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 FAA has historically created confusion regarding instructor sign-offs for simulator-based instrument currency due to inconsistent Letters of Authorization (LOAs) and conflicting guidance within its own regulations and interpretations.
Multiple FAA legal interpretations have clarified that 14 CFR 61.51(g)(4) is the controlling regulation, explicitly requiring an authorized instructor to be present to observe and sign a pilot's logbook for simulator time to count towards instrument currency.
Despite previous ambiguities and logical arguments for self-logging, the definitive legal stance is that an instructor sign-off is mandatory for pilots to properly log simulator time for instrument recency experience.

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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.