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 explores a long-standing controversy regarding whether an instructor signoff is required when using a simulator (ATD) to maintain instrument currency.
The confusion arises from conflicting FAA guidance: while 14 CFR 61.57 allows ATDs for currency, 14 CFR 61.51(g)(4) explicitly states that an authorized instructor must be present to observe and sign off on simulator time for it to be legally logged for recency.
Multiple FAA legal interpretations have consistently affirmed that 14 CFR 61.51(g)(4) controls, making an instructor signoff mandatory for logging instrument currency in an ATD, despite other omissions or perceived logical inconsistencies.
Pilots are advised to obtain an instructor signoff when maintaining instrument currency in an ATD to ensure their status is legally verifiable and avoid potential issues.

See a mistake? Contact us.

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.