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FAR 61.57(c)(1) question

S

Steve Brown

Well Known Member
This rule seems to allow maintaining IFR currency with the simulator of your choice, without CFI supervision. In past revisions, there were caveats about the simulator being "approved by the administrator" etc, plus the need for a CFI to log sim time. That seems to have been dropped.

I called the local FSDO, but the woman knew much less about the FARs than I did. Her and her supervisor kept referring me to section (d), which is the instrument proficiency check. I kept telling her I didn't need one of those, but she seemed unable to comprehend.

anyway. Here is the reg in question:
(c) Instrument experience. Except as provided in paragraph (e) of this section, no person may act as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR, unless within the preceding 6 calendar months, that person has:
(1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or flight training device that is representative of the aircraft category for the instrument privileges sought?
(i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of navigation systems.

Anyone have last years (or earlier) regs for comparison? anyone know if this is a deliberate change or an accidental loophole?
 
Thanks

Thanks David,

I figured there was still some restriction, but I didn't think to look that far away. It would be better if they had a reference to this near the currency requirements.
 
David, are you sure of that interpretation? I believe the question was, do you need an instructor to log your time for instrument currency on an approved simulator. I was under the impression you do not, just as you do not need an instructor aboard to log your currency (ie, a routine instrument flight) if you were flying an aircraft. This question is interesting as our EAA Chapter just purchased an approved PCFTD, and all the instructors that came and talked to us about the program indicated that if the time was being logged toward a rating, that an instrument instructor WAS needed, but if you were just logging currency (you already have the rating), an instructor was NOT needed. The caveat we were given is, if you are NOT current, then yes, you would need an instructor to log that time with you (a currency "checkride").
 
Bob Brown said:
David, are you sure of that interpretation? I believe the question was, do you need an instructor to log your time for instrument currency on an approved simulator. I was under the impression you do not, just as you do not need an instructor aboard to log your currency (ie, a routine instrument flight) if you were flying an aircraft. This question is interesting as our EAA Chapter just purchased an approved PCFTD, and all the instructors that came and talked to us about the program indicated that if the time was being logged toward a rating, that an instrument instructor WAS needed, but if you were just logging currency (you already have the rating), an instructor was NOT needed. The caveat we were given is, if you are NOT current, then yes, you would need an instructor to log that time with you (a currency "checkride").
Click to expand...

Bob,

This is what it says-

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of ?61.57(c) of this part, the following information must be recorded in the person's logbook?

(i) The location and type of each instrument approach accomplished; and

(ii) The name of the safety pilot, if required.

(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.
 
Hmmm. David, after (re)reading the FAR you cited, it does seem to say that an instructor is required for ANY logging of Flight Simulator time. Sure seems odd that an instructor is NOT required for you to log currency in a REAL aircraft but one IS required for you to sit in front of an approved FTD. FAR 51.61 (g)(3) (i,ii) seem to indicate a possible loophole (training vs currency). Anyone else with experience on this matter?
 
Currency vs Training

Bob Brown said:
Hmmm. David, after (re)reading the FAR you cited, it does seem to say that an instructor is required for ANY logging of Flight Simulator time. Sure seems odd that an instructor is NOT required for you to log currency in a REAL aircraft but one IS required for you to sit in front of an approved FTD. FAR 51.61 (g)(3) (i,ii) seem to indicate a possible loophole (training vs currency). Anyone else with experience on this matter?
Click to expand...

It makes sense to me. I think that the intent of the rule was to keep people from sitting in front of an FTD, alone, doing procedures that they are comfortable with and not being challenged. Flying in the system will provide changes and challenges that would have to be provided by an instructor in a simulated environment.

John Clark ATP, CFI
RV8 N18U "Sunshine"
KSBA
 
With a simulator, you could just crash and say "oh yeah I did 15 approaches" but in the plane you can't exactly do that. It also should be noted that most people do not have an approved device, they are at flight schools. Simulators are not airplanes, there is a big difference. You can always stop the simulator if you are task saturated and get out. Thats not very good training in my book. In an airplane you are required to have an instructor on board if you have lapsed over a year.
 
OK, maybe but WOULD YOU DO IT?

All the lawyerly interpretations aside, would you fly actual IMC in an RV if the experience that made you legal was in a simulator, without an instructor, and on a device that may not in the past have been approved?

I am one of (I suspect) many pilots who barely maintain currency for IFR by flying with a check pilot and shooting some local approaches. I'd hesitate to push that skill level very far. I'd hesitate twice and then some if I hadn't even done that but merely sat at a desk and twiddled a joy stick.

There's legal and then there is smart or wise.
 
Actually I would fly in IMC, but I have the luxury of flying in WX all the time. I can get my proficiency up. But your right, not everyone can do that. So I suppose that if you wanted to practice, then practice.

I guess what I am interpreting is the legality of it, if you got the dreaded ramp check and they asked you where you did your approaches at. I guess the question is, what is the spirit of the law.
 
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