Another FAR 61.57 Experience Question

[Jaybird180]

C (2) and (3) makes a distinction between Flight Simulator, flight training device and aviation training device. Where can I find the definitions of these distinctions?

Why does it require unusual attitude recoveries in the ATD only and not in the other 2? Why is it required every 2 months whereas the other devices and use of the airplane the PIC can go 6 months?
(I suppose understanding the differences in the devices will reveal the answers to the above questions)

Are there any ATDs that can automatically setup each requirement for Instrument Experience requirements?

Finally, I don't see in this section where a CFII is required. From that I can assume that I can do this at home on my own time and log it as 61.57 training requirements.

(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.
  (2) Use of a flight simulator or flight training device 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 a flight simulator or flight training device, provided the flight simulator or flight training device represents the category of aircraft for the instrument rating privileges to be maintained and 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.
  (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.
  (4) Combination of completing instrument experience in an aircraft and a flight simulator, flight training device, and aviation training device. A person who elects to complete the instrument experience with a combination of an aircraft, flight simulator or flight training device, and aviation training device must have performed and logged the following within the 6 calendar months preceding the month of the flight--
  • 
    
    (i) Instrument experience in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained, performed in actual weather conditions, or under simulated weather conditions while using a view-limiting device, on the following instrument currency tasks:
    • 
      (A) Instrument approaches.
      (B) Holding procedures and tasks. (C) Interception and tracking courses through the use of navigational electronic systems.
    (ii) Instrument experience in a flight simulator or flight training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves performing at least the following tasks--
    • 
      (A) Instrument approaches.
      (B) Holding procedures and tasks. (C) Interception and tracking courses through the use of navigational electronic systems.
    (iii) Instrument experience in an aviation training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves performing at least the following tasks--
    • 
      (A) Six instrument approaches.
      (B) Holding procedures and tasks. (C) Interception and tracking courses through the use of navigational electronic systems.
      
      

 

[poadeleted20]

C (2) and (3) makes a distinction between Flight Simulator, flight training device and aviation training device. Where can I find the definitions of these distinctions?

14 CFR 61.1...

(6) Flight simulator means a device that--

• 
  (i) Is a full-size aircraft cockpit replica of a specific type of aircraft, or make, model, and series of aircraft;
  (ii) Includes the hardware and software necessary to represent the aircraft in ground operations and flight operations;
  (iii) Uses a force cueing system that provides cues at least equivalent to those cues provided by a 3 degree freedom of motion system;
  (iv) Uses a visual system that provides at least a 45 degree horizontal field of view and a 30 degree vertical field of view simultaneously for each pilot; and (v) Has been evaluated, qualified, and approved by the Administrator.

(8) Flight training device means a device that--

• 
  (i) Is a full-size replica of the instruments, equipment, panels, and controls of an aircraft, or set of aircraft, in an open flight deck area or in an enclosed cockpit, including the hardware and software for the systems installed, that is necessary to simulate the aircraft in ground and flight operations;
  (ii) Need not have a force (motion) cueing or visual system; and (iii) Has been evaluated, qualified, and approved by the Administrator.

...and AC 61-136.

a. Basic Aviation Training Device (BATD).

[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]A BATD is a device that: [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](1) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Meets or exceeds the criteria outlined in Appendix 2 (BATD Requirements) of this advisory circular (AC), [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](2) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Provides a training platform for at least the procedural aspects of flight relating to an integrated ground and flight instrument training curriculum, and [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](3) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The Federal Aviation Administration (FAA) finds acceptable in a manner as outlined in this AC. [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT]b. Advanced Aviation Training Device (AATD). ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]An AATD is a device that: [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](1) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Meets or exceeds the criteria outlined in Appendix 2; [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](2) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Meets or exceeds the criteria outlined in Appendix 3 (AATD Requirements); [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](3) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]Provides a training platform for both procedural and operational performance tasks related to ground and flight training towards private pilot, commercial pilot, and airline transport pilot certificates, a flight instructor certificate, and instrument rating per Title 14 of the Code of Federal Regulations (14 CFR) parts 61 and 141; and [/FONT][/FONT][FONT=Times New Roman,Times New Roman]

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[/FONT](4) ​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The FAA finds acceptable in a manner as outlined in this AC. [/FONT][/FONT][FONT=Times New Roman,Times New Roman]
[/FONT]​

Why does it require unusual attitude recoveries in the ATD only and not in the other 2? Why is it required every 2 months whereas the other devices and use of the airplane the PIC can go 6 months?

I don't know, but the answer is probably in the preamble to either the NPRM or the Final Rule for that change to 61.57(c).

Are there any ATDs that can automatically setup each requirement for Instrument Experience requirements?

None of which I am aware.

Finally, I don't see in this section where a CFII is required.

That's because it is in 61.51(g)(4), not 61.57.

(4) 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.

From that I can assume that I can do this at home on my own time and log it as 61.57 training requirements.

You would be incorrect in your assumption, according to the FAA Chief Counsel.
http://www.faa.gov/about/office_org...nterpretations/data/interps/2010/Keller-1.pdf
AFS-800 thinks it should be otherwise, and that's the subject of an ongoing internal FAA debated, but when it comes to the regulations, by the Administrator's direction, the Chief Counsel has the final word.
​

 

[midlifeflyer]

http://www.faa.gov/about/office_org...nterpretations/data/interps/2010/Keller-1.pdf
AFS-800 thinks it should be otherwise, and that's the subject of an ongoing internal FAA debated, but when it comes to the regulations, by the Administrator's direction, the Chief Counsel has the final word.
[/LEFT]

Oh please. The reg writers have the final word on this one.

All the reg-writers had to do was actually write the regulation they intended to write. Or make one of those technical corrections to fix their screw-up since the issue and it's resolution was already published in the Federal Register. Why blame the Chief Counsel for pointing out that while the reg writers may have intended to say, "you may enter the intersection and make a right turn on a red light,". they actually said, ""you may not enter the intersection and make a right turn on a red light"?

 

[poadeleted20]

Why blame the Chief Counsel for pointing out that while the reg writers may have intended to say, "you may enter the intersection and make a right turn on a red light,". they actually said, "you may not enter the intersection and make a right turn on a red light"?

Beats me. AFS-800 goofed, and now they're trying to allow what the reg they wrote doesn't allow by writing a letter of authorization saying you don't need an instructor for a BATD and claiming 61.4 permits them to change the rules at their will this way instead of going through the legally correct rulemaking process of either revising 61.51(g)(4) to eliminate the phrase "or instrument recency experience" or processing an exemption through the Federal Register. The Chief Counsel's office is refusing to go along with that bypass of the Administrative Procedures Act -- no doubt something a lawyer like Mark understands.

Meanwhile, Redbird and King Schools are telling their customers it's OK to violate 61.51(g)(4) in this context because they have a letter from AFS-800 saying you don't need an instructor to log recent instrument experience on a BATD. They're posting that letter with but not telling anyone about the Keller letter, of which they are aware (I've communicated with a King VP on this). The VP told me that as long as AFS-800 says it's OK, they'll tell their customers it's OK no matter what the Chief Counsel says.

Me? I'm telling my trainees the whole story, and recommending they do what the plain reading of the regulation and the Chief Counsel both say.

 

[dell30rb]

From what you mentioned about the Elite sim your club has, it is likely a BATD and you can log up to 10 hours of time (IF it is dual, with a CFI supervising) toward the instrument rating. I went for my checkride with 35 hours in the plane, 5 hours in the sim.

 

[nosehair]

Why does it require unusual attitude recoveries in the ATD only and not in the other 2? Why is it required every 2 months whereas the other devices and use of the airplane the PIC can go 6 months?

I don't know for sure, but the main difference in a simulator and an ATD is that the sim has motion and the ATD does not.

 

[ujocka]

I know this thread is old, however I found it interesting that Precision Flight Controls has their BATDs certified under 61.57(c)(2), which allows them to take advantage of the same IFR currency requirements as FTDs and an aircraft. When comparing the Redbird tabletop and Precision's BATDs, this was the tie breaker for me. The Redbirds and all other BATDs I have found are under 61.57(c)(3), which has ridiculous requirements and timeframes.

 

[poadeleted20]

I know this thread is old, however I found it interesting that Precision Flight Controls has their BATDs certified under 61.57(c)(2), which allows them to take advantage of the same IFR currency requirements as FTDs and an aircraft. When comparing the Redbird tabletop and Precision's BATDs, this was the tie breaker for me. The Redbirds and all other BATDs I have found are under 61.57(c)(3), which has ridiculous requirements and timeframes.

61.57(c) does not cover the certification of either flight simulation training devices (FSTD's, including both full flight simulators and FTD's) or aviation training devices (ATD's). That's covered by Part 60 for FSTD's and AC 61-136 for ATD's. So, I'm not sure how you came up with what you posted.

 

[EdFred]

Just go fly a plane and not worry about sims.

 

[cirrusmx]

dont even bother. at the spam can, level sims are pretty much worthless. you are better off flying the real airplane than wasting time and money flying a pc while thinking you are logging acceptable/useful flying experience. for practicing procedures you might as well play fsx.

 

[Palmpilot]

I find that using MS Flight Simulator, which is not loggable, helps my scan a lot, and it doesn't seem to matter that I'm using a joystick instead of a yoke. With the old "grandfathered" flight training device at my club, which is loggable, the yoke has so much hysteresis that I seldom use it, because I feel that it produces negative learning to some degree. (I think the hysteresis encourages overcontrolling.)

 

[poadeleted20]

dont even bother. at the spam can, level sims are pretty much worthless. you are better off flying the real airplane than wasting time and money flying a pc while thinking you are logging acceptable/useful flying experience. for practicing procedures you might as well play fsx.

There is a great deal of formal research which says otherwise, and none of which I am aware which agrees with you. Look especially for papers authored by Dr. Henry L. Taylor from the University of Illinois, as he was a ground-breaker in such research.

 

[cirrusmx]

There is a great deal of formal research which says otherwise, and none of which I am aware which agrees with you. Look especially for papers authored by Dr. Henry L. Taylor from the University of Illinois, as he was a ground-breaker in such research.

I wont argue about airline grade sims.
But, A lesson in a 172 sim at the mom and pop fbo will cost you probably 30-40 dollars less than a lesson in a real airplane. I would rather suck up the difference and get some real flying rather than thinking I am getting good experience on a PC. Also, it gets dangerous when people think they can go flying IMC to legal minimums just because they did the 6 hits in a sim.

 

[Greg Bockelman]

But, A lesson in a 172 sim at the mom and pop fbo will cost you probably 30-40 dollars less than a lesson in a real airplane. I would rather suck up the difference and get some real flying rather than thinking I am getting good experience on a PC.

The experience you get is only as good as the instructor operating the sim. Procedures are procedures. Doesn't matter if it is a sim or the real airplane. They should be the same regardless. In that regard, learn the procedures in the sim and save the 30 to 40 bucks.

Also, it gets dangerous when people think they can go flying IMC to legal minimums just because they did the 6 hits in a sim.

As a general rule, I tend to agree. BUT, that also depends on the sim and the instructor running it.

 

[poadeleted20]

I wont argue about airline grade sims.
But, A lesson in a 172 sim at the mom and pop fbo will cost you probably 30-40 dollars less than a lesson in a real airplane. I would rather suck up the difference and get some real flying rather than thinking I am getting good experience on a PC. Also, it gets dangerous when people think they can go flying IMC to legal minimums just because they did the 6 hits in a sim.

Prof. Taylor's research focused on ATD's for light singles, so you'd be arguing with him and a ton of research he did if you say otherwise.

 

[EdFred]

Prof. Taylor's research focused on ATD's for light singles, so you'd be arguing with him and a ton of research he did if you say otherwise.

He obviously didn't do enough research, because the ATC-610 I used did nothing except help get me towards the 40 hours.

 

[poadeleted20]

He obviously didn't do enough research, because the ATC-610 I used did nothing except help get me towards the 40 hours.

You might consider the possiblity that the issue wasn't the device.

 

[EdFred]

You might consider the possiblity that the issue wasn't the device.

Considering that the DE spun the CDI to make sure it was working on my check ride because the needle wasn't moving, I doubt it. And taking the IR ride at 40.2 hours instrument time says you better check yourself before you wreck yourself. Yes Ron, it's possible that someone who wasn't your student can actually fly a plane.

 

[poadeleted20]

Considering that the DE spun the CDI to make sure it was working on my check ride because the needle wasn't moving, I doubt it. And taking the IR ride at 40.2 hours instrument time says you better check yourself before you wreck yourself. Yes Ron, it's possible that someone who wasn't your student can actually fly a plane.