Can I log instrument flight time for currency purposes in an Advanced Aviation Training Device (AATD)?

Question

Advisory Circular AC 61-136 which outlines the approval and limitations of flight training devices seems to contradict 14 CFR 61.57(c).

To what extent can I use an AATD for instrument currency? In addition, to what extent can an AATD be used toward and instrument proficiency check (IPC)?

Edit:

I have located this document from the FAA Office of Aviation Safety that clarifies that AATDs and BATDs are governed by FAR 61.4(c) and are authorized for specific purposes and can be used in the same manner at a Flight Training Device instead of a Aviation Training Device as long as they have an approve Letter of Agreement (LOA) from the administrator.

This leads me to believe that an AATD qualifies for FAR 61.57(c)(2) not FAR 61.57(c)(3).

Answer 1

From what I can tell, the Advisory Circular is outdated. It was issued July 14, 2008, while the most recent update to 14 CFR 61.57 was effective Nov 15, 2013.

When the AC was issued, 61.57(c) did not contain the wording specific to Aviation Training Devices (effective 11/17/2003). That language was added in the version effective 10/20/2009, and the AC apparently has not been revised since that point.

At this point the regulations are more specific (and regulatory) than the Advisory Circular. You should be able to log recent flight instrument experience in a ATD based on 61.57(c)(3), or the subsequent subsections that pertain to mixed currency.

(3) Use of an aviation training device for maintaining instrument experience. Within the 2 calendar months preceding the month of the flight, that person performed and logged at least the following tasks, iterations, and time [emphasis mine] in an aviation training device and has performed the following--

(i) Three hours of instrument experience.
(ii) Holding procedures and tasks.
(iii) Six instrument approaches.
(iv) Two unusual attitude recoveries while in a descending, Vne airspeed condition and two unusual attitude recoveries while in an ascending, stall speed condition.
(v) Interception and tracking courses through the use of navigational electronic systems.

Answer 2

I wrote this back in 2014 following a briefing on a Cardinal accident where two people perished on approach to CYOW (Ottawa). I should have posted it here back then.

At an IFR Club meeting on 27 Feb 2014 involving the accident of C-FEFQ, the issue of improperly logging “instrument time” for IFR recency was highlighted. I believe that commercial pilots, cruising along in VMC in Class A airspace where operations are IFR, log all their flight time as “instrument time” even when they are on autopilot and not actually operating the aircraft. This is probably why many GA IFR pilots log their IFR time (in VMC) as “instrument time” as well. Unfortunately, based on the Canadian CARs, GA IFR Pilots cruising along in VMC at 5000’ on an IFR flight plan cannot log their flight time as “instrument time” unless it is either actual flight instrument time, simulated flight instrument time or ground instrument time. There seems to be a problem of interpretation in logging “instrument time” that no one wants to address. There is even a problem with the term "IFR Time" itself, which isn't your Flight Time. IFR Time really means your time in the IFR system. You could be in VMC for quite awhile before getting your clearance, then have your IFR clearance cancelled well before arriving at your destination. Your IFR Time would be less than your Air Time, an you never even see a cloud!

I believe this issue of logging “instrument time” has been debated for years and years (and years!) with lots of interpretations based on FARs Section §61.51- Pilot logbooks and §61.57- Recent flight experience: Pilot in command, as well as CARs Part IV - Personnel Licensing and Training, Section 401.05(3) - Recency Requirements and Section 401.08- Personal Logs.

Here is how I would recommend logging your “instrument time” for recency. In each situation you must be operating the aircraft or approved simulator solely by reference to the flight instruments:

Actual Flight instrument time

• This is your time spent in cloud, smoke, fog, haze, mist or dark night conditions when you don’t have any horizon or lights for visual reference to the ground during an actual flight in non-VFR conditions.

• If you are in these non-VFR conditions, you will obviously have to be on an IFR Flight Plan to be legal.

• If you are in non-VFR conditions for the entire flight you can only take credit for up to the maximum Air Time ( up – down), not the entire Flight Time. You are not flying solely on instruments while taxiing.

Simulated Flight instrument time

• This is your time spent simulating cloud, smoke, fog, haze, mist or dark night without an horizon or without visual reference to the ground during an actual flight and in VFR conditions.

• You are expected to have a safety pilot with you and to use a view limiting device or hood in order to get credit for logging this simulated flight instrument time.

• The safety pilot will also be your instructor when you are conducting IFR training in order to get credit for logging this simulated flight instrument time. You are allowed to log it, and your instructor (PIC) is also allowed to log it.

• You can only take credit for the time that you are simulating instrument conditions. This may be less than the Air Time depending upon when you start and stop flying by sole reference to the flight instruments.

Ground instrument time

• This is your time spent simulating non-VFR conditions on a simulated IFR flight in an approved flight simulator.

• An instructor is expected to be with you when you are conducting IFR training in order to get credit for this ground instrument time, but if you are an IFR rated pilot you don’t need an instructor. You can be alone or with another pilot.

• If you are in non-VFR conditions for the entire flight you can only take credit for up to the maximum simulator Air Time (up – down), not the total simulator Flight Time as the simulator could be paused during the simulated flight.

These are suggested guidelines or best practices for estimating and logging “instrument time” that anyone should be able to follow to meet the 6 hours and 6 approaches in 6 months rule. There are differences between US and Canadian IFR recency requirements also creates more confusion. Even approved training devices are described differently so this discussion could continue endlessly.

My conclusion is that logging “instrument time” is based on your good judgement to determine if the flight was under instrument flight conditions. It is also based on the honour system for reporting your time. Please feel free to disagree with my interpretations and discuss as needed. I hope that a “standard” interpretation will eventually be achieved through consensus.