Instrument Currency

[meritflyer]

I scheduled some time in a sim tomorrow at a local flight school. The CFI (non-CFII) called me back and said he couldn't operate the sim for me since he was not a II.

It's just approaches for currency NOT an IPC or anything else instruction related.

I found it interesting that he said -

1) A pilot can not fly the sim by themselves for currency since "you need a signature from the II or authorized instructor";

2) A CFI (not II) can not operate the sim even if it's not for an IPC or rating; and

I tend to believe that a pilot could fly a sim solo for instrument currency (if the sim is appropriately rated) and 2) a CFI (not II) could operate the sim for such purposes.

 

[JEP]

I was always under the impression that any time logged for whatever reason in a sim required an instructor. I have never heard that a pilot alone could log time in the sim for currency.

 

[tgrayson]

I tend to believe that a pilot could fly a sim solo for instrument currency (if the sim is appropriately rated) and 2) a CFI (not II) could operate the sim for such purposes.

I'm reposting what I sent you via PM:

The regulations don't specifically require a signature from the instructor in order to log the approaches for currency. The regs just say:

(4) A flight simulator or approved flight training device may be used by a person to log instrument time, provided an authorized instructor is present during the simulated flight.
​

Since no training is involved, there is no real need for the person to be a -II, based solely on the regulation itself.

However, the old Part 61 FAQ's did interpret this as training and said "we write the rules and our interpretation is correct by definition", which sounds rather childish to me. Here's what they said:

===================================
QUESTION: Would a pilot using an approved flight simulator or flight training device to meet the instrument currency requirements of paragraph 61.57(c)(1) or (2) need to have an instructor present?

ANSWER: Ref. § 61.1(b)(10) and § 61.51(g)(4); Yes, if using a flight simulator (FS) or a flight training device (FTD), the instrument currency requirements must be accompanied and monitored by a:
1. Certificated Flight Instructor-Instrument (CFII) who is appropriately rated and qualified;
2. Instrument Ground Instructor (IGI);
3. Advanced Ground Instructor (AGI);
4. Part 142 training center instructor who is appropriately rated and qualified;
5. Persons cited in § 61.57(d)(2) and who are appropriately rated and qualified;
6. An ATP in accordance with § 61.167 and who is appropriately rated and qualified; and
7. An authorized instructor as defined in § 61.1(b)(2), and who is appropriately rated and qualified.


And for those of you who will argue that currency is not the same as training, the answer is still yes. We here in AFS-840 write the rules and we also write the policy and we say that currency is training. So, the answer is yes.

To use a FS or FTD you have to have an authorized instructor there to monitor the training.
=============================

So the FAA opinion, which really has no legal standing anymore, is that the instructor must be a -II. Note that still they didn't say there is a signature required, but as you know, CFI's are required to endorse logbooks for training. To know for sure would require a letter of interpretation from the General Counsel's office.

 

[bap327]

II or IGI is needed for the time to "count". You can fly the sim for "your" currency but it doesn't count for the FAA.

 

[deadstick]

Just curious, what about the 3 hrs of hod time for the ppl? That is training, but a CFI can do it. And can't part of that be done on a sim?

 

[Air Pirate]

61.109(a)(3)

"3 hours of flight training IN A single-engine AIRPLANE on the control and maneuvering of an airplane soley by reference to instruments..."

 

[deadstick]

61.109(a)(3)

"3 hours of flight training IN A single-engine AIRPLANE on the control and maneuvering of an airplane soley by reference to instruments..."

DOH! Does anybody know if this changed since...(cough-cough) the late 80's? I ask because I know had a lesson or two in an ATC610 for this. Ok, so what about the other part? Why could a CFI do this in VMC and not sit at a box?

 

[tgrayson]

DOH! Does anybody know if this changed since...(cough-cough) the late 80's? I ask because I know had a lesson or two in an ATC610 for this.

The THREE hours wasn't required until the late 90's sometime. I threw away all those FAR/AIMs (why, oh, why?). When I was trained, the only requirement was "some" training in flight by reference to instruments, but I don't recall whether it said "AIRPLANE".

 

[SJM]

61.109(a)(3)

"3 hours of flight training IN A single-engine AIRPLANE on the control and maneuvering of an airplane soley by reference to instruments..."

I know someone that did 2 of those instrument hours in a sim...

61.109(k)(1):

(k) Permitted credit for use of a flight simulator or flight training device. (1) Except as provided in paragraphs (i)(2) of this section, a maximum of 2.5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section, if received from an authorized instructor.

 

[FriendlySkies]

Lets make it simple...Training in the sim, in IMC but not for currency requires only a CFI or AGI. In IMC and for currency (such as a 61.57 check) requires a CFII or AGI. not sure if an ATP could do it.

 

[tgrayson]

I know someone that did 2 of those instrument hours in a sim...

61.109(k)(1):

(k) Permitted credit for use of a flight simulator or flight training device. (1) Except as provided in paragraphs (i)(2) of this section, a maximum of 2.5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section, if received from an authorized instructor.

This regulation just allows the 2.5 to be counted towards the total flight time required. It can't substitute for any of the specifically mentioned training, such as the flight by reference to instruments, night time, cross country, etc.