Can ATD Simulators Replace Sim Instructors?

Do ATD simulators replace the requirement of sim instructors? Weve clearly stated in a previous article that an instructor signoff is not required if youre using a simulator (ATD) to maintain your instrument currency, but now the FAA has changed its mind. Ultimately, what matters is the necessity of logging instrument time, which an instructor is mandated to sign on while you fly. The whole point of maintaining currency is to log proof of compliance, so no- sim instructors are here to stay.

IFR Staff

Friday, December 04, 2015 at 12:00 AM ET

Verified

Key Takeaways:

The article addresses the long-standing controversy and confusion surrounding the requirement for an instructor sign-off when using a simulator (ATD) to maintain instrument currency.
Despite historical inconsistencies in FAA guidance, Letters of Authorization (LOAs), and conflicting regulation preambles, FAA legal counsel has repeatedly clarified the correct interpretation.
According to FAA legal interpretations of 14 CFR 61.51(g)(4), an authorized instructor must be present to observe and sign a pilot's logbook when using a flight simulator or ATD to acquire instrument recency experience.
The article concludes that while enforcement may be rare, pilots should adopt a conservative view and obtain an instructor sign-off to ensure their instrument currency is legally compliant.

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We’ve clearly stated in a previous article that an instructor signoff is not required if you’re using a simulator (ATD) to maintain your instrument currency per 14 CFR 61.57(c) (3). So has the FAA. Then, in another article, we’ve just as clearly stated that an instructor signoff is, indeed, required. And, so has the FAA. Perhaps this controversy is something we should explore.

Under the Hood

Controversy is always a ripe subject for IFR, so we dug into this from different angles. We looked inside the FAA and found a can of worms. We researched the applicable Aviation Circular, AC-61.136A. We spoke to a couple different ATD manufacturers. We examined the simulators’ Letters of Authorization that formally specify what can be done in an Aviation Training Device or ATD, which can be either Basic (BATD) or Advanced (AATD). We researched the Federal Register as well as letters from the FAA’s Office of Chief Counsel.