BATD Simulator Time

dell30rb

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Our club has a BATD simulator - good for logging up to 10 hours towards the instrument rating. As I understand, these hours must be logged "dual" with an instructor.

What else can this type of simulator be used for? Can you log time in it towards the 250 Hours for commercial?

And another commercial question - As I understand only 100 hours of the 250 must be PIC. So the rest is dual... and what else? can you log time flying right seat as a safety pilot?
 
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This question can have a lot of different answers, depending on who you ask.

I've only seen them loggable for simulated instrument time or ground training time. For instrument instruction, an authorized instructor must be present. However, for instrument currency, it can depend on the language the approver used for that device.

I know that for the Redbird AATD in my club, there's an email from the FAA plastered to the outside that states that instrument currency is NOT "training" and therefore a CFII doesn't need to be present to log sim instrument time and approaches when you're doing instrument currency. The requirements in part 61 for the instrument currency (airplane vs. sim vs. AATD vs BATD) apply.

What I do is mix up the AATD and the airplane, and get my 6 approaches every six months that way.

The BATD/AATDS can be very good trainers for stuff beyond instrument work, like ADM or VOR navigation. A good instructor will be able to give you a good workout in one. It may only be loggable as ground training time, however.
 
This question can have a lot of different answers, depending on who you ask.

I've only seen them loggable for simulated instrument time or ground training time. For instrument instruction, an authorized instructor must be present. However, for instrument currency, it can depend on the language the approver used for that device.

I know that for the Redbird AATD in my club, there's an email from the FAA plastered to the outside that states that instrument currency is NOT "training" and therefore a CFII doesn't need to be present to log sim instrument time and approaches when you're doing instrument currency. The requirements in part 61 for the instrument currency (airplane vs. sim vs. AATD vs BATD) apply.

What I do is mix up the AATD and the airplane, and get my 6 approaches every six months that way.

The BATD/AATDS can be very good trainers for stuff beyond instrument work, like ADM or VOR navigation. A good instructor will be able to give you a good workout in one. It may only be loggable as ground training time, however.

Thanks for your reply,

My instructor said it counts toward the 40 hours of hood time as well, up to 10 hours of it can be logged.

I use the sim on my own to practice stuff between instrument lessons in da real plane. Right now, focusing on getting sharp using the ADF. Can I log this time towards anything?
 
Thanks for your reply,

My instructor said it counts toward the 40 hours of hood time as well, up to 10 hours of it can be logged.

I use the sim on my own to practice stuff between instrument lessons in da real plane. Right now, focusing on getting sharp using the ADF. Can I log this time towards anything?

You can certainly log it, but as far as counting it towards requirements, follow your CFII's guidance.
 
You can certainly log it, but as far as counting it towards requirements, follow your CFII's guidance.

Well the reason I am asking here is that my CFII was unsure of the answer to this question. He told me to tell him what I found out. I'll do a little digging and see what I can come up with but I was hoping someone on here might already know the answer!
 
It looks like the simulator time can count towards a pilot's "total time" but not as "flight time" which is required for the 250 hour commercial. It is interesting to note that a dual x/c can be counted toward the 100 hour PIC as long as you performed "PIC duties" during the flight. I assume this to be sole manipulator, pre flight planning etc..?
 
I never log time in a sim as FLIGHT TIME... but it does count as simulated instrument time. Even when I did some time in Level-D sim, that was not FLIGHT TIME.

Ron does a lot of work with sims, so hopefully he'll chime in.

The Dual X/C under the supervision of a CFI is something they put in for folks who couldn't (for insurance reasons) go solo in the airplane they were training in. In that case, the supervised PIC exception would apply but I'd expect it would need to be logged that way in the logbook - i.e. the words "performing the duties of PIC".. or something similar.
 
Our club has a BATD simulator - good for logging up to 10 hours towards the instrument rating. As I understand, these hours must be logged "dual" with an instructor.
That is correct per 61.51:
(v) Training received in a flight simulator, flight training device, or aviation training device from an authorized instructor.
(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.]
The upshot of that last part is that you can log instrument time (but not training time) on an ATD in a classroom type scenario where one instructor is monitoring/supervising a room full of people but not giving individual training. That's not a common scenario outside some large university and professional training environments, and probably doesn't apply to your situation.

What else can this type of simulator be used for? Can you log time in it towards the 250 Hours for commercial?
The certification paperwork that came with that ATD tells you what it can be used for (and by lack of inclusion, what it can't). Have your instructor go over that paperwork with you.

And another commercial question - As I understand only 100 hours of the 250 must be PIC. So the rest is dual... and what else? can you log time flying right seat as a safety pilot?
Yes -- SIC safety pilot time counts towards the 250.
 
I never log time in a sim as FLIGHT TIME... but it does count as simulated instrument time. Even when I did some time in Level-D sim, that was not FLIGHT TIME.

Ron does a lot of work with sims, so hopefully he'll chime in.
Tim is correct. It's pilot time, simulated instrument time, and training time, but not flight time or PIC time. See 61.51 and the definitions in 61.1 and 1.1 for details.
 
I use the sim on my own to practice stuff between instrument lessons in da real plane. Right now, focusing on getting sharp using the ADF. Can I log this time towards anything?
Not without an instructor present to at least supervise and sign your log. And as far as logging things that don't count, while I know folks who put things in their log even when they don't qualify under 61.51, I strongly recommend against that practice because it creates questions about the accuracy and reliability of your other entries in the mind of anyone who reviews it.
 
It looks like the simulator time can count towards a pilot's "total time" but not as "flight time" which is required for the 250 hour commercial.
That would be based on the simulator's letter of certification, not the regulations, since 61.129 allows up to 50 hours in an simulator to be credited towards the 250-hour flight time requirement:
(i) Permitted credit for use of a flight simulator or flight training device.

(1) Except as provided in paragraph (i)(2) of this section, an applicant who has not accomplished the training required by this section in a course conducted by a training center certificated under part 142 of this chapter may:
(i) Credit a maximum of 50 hours toward the total aeronautical experience requirements for an airplane or powered-lift rating, provided the aeronautical experience was obtained from an authorized instructor in a flight simulator or flight training device that represents that class of airplane or powered-lift category and type, if applicable, appropriate to the rating sought; and (ii) Credit a maximum of 25 hours toward the total aeronautical experience requirements of this section for a helicopter rating, provided the aeronautical experience was obtained from an authorized instructor in a flight simulator or flight training device that represents a helicopter and type, if applicable, appropriate to the rating sought.
Note that this paragraph only applies to flight simulators and FTD's, which may be why your ATD's letter of certification doesn't include it.
 
Captain Ron,

Thanks! Mine is a BATD and i'll ask to see the letter. Didn't know that they came with a letter of certification.
 
Ron, correct me if I'm wrong...

The device should come with a letter from the FAA branch/FSDO that oversaw it's manufacture. There may also be a letter from the local FSDO (especially if it's a 141 school) laying out what the device is approved for.

The local FSDO opinion "wins" if there are any discrepancies.
 
Mine is a BATD and i'll ask to see the letter. Didn't know that they came with a letter of certification.
They do indeed, and if it's a Part 141 school, that particular sim installation will also need a letter from the local FSDO authorizing its use in that school and stating its capabilities and limitations. The school will probably keep that original letter tucked away safely, although most schools will post a copy by the sim for immediate reference.

And what Tim said is correct regarding its use under a 141 program, although there is no requirement or procedure for the local FSDO to examine or provide a letter for a flight simulation training device if it's only being used under Part 61.
 
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Captain Ron,

Thanks! Mine is a BATD and i'll ask to see the letter. Didn't know that they came with a letter of certification.

As noted, it should come with one. Advisory circular 61-136 covers BATD and AATD. It's mostly a listing of the standards for certification, but it includes the list of what the FAA will approve the BATD for (see the excerpt below).
The certification letter says what it can actually be used for, but this what it probably allows. (however, see my next post)

AC 61-136 said:
Authorized Use of a BATD to Credit Flight Experience as a Means to Obtaining Flight Experience in a Flight Simulator, FTD, or Aircraft.
This appendix provides for a specific element of training time in a BATD meeting FAA standards instead of the total flight-hours that pilots would otherwise complete in a qualified flight simulator, FTD, or aircraft to meet the requirements of parts 61 or 141. The FAA will approve a BATD meeting the criteria found in this appendix for:
• Not more than 10 hours toward instrument rating flight instruction time under part 61, § 61.65(e)(2);
• Not more than 10 hours toward instrument rating flight instruction time under part 141, appendix C;
• Use in performing instrument recency of experience requirements of § 61.57(c)(1);
• Not more than 2.5 hours of training permitted under § 61.109(k)(1) in the introduction to the operation of flight instruments, except as limited by part 141 appendices; and
• The flight experience allowance for the use of a BATD and the flight experience allowance for an AATD, an FTD or a flight simulator towards obtaining an instrument rating may be combined. However, that combination may not exceed that allowed under § 61.65 (20 hours maximum) and may not exceed that allowed under part 141, appendix C, paragraph 4(b)(4) (50 percent maximum) of the required training.
NOTE: A part 141 certificated pilot school must obtain a specific authorization for the use of the ATD as part of that pilot school’s approved training curriculum. This authorization must come from the FAA FSDO assigned to that pilot school.
 
Note that the AC does not include authorization for any BATD to be used for the 50 hours towards the CP's 250 as covered by 61.129(i), so that part is dead for your machine. And as noted, that AC section posted lists the maximum which may be allowed in a BATD. While most BATD's are probably allowed all of that, only the certification letter for your machine tells you for sure.
 
dell30rb said:
It looks like the simulator time can count towards a pilot's "total time" but not as "flight time" which is required for the 250 hour commercial.
That would be based on the simulator's letter of certification, not the regulations, since 61.129 allows up to 50 hours in an simulator to be credited towards the 250-hour flight time requirement:
(i) Permitted credit for use of a flight simulator or flight training device.

(1) Except as provided in paragraph (i)(2) of this section, an applicant who has not accomplished the training required by this section in a course conducted by a training center certificated under part 142 of this chapter may:
(i) Credit a maximum of 50 hours toward the total aeronautical experience requirements for an airplane or powered-lift rating, provided the aeronautical experience was obtained from an authorized instructor in a flight simulator or flight training device that represents that class of airplane or powered-lift category and type, if applicable, appropriate to the rating sought; and (ii) Credit a maximum of 25 hours toward the total aeronautical experience requirements of this section for a helicopter rating, provided the aeronautical experience was obtained from an authorized instructor in a flight simulator or flight training device that represents a helicopter and type, if applicable, appropriate to the rating sought.
Note that this paragraph only applies to flight simulators and FTD's, which may be why your ATD's letter of certification doesn't include it.

I've been confused about this part.

I have access to an AATD, and it did come with a certification letter stating what it can be used for along with FAR references for each item. The FARs have changed since then and presumably will continue to change, but the letter is never updated.

When the letter was written, there was no references in the FARs to ATDs, and all the hours you can credit reflected the FTD references in the FARs.
For example, the letter states 20 hours can be credited towards the instrument rating. This was based on the information in AC 61-136. The previous version of the 61.65 allowed 20 hours of FTD or sim time, with no mention of ATDs. The current version still lists 20 hours of FTD or sim time, but also allows up to 10 hours for ATDs. I assume the FARs take precedence over the AC and the ATD certification letter and only 10 hours are allowed?

But if that's the case, is the rest of the certification letter still valid? It allows 50 hours towards the commercial - which agrees with the AC and 61.129 - except 61.129 says it applies to training in an FTD with no mention of ATD. So can i still use up to 50 hours of ATD training towards the commercial? If so, how do I prove that to a skeptical examiner who notes that it says I can use FTD training?
 
I've been confused about this part.

I have access to an AATD, and it did come with a certification letter stating what it can be used for along with FAR references for each item. The FARs have changed since then and presumably will continue to change, but the letter is never updated.

When the letter was written, there was no references in the FARs to ATDs, and all the hours you can credit reflected the FTD references in the FARs.
For example, the letter states 20 hours can be credited towards the instrument rating. This was based on the information in AC 61-136. The previous version of the 61.65 allowed 20 hours of FTD or sim time, with no mention of ATDs. The current version still lists 20 hours of FTD or sim time, but also allows up to 10 hours for ATDs. I assume the FARs take precedence over the AC and the ATD certification letter and only 10 hours are allowed?

But if that's the case, is the rest of the certification letter still valid? It allows 50 hours towards the commercial - which agrees with the AC and 61.129 - except 61.129 says it applies to training in an FTD with no mention of ATD. So can i still use up to 50 hours of ATD training towards the commercial? If so, how do I prove that to a skeptical examiner who notes that it says I can use FTD training?
The FAA has in the past allowed units that were previously approved for various operations to continue to be used for those operations despite not meeting current standards for those operations. An example is the ATC 610, approved as an FTD about 30 years ago, but which no longer would qualify as an FTD due to lack of a cockpit enclosure. The FAA still honors that certification, and use of the ATC 610 for 20 hours towards the IR is still approved.

Therefore, while the current rules may not permit issuance of a letter allowing the same use for a new design AATD today, I'd say that whatever the certification letter for your AATD says is approved remains approved unless/until the FAA rescinds that letter. If you have any doubts, contact your FSDO and have them ask AFS-810 for guidance.
 
The FAA has in the past allowed units that were previously approved for various operations to continue to be used for those operations despite not meeting current standards for those operations. An example is the ATC 610, approved as an FTD about 30 years ago, but which no longer would qualify as an FTD due to lack of a cockpit enclosure. The FAA still honors that certification, and use of the ATC 610 for 20 hours towards the IR is still approved.

Therefore, while the current rules may not permit issuance of a letter allowing the same use for a new design AATD today, I'd say that whatever the certification letter for your AATD says is approved remains approved unless/until the FAA rescinds that letter. If you have any doubts, contact your FSDO and have them ask AFS-810 for guidance.

Thanks. Can you give me some idea of what I'm looking for from the FSDO regarding this? My concern is showing up to a checkride and having the examiner ignoring the certification letter and not accept the credit, citing the FARs (which as you say, specify FTD and not ATD). There are many people around here with the same concern.

Do we just need a letter from the FSDO with their interpretation, or quoting AFS-810? And would that only be valid within the area governed by that FSDO?

Sorry for all the questions, but I'm not even sure what I'm supposed to be looking for when talking to the FSDO. So far, you're the first person who seems to have any idea.
 
Well the reason I am asking here is that my CFII was unsure of the answer to this question. He told me to tell him what I found out.

I question what he's doing using a sim if can't keep up with the most fundamental of regulatory issues related to their use. He should know this stuff.
 
This question can have a lot of different answers, depending on who you ask.

I've only seen them loggable for simulated instrument time or ground training time. For instrument instruction, an authorized instructor must be present. However, for instrument currency, it can depend on the language the approver used for that device.

I know that for the Redbird AATD in my club, there's an email from the FAA plastered to the outside that states that instrument currency is NOT "training" and therefore a CFII doesn't need to be present to log sim instrument time and approaches when you're doing instrument currency. The requirements in part 61 for the instrument currency (airplane vs. sim vs. AATD vs BATD) apply.

I seem to recall reading something similar somewhere - possibly in the revision notes from the FAR update that modifed the currency rules.

Any chance you have a copy of the email that's posted on the Redbird? I'd be interested in seeing it.
 
Thanks. Can you give me some idea of what I'm looking for from the FSDO regarding this? My concern is showing up to a checkride and having the examiner ignoring the certification letter and not accept the credit, citing the FARs (which as you say, specify FTD and not ATD). There are many people around here with the same concern.

Do we just need a letter from the FSDO with their interpretation, or quoting AFS-810? And would that only be valid within the area governed by that FSDO?

Sorry for all the questions, but I'm not even sure what I'm supposed to be looking for when talking to the FSDO. So far, you're the first person who seems to have any idea.
I've never heard of an examiner "ignoring" such a letter. Since this is probably going to be an ongoing matter for the club, I would have the club's chief instructor contact the examiner in question now, and, with the assistance of the examiner's POI at the FSDO if necessary, make sure everyone's on the same page before anyone shows up for an IR practical test with more than ten hours from that device as part of their required 40.
 
I know that for the Redbird AATD in my club, there's an email from the FAA plastered to the outside that states that instrument currency is NOT "training" and therefore a CFII doesn't need to be present to log sim instrument time and approaches when you're doing instrument currency. The requirements in part 61 for the instrument currency (airplane vs. sim vs. AATD vs BATD) apply.
That letter was the result of a misunderstanding. The current version of 61.51 quoted above (61.51)(I)(4)) makes clear the necessity of an instructor's presence and signature to log instrument time to meet the instrument recency requirements of 61.57(c).
 
I question what he's doing using a sim if can't keep up with the most fundamental of regulatory issues related to their use. He should know this stuff.


My primary CFII has been a pilot since the 50's and instructor since the 70's. He is an excellent instructor, but he is a little bit computer challenged. Probably due to his age. That's not to say he's too over the hill, the guy is still sharp and a very active CFI, otherwise I would not use him. He recommended I use another club instructor who is more experienced with the sim if I wanted to log some simulator time towards my rating.
 
That letter was the result of a misunderstanding. The current version of 61.51 quoted above (61.51)(I)(4)) makes clear the necessity of an instructor's presence and signature to log instrument time to meet the instrument recency requirements of 61.57(c).
I think I have the latest version and it's 61.51(g)(4) now. Revision was Aug 2009. And the online version from the FAA agrees.

I'll see if I can find the mail message. Regardless I agree that the way the regs (61.51) read now an instructor is required.

To be honest, I don't really see the point of requiring an instructor for currency - it's all on the honor system in the airplane, so why not in the sim?
 
Captain Ron,

Thanks! Mine is a BATD and i'll ask to see the letter. Didn't know that they came with a letter of certification.
This is the absolute key post. See the LETTER.

Your CFI should really know about the letter.
 
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This is the absolute key post. See the LETTER.

Your CFI should really know about the letter.

Maybe its different at other flight schools, but our simulator is not used very much. Its nearly always free.

And he never said he didn't know about the letter. Maybe he just forgot to mention it... he did tell me to contact another CFI for instruction in the sim.
 
I think I have the latest version and it's 61.51(g)(4) now. Revision was Aug 2009. And the online version from the FAA agrees.

I'll see if I can find the mail message. Regardless I agree that the way the regs (61.51) read now an instructor is required.

To be honest, I don't really see the point of requiring an instructor for currency - it's all on the honor system in the airplane, so why not in the sim?
Sorry, mate -- I can always help with the "what," but not always with the "why."
 
Sorry, mate -- I can always help with the "what," but not always with the "why."
Follow on for Ron...

The reg says
(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.

Now, if someone's doing instrument currency work, there's no real "Training" going on, and the reg requires the presence of an authorized instructor, and that they verify the time and content.

What I get from this is that a CFII could be in the same room, but not sitting in the sim with the student, and validate the time spent in the box and look at the flight log on shutdown, and just "validate" it - yes you spent 1.2 hours and conducted 4 approaches and 2 holds, no instruction given. Essentially the authorized instructor is acting as a proctor in this case.

Am I reading more into this than I should?
 
Follow on for Ron...

What I get from this is that a CFII could be in the same room, but not sitting in the sim with the student, and validate the time spent in the box and look at the flight log on shutdown, and just "validate" it - yes you spent 1.2 hours and conducted 4 approaches and 2 holds, no instruction given. Essentially the authorized instructor is acting as a proctor in this case.

Am I reading more into this than I should?
No. The FAA put that in to allow university students in big sim laboratories to all log time while one instructor supervises all of them.
 
No. The FAA put that in to allow university students in big sim laboratories to all log time while one instructor supervises all of them.

Oh good. I notice on the King site for the redbird TD they say "log your instrument currency at home" and don't mention an instructor. I may ask them to see if they just forgot to mention it, or if they've seen something from the FAA that contradicts the 61.51 reference, essentially saying "what we REALLY meant was....".

And I got an answer..., and I LIKE IT.
 

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