Simulator Use?  Well, I'm Confused

If you listen to the talk around your local FBO, you get a lot of "This I know" from the airport regulars on the subject of simulator use. A lot of it is wrong and it is no surprise.  To fully understand how we pilots can use simulators for training we need to look in several different places. Let's sort them out.

what  is a simulator?

 aviation training device?

 flight training device?

First of all, what is a simulator? Or an aviation training device? Or a flight training device?  Well, we might think that these are three names for the same animal, but the FAA does not.  I won't go into all the details about what makes a device fall into one category and not another except to say this: Unless you flying a ground-based device that looks exactly like the inside of an Airbus or Gulfstream or such, you are flying an Aviation Training Device (ATD).  And, I am going to address my comments solely to ATDs

So, where do find the rules and regulations concerning any flight training that is not in an airplane?  Five places, actually, and we have to put them all together – we cannot pick and choose.  They are:


Redbird BATD

  • FAR Part 61-51 - Pilot logbooks
  • FAR Part 61.57 - Recent flight experience: Pilot in command
  • FAR Part 61.65 - Instrument rating requirements
  • Aviation Circular 61-136A: FAA Approval of Aviation Training Devices and Their Use for Training and Experience
  • InFO 15012 – Logging Instrument Approach Procedures (IAPs)
  • (and 61.109 - Private Pilot – Aeronautical Experience, which is silent on the subject.)

Simulator - Flight Safety

Let's start with AC 61-136A, because this is where we get the definition of the equipment. This is pretty dry, but just jump to Appendix 2 and 3.  Appendix 2 describes the attributes of a Basic Aviation Training Device (BATD), and Appendix 3 describes the attributes of an Advanced Training Device (AATD)

A half-step back.  Some pilots, and non-pilots alike, have used various computer programs and games to fly simulated aircraft.  These often are mouse-driven, or keyboard-driven, or maybe have a joystick attached.  They generally have one, but sometimes more, monitor(s) and allow us to "fly" several different aircraft.  These are NOT ATDs.  The attributes of a BATD are precisely spelled out, and must include:

  • Flight instruments that look like the instruments in the plane
  • All of the controls, switches etc. that we see in the plane, and they must work identically to those in the plane.
  • A yoke or stick and throttle quadrant and rudder pedals.
  • A means for an instructor to pause the program without using a keyboard or mouse.
  • A means of recording the flight or playback

And two pages more

And AATD will have all of the Basic ATD features, and will add:

  • Motion capability, encouraged but not required
  • A realistic shrouded or unshrouded  (enclosed or open) design
  • An independent visual cuing system, which allows the pilot to "see" his surroundings.
  • And more

Little Blue Aviation AATD

So, in general, the AATD will put the pilot inside of some closed container which need not look like the inside of a real plane. But the flight panel must look like the plane it represents – Cessna, Beech, Piper, etc, and it must have full motion and outside screens which realistically show the outside world. The BATD will have a realistic instrument panel, but will not have motion or outside simulation.

So, now how do we get to use this equipment? First of all, there is no restriction on how much a pilot can use an ATD for training or for recurrency. In fact, the FAA and the flight training industry at large enthusiastically encourage ATD use, with or without a CFI. But when it comes to using an ATD as a substitute for training in an aircraft, three FAR paragraphs come into play. Let's start with FAR 61.51 and get that out of the way.

Open 61.51, and drop down to paragraph (g) 4. This paragraph states

A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session .

Interesting wording. A pilot who wants to use the aviation training device does not need to be supervised by an authorized instructor, nor does he/she need to actually receive any instruction. However, the instructor needs to be present to observe the time and then needs to sign the logbook verifying the time and content of the training session. My thought – If you are going to pay for an instructor to hang around and sign your log book, make her work for her pay and actually teach you something.

There are four regulatory situations in which we are required to log instrument time. The first time is when we work toward our Private Pilot's License and we are required to receive three hours of instrument instruction. The second is when we seek an instrument rating, and we are required to log forty hours of instrument time, including twenty hours of instruction. The third and fourth situations are the recurrency requirements, in which we actually log instrument time, and / or in which we take an Instrument Proficiency Check

Private Pilot training – Part 61.109 lists in dreary detail the flight experience requirements for the Private Pilot License, single-engine-land. Paragraph (a) 3 dictates:

3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight

So, although a simulator can be used for the PPL, it cannot be used to satisfy the requirement for three hours of instrument instruction. However, buried at the end of 61.109, in paragraph (k) is the statement - ". . . a maximum of 2.5 hours of training in a flight simulator . . may be credited toward the flight training ." I find it curious that this paragraph does not limit the 2.5 hours to the instrument portion of the Private Pilot flight training ." On to the Instrument Rating

Instrument training – We are now governed by FAR 61.65. And this one is brief and easy to follow

  • (i) Use of an aviation training device. A maximum of 10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device may be credited for the instrument time requirements of this section if—
  • (1) The device is approved and authorized by the FAA;
  • (2) An authorized instructor provides the instrument time in the device; and
  • (3) The FAA approved the instrument training and instrument tasks performed in the device

So, find a full-motion ATD and you can log half of your hours. Using a Basic ATD still allows you to log 10 hours. (However, you cannot take 20 of one and then 10 more of the other.)

Recurrency training. Let's look first at recurrency if we are using an aircraft. FAR 61.57 states:

  • (c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if:
  • (1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
  • (i) Six instrument approaches.
  • (ii) Holding procedures and tasks.
  • (iii) Intercepting and tracking courses through the use of navigational electronic systems

6 months
3 hours
6 approaches
unusual attitude recoveries
course interception

If we want to accomplish this recurrency with an ATD, we have already established that we need to have a CFI-I present. Paragraph (2) of 61.57 allows us to use a simulator or Fight Training Device to get our recurrency. But we have already seen that we do not have a simulator or FTD – we have an Aviation Training Device. So we are governed by paragraph (3), which tells us:

(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 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.

2 months
3 hours
6 approaches
unusual attitude recoveries
course interception

So, we can use an ATD for recurrency, but the requirements are a good deal more stringent than using an airplane.

Instrument Proficiency Check – And finally, "If I need an Instrument Proficiency Check (IPC), can I take it using an ATD?" Short answer – "YES".

(d) Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of the areas of operation and instrument tasks required in the instrument rating practical test standards. (1) The instrument proficiency check must be— (i) In an aircraft that is appropriate to the aircraft category;
(ii) for other than a glider, in a flight simulator or flight training device
that is representative of the aircraft category

What constitutes "an approach?" The last question that seems to come up when using an ATD for log approaches has to do with exactly how the FAA defines "approach" in the context of training and recurrency. And actually, that question comes up as well when using an aircraft to log currency. If we go in the weather just after passing the final approach fix, but break out three hundred feet above minimums, can we log an approach for recurrency requirements? Well, others have apparently asked this question, and the FAA addresses it in InFo 15012. (And InFOs are the FAAs way of explaining themselves when they don''t want the force of a regulation.)

Not too surprisingly, the answers vary. If we are in an airplane, and in IMC conditions at any point in the approach and we transition to visual conditions after the Final Approach Fix, we can log it as an approach.

If we are in an airplane in VMC with a vision-restricting device, or if we are using an ATD, we need to be in simulated instrument conditions from a point prior to the Initial Approach Fix (IAF), then to the Final Approach Fix (FAF) and then all the way to the published Missed Approach Point (MAP).

So does this clear up some confusion? I hope so



Don't Practice Until You Get It Right - Practice Until You Don't Get It Wrong

Comments, questions, or just want to chat about anything aviation?  Drop me a note or call: 816-763-5205

updated August, 2020