New Part 61 and Simulators/BATDs
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Join Date: Jan 2008
Location: Boston, MA USA
Age: 68
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New Part 61 and Simulators/BATDs
I have to admit it, I understand a lot of things about aviation but the new FAA Part 61 rules on simulators and instrument currency have me completely confused. 
Searching on the Internet hasn't helped at all. In different places, I see BARD/AATDs (Like Elite and Precision Flight controls sell) defined as ATDs (requiring 3 hours every two months) and not ATDs (able to follow the 6in6 rule).
I've seen people say (including the FAA in the Federal register but NOT in the rule itself) that an "authorized instructor" no longer needs to be present during currency work. The logic (which sounds reasonable) is that pilots can self-certify doing the work in an airplane, they should be able to self-certify in a sim.
Others quote a nearby but still present phrase in part 61 to say that an instructor is still needed to sign the log.
And lastly, speaking of the definition of "authorized instructor". I've heard of a recent legal interpertation by the FAA chief counsel's office (often a source of true irrational claptrap such as the now infamous "icing letter") that Instrument ground instructors are NOT authorized to give instruction in simulators
This despite the fact that this is a widespread practice and has been specifically mentioned as being permitted in Part 61 FAQs previously published by the FAA.
One truly wishes that this organization would get its administrative act together.
So I'd like to solicit input from anyone who thinks they have insight into the facts.
1. Can IGIs teach in sims?
2. Must an authorized instructor be present to count sim time for currency (not for a rating, just currency)
3. Is a BATD or AATD approved under the old regulations now all of a sudden a very restricted "ATD"?
inquiring minds want to know!
Searching on the Internet hasn't helped at all. In different places, I see BARD/AATDs (Like Elite and Precision Flight controls sell) defined as ATDs (requiring 3 hours every two months) and not ATDs (able to follow the 6in6 rule).
I've seen people say (including the FAA in the Federal register but NOT in the rule itself) that an "authorized instructor" no longer needs to be present during currency work. The logic (which sounds reasonable) is that pilots can self-certify doing the work in an airplane, they should be able to self-certify in a sim.
Others quote a nearby but still present phrase in part 61 to say that an instructor is still needed to sign the log.
And lastly, speaking of the definition of "authorized instructor". I've heard of a recent legal interpertation by the FAA chief counsel's office (often a source of true irrational claptrap such as the now infamous "icing letter") that Instrument ground instructors are NOT authorized to give instruction in simulators
This despite the fact that this is a widespread practice and has been specifically mentioned as being permitted in Part 61 FAQs previously published by the FAA.One truly wishes that this organization would get its administrative act together.
So I'd like to solicit input from anyone who thinks they have insight into the facts.
1. Can IGIs teach in sims?
2. Must an authorized instructor be present to count sim time for currency (not for a rating, just currency)
3. Is a BATD or AATD approved under the old regulations now all of a sudden a very restricted "ATD"?
inquiring minds want to know!
Thread Starter
Join Date: Jan 2008
Location: Boston, MA USA
Age: 68
Posts: 18
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Still confused (though perhaps less)
SoCal,
I agree with part of your answer though I still don't think it is as clear cut as it should be. I agree that a strict parsing of the language seems to limit IGI activities to knowledge areas, 61.215(c)2 does not explicitly say what ground training for an IPC includes. Unlike the other two, it does not specifically impose limits but simply uses the unfortunatly vague word, "training". After reading the language below from the FAA, see if their use of the terms "Ground Instructor or Flight instructor" when discussing certifying simulator time doesn't seem to imply something different. The language below is not just random FAA verbage, it is from the official Federal register entry that actually officially unveiled the new Part 61. While not part of the regulation, it is part of the official clarifying language.
As for not needing an instructor present, 61.51(g)4 seems very specific:
I agree with part of your answer though I still don't think it is as clear cut as it should be. I agree that a strict parsing of the language seems to limit IGI activities to knowledge areas, 61.215(c)2 does not explicitly say what ground training for an IPC includes. Unlike the other two, it does not specifically impose limits but simply uses the unfortunatly vague word, "training". After reading the language below from the FAA, see if their use of the terms "Ground Instructor or Flight instructor" when discussing certifying simulator time doesn't seem to imply something different. The language below is not just random FAA verbage, it is from the official Federal register entry that actually officially unveiled the new Part 61. While not part of the regulation, it is part of the official clarifying language.
As for not needing an instructor present, 61.51(g)4 seems very specific:
(4) 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.
But the following official text from the Federal Register clearly states the opposite!Therefore, a person who is instrument current or is within the second 6-calendar month period (See§ 61.57(d) for currency) need not have a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of § 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator.
(See Federal Register | Pilot, Flight Instructor, and Pilot School Certification
)
(See Federal Register | Pilot, Flight Instructor, and Pilot School Certification
)
