MidlifeFlyer
Well-Known Member
As some may or may not know, the FAA has a customer service website (http://faa.custhelp.com) where they post answers to common questions. One of the 2009 changes to Part 61 involved expanded use of ATDs for instrument currency. If you read the regs, there's an interesting hole.
Anyway, I decided to give the FAA Customer Service site a try. Here's the results. Sorry, no reading ahead to the punchline:
Me: In addition to expanding the use of ATDs, the 2009 revision to 61.57 appears to have limited the use of a combination of flight in aircraft and the use of simulators and FTDs. Previously, one could use a combination of aircraft and simulator/FTDs to meet the 6 approach requirement. Now it appears that they cannot be used in combination at all, unless there is also an ATD in the mix. At least as the reg reads, you can do the 6 in an aircraft, the 6 in a sim/FTD, with the only approved combination being an aircraft, a sim/FTD and an ATD. The Final Rule Supplementary Material give no guidance on this limitation; is it merely an error in the way the rule was re-written or was it intentional?
FAA: Your local FAA Flight Standards District Office (FSDO) can give the best answer to your question. Their personnel will evaluate your question along with any specific issues you may have. You can find contact information for your local FSDO on our website at: http://www.faa.gov/about/office_org/field_offices/fsdo/
Thank you for your question.
Me: This is a national issue that is subject to multiple interprettation and needs to be dealt with on a national not a reigonal basis. What happens if FSDO A says you're current but you have an incident at FSDO B and they decide you're not?
FAA: Our FSDOs are standardized and provide the same information.
Anyway, I decided to give the FAA Customer Service site a try. Here's the results. Sorry, no reading ahead to the punchline:
Me: In addition to expanding the use of ATDs, the 2009 revision to 61.57 appears to have limited the use of a combination of flight in aircraft and the use of simulators and FTDs. Previously, one could use a combination of aircraft and simulator/FTDs to meet the 6 approach requirement. Now it appears that they cannot be used in combination at all, unless there is also an ATD in the mix. At least as the reg reads, you can do the 6 in an aircraft, the 6 in a sim/FTD, with the only approved combination being an aircraft, a sim/FTD and an ATD. The Final Rule Supplementary Material give no guidance on this limitation; is it merely an error in the way the rule was re-written or was it intentional?
FAA: Your local FAA Flight Standards District Office (FSDO) can give the best answer to your question. Their personnel will evaluate your question along with any specific issues you may have. You can find contact information for your local FSDO on our website at: http://www.faa.gov/about/office_org/field_offices/fsdo/
Thank you for your question.
Me: This is a national issue that is subject to multiple interprettation and needs to be dealt with on a national not a reigonal basis. What happens if FSDO A says you're current but you have an incident at FSDO B and they decide you're not?
FAA: Our FSDOs are standardized and provide the same information.
