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A flight simulator system company has a system that they say lets you "Log IFR Currency without an Instructor." Can someone explain to me how exactly that works?
Does that mean that an Instrument rated pilot only needs a simulator to stay current?
Note: I am not a pilot so I don't know about currency requirements. I'm just curious.
UPDATE: 83 FR 30232, updated the requirements of 61.51(g) where an instructor is NO LONGER required to be present in order to log time in a flight simulator or aviation training device for instrument currency. Note that an instructor is still required in order to log simulator time that counts towards a rating or certificate and that a FAA approved device must be used. This particular change was effective July 27, 2018.
The following is no longer accurate, but retained for historical purposes:
There has been quite a bit of confusion in this area due to language in a preamble to the 2009 Final rule on Pilot, Flight Instructor, and Pilot School Certification, which implied that an instructor was not required for instrument currency and 14 CFR 61.51(g)(4) which says that an instructor must be present. I believe this all started with an email to John King of King Schools, where Lance Nuckolls at AFS-810 stated:
...approved uses for a BATD and an AATD are governed by § 61.4(c) and the LOA. The LOA states that an authorized instructor must certify the instructional use. Simply satisfying the requirements of § 61.57(c)(2) is not considered instructional use, therefore an authorized instructor does not need to be present.
(Emphasis added)
Interestingly enough, the PDF of this email is no longer available on the King Schools website. Instead users are redirected to the Rebird TD page where it now implies that an instructor is required to maintain instrument currency. A copy of the message text is available here.
Of course, this was too much of a good thing, so someone had to get the lawyers involved! In Keller (2010), the FAA's Office of the Chief Counsel made their opinion known:
...in order to log the time an instructor must be present to observe an individual using a flight training device or flight simulator to maintain instrument recency experience.
This position was reasserted in Stewart (2014), which references the Keller letter and explicitly cites 14 CFR 61.51(g)(4).
So we now have a situation where the FAA doesn't agree with itself! Whose opinion wins? The lawyers', of course! In Perry (2010), the Chief Counsel's office states:
...where two interpretations address an identical scenario and reach an inconsistent result, the interpretation issued by the Assistant Chief counsel for Regulations takes precedence.
Some additional background:
I believe the author is referring to the Redbird Flight Simulations' FAA approval page where it states:
When using the Redbird to maintain instrument currency an instructor is not required to be present. This has been discussed with and confirmed by AFS-810. A current Instrument pilot is not required to have an instructor on board the real aircraft to log approaches in IMC, therefore it follows that the FAA trusts a pilot to correctly log an approach preformed in the Redbird.
On its face, this statement appears to be in direct conflict with FAA's legal interpretation. Of course, one could try challenging this position (an interpretation is an opinion, after all), but it won't be me!
Recent changes to the rules just took effect.
https://www.aopa.org/news-and-media/all-news/2018/june/27/faa-cuts-cost-of-training-proficiency
14 CFR §61.51 Pilot logbooks. (g) Logging instrument time. (5) A person may use time in a full flight simulator, flight training device, or aviation training device for satisfying instrument recency experience requirements provided a logbook or training record is maintained to specify the training device, time, and the content.
(2018) Here is my Canadian interpretation after recently posting some guidelines on Logging “Instrument Time” for IFR Recency Requirements. I was initially told that an "IFR rated" pilot needs an instructor with them in the simulator to log “ground” instrument time. I could not see the logic in having an instructor in the seat beside you when you can fly in actual IMC without an instructor. I therefore indicated that you only needed an instructor with you if you were under “training” or getting your "Instrument Proficiency Check" in order to log ground instrument time.
It is fairly obvious that an instructor is expected to be with you when you are conducting "IFR training" and 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.
As a result of this feedback, I further checked and found out that the FAA have changed their interpretation of their regulations in 2010. They have certified the Redbird as an Advanced Aircraft Simulation Device (AATD) and confirmed that you can log your IFR recency requirements without an instructor. This is a US interpretation, so I don’t believe Transport Canada has caught up with the new definitions of BATD and AATD, nor the current simulator technology.
I also wrote to Redbird Flight Simulations, Inc. to confirm the FAA legally approved uses of the RedBird FMX as well as this new interpretation. Their reply is as follows (this was quoted in the previous comment):
**On August 21, 2009 in the initial notice of changes to the Federal Register, there was conflicting language in CFR 61.51(g)(4) between the preamble and the rule making itself as to whether an instructor must be present in order to log approaches for instrument recency experience. On August 6, 2010, an opinion by Neal O’Hara, Attorney in the Regulations Division of the Office of the Chief Counsel and distributed by Rebecca MacPherson, Assistant Chief Counsel for Regulation specified that when there is a discrepancy between the preamble and the rule, the rule will govern and as such, would require an instructor to be present. However, due to the conflicting language the issue was forwarded back to Flight Standards Service for review and comment. After this occurred, John King of King Schools (and a reseller of Redbird products) contacted Flight Standards Service to clarify the conflicting language. In an opinion returned to John King on November 3, 2010, Flight Standards agreed that the language specifies that instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience requires an authorized instructor sign the person’s logbook or training record to verify the time and the content of the training session. Per Flight Standards, the operative term is “training session”. Their interpretation is that a person, who is current, logging the time and experience necessary to maintain instrument recency experience (CFR 61.57(c)(2)) is not a “training session”. Therefore, CFR 61.51(g)(4) does not apply to an instructor being present for instrument recency. Furthermore, according to Flight Standards, the LOA (Letter of Authorization) for the AATD states that an authorized instructor must certify instructional use. Satisfying the requirements of CFR 61.57(c)(2) is not considered instructional use, therefore an authorized instructor does not need to be present.* I have attached a link below that will give you the full text of the communication between John King and Lance Nuckolls of Flight Standards.*
Subsequently, based on this information and no information from the FAA since the publication of this information on November 3, 2010 that conflicts with this interpretation, we still are of the opinion that as long as a pilot has not exceeded the 6-month window, instrument recency may be logged without an instructor present.
Here is my summary for 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 training device (FSTD).
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. Also remove the time the simulator is paused during the simulated flight.
