are in your grace periods so you can use a Private pilot in the right seat to be safety pilot while you fly the required approaches.

https://pilotworkshop.com/tips/safety-pilot-requirements/