Flight Sims: Difference betw Redbird & your own setup?

[Michele]

A Kings School ad popped up in my inbox and it got me wondering. It was for the Redbird TD Table Mounted Trainer for 7-8K. Now, you can buy the software for $30 and a yoke and some rudder pedals for a few hundred. My question is this, what is the difference between the Redbird set up and buying your own components besides about 7.5K?

http://www.kingschools.com/flight-s...bletop-desktop-trainer.asp?sco=WBEM&scu=1109A

 

[Sac Arrow]

I'm going to guess, the same difference as the home X-plane and the commercial version. Licensing. One counts for logging approaches and the cheaper version doesn't.

 

[TMetzinger]

FAA Approval - there's a specific letter from AFS-800 stating what the device can be used for.

 

[Palmpilot]

FAA Approval - there's a specific letter from AFS-800 stating what the device can be used for.

Is there a link to that letter? I'm interested because a local FBO manager claimed that their Redbird can be used for IFR currency without an instructor present. (I'm skeptical.)

 

[bob_albertson]

Is there a link to that letter? I'm interested because a local FBO manager claimed that their Redbird can be used for IFR currency without an instructor present. (I'm skeptical.)

You should be.... I've never heard of a simulator that didn't require an instructor to be present in order to log the time..... For ANY kind of IFR currency requirements. Usually these type of systems can do everything but CTL procedures since they don't afford a wide enough view.... shoot even our Level D sim isn't that great for it either, but it's the lowest level that counts for circling approaches.... which are important for an IPC.

They may have a specific letter from the FAA (they should anyway) for their set-up, but it should be the generic letter that still requires an instructor to log the time.

Bob

 

[TMetzinger]

There's another thread on this... but if you look at the King link in the OP, they say

Maintain Your Instrument Currency



With the optional rudder pedals, the TD is approved as a Basic Aviation Training Device by the FAA. That means that you can log instrument currency for approaches and holding right at home. Not only will you save time and money, but with a good currency plan, you will stay sharp by regularly practicing the real-world failures that can occur including vacuum failures for analog instruments and loss of your Air Data Computer on the G1000. While regularly practicing instrument flying in the airplane is critical to safety, you can get prepared and stay sharp by incorporating the TD into your overall currency plan.

Nothing in there about a CFII being present. I guess I'll contact them and see if this is marketing or if there's specific guidance. I HAVE seen (and I'll try and photograph it) a message stating that "recency" is not training and therefore no instructor is needed, but that doesn't explain how they get around the language in 61.51.

Edit: King says no CFII needed, and are e-mailing me something to back it up. I'll post it when it arrives.

Edit/Edit: Message attached, and it's later than the FAR rewrite. This is what I've seen on Redbirds before.

Believe me, I LIKE this message... but the way this particular hair was split... I hope that no Counsel overrides this.. I'm certainly NOT going to ask the question.

 

[denverpilot]

<-- For the FAA and their consistency.

 

[BillTIZ]

Tim, thanks for a copy of that letter. That is what I've always understood about BATD simulators. Only need an instructor if using the time towards a rating, not proficiency.

Many flight schools will not allow a BATD or AATD to be used without a CFI present to operate it. Unless you use it all the time, many would not know how to operate it. Plus, they can glean some $$ by providing an instructor.

Now, if you could get an FAA LOA for your home grown, PC Flight Sim to be an approved BATD, you may have something. It's a shame to spend $8K on a computer with only one application for home use.

 

[JeffDG]

I'm going to guess, the same difference as the home X-plane and the commercial version. Licensing. One counts for logging approaches and the cheaper version doesn't.

That only accounts for about $500...you can buy the key that unlocks the "certifiable" version of X-Plane for $400 or $500 IIRC. It's the same software, but it removes the "non-commercial use" license restriction, and does some hardware and frame-rate checking required for FAA certification.

 

[Palmpilot]

There's another thread on this... but if you look at the King link in the OP, they say


Nothing in there about a CFII being present. I guess I'll contact them and see if this is marketing or if there's specific guidance. I HAVE seen (and I'll try and photograph it) a message stating that "recency" is not training and therefore no instructor is needed, but that doesn't explain how they get around the language in 61.51.

Edit: King says no CFII needed, and are e-mailing me something to back it up. I'll post it when it arrives.

Edit/Edit: Message attached, and it's later than the FAR rewrite. This is what I've seen on Redbirds before.

Believe me, I LIKE this message... but the way this particular hair was split... I hope that no Counsel overrides this.. I'm certainly NOT going to ask the question.

I'll be darned. Thanks for doing that research.

 

[poadeleted20]

I did a bit more research. Yes, that email reflects AFS-810's position and intent on the matter. However, it appears the wording of the regulation may have been inadvertently altered somewhere along the line. Note the discussion in the preamble to the Final Rule:

An authorized instructor (See Sec. 61.1(b)(2)) must be present in the FS, FTD, or ATD when instrument training time is logged for training and aeronautical experience for meeting the requirements for a certificate, rating, or flight review (See Sec. 61.51(a)).

...in comparison with the wording in the regulation itself:

[(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.]

Don't be surprised if a correction to the regulation comes out to make it consistent with the intent experessed in the preamble and the email. And please, don't ask the Chief Counsel, who may interpret it as the reg reads rather than as AFS-810 wants things to be.

 

[TMetzinger]

I did a bit more research. Yes, that email reflects AFS-810's position and intent on the matter. However, it appears the wording of the regulation may have been inadvertently altered somewhere along the line. Note the discussion in the preamble to the Final Rule:
...in comparison with the wording in the regulation itself:
Don't be surprised if a correction to the regulation comes out to make it consistent with the intent experessed in the preamble and the email. And please, don't ask the Chief Counsel, who may interpret it as the reg reads rather than as AFS-810 wants things to be.

This is a good thing, and NO, I won't ask, especially given the current counsel's interpretation history.

 

[n20junkie]

An instructor has to be present to "verify" the time.

But if I take my plane out to maintain currency, who "verifys" that time?

 

[Palmpilot]

An instructor has to be present to "verify" the time.

But if I take my plane out to maintain currency, who "verifys" that time?

Shhh! Don't give them ideas!

 

[TMetzinger]

An instructor has to be present to "verify" the time.

But if I take my plane out to maintain currency, who "verifys" that time?

No, an instructor doesn't have to verify your currency time, only your "training" time...

so don't sweat it. Just go fly an ATD, log the simulated instrument time and the approaches, and comply with the various 61.57 requirements depending on the device(s) you use.

I use a combination of actual airplane and AATD. In the AATD I practice various system failures (pitot, static, gyro/AHRS). In the airplane I'm usually logging the approaches in actual or occasionally with a safety pilot.

 

[denverpilot]

Don't be surprised if a correction to the regulation comes out to make it consistent with the intent experessed in the preamble and the email. And please, don't ask the Chief Counsel, who may interpret it as the reg reads rather than as AFS-810 wants things to be.

So nice they're all on the same page.

 

[shenanigans]

I did a bit more research. Yes, that email reflects AFS-810's position and intent on the matter. However, it appears the wording of the regulation may have been inadvertently altered somewhere along the line. Note the discussion in the preamble to the Final Rule:
...in comparison with the wording in the regulation itself:
Don't be surprised if a correction to the regulation comes out to make it consistent with the intent experessed in the preamble and the email. And please, don't ask the Chief Counsel, who may interpret it as the reg reads rather than as AFS-810 wants things to be.

Someone already did last year, with predictable results.

 

[TMetzinger]

Yes, but Lance's letter is LATER than the counsel letter. So as I see it, she sent it to Flight Standards for action, and they said... no CFII required.

<sarcasm>I'd like to lock these folks in a room with one pistol.. Whoever comes out gets to say what the rule is.... Unless I disagree, in which case I shoot them. </sarcasm>

 

[RotorAndWing]

Yes, but Lance's letter is LATER than the counsel letter. So as I see it, she sent it to Flight Standards for action, and they said... no CFII required.

Correct. It got punted back to Flight Standards.

<sarcasm>I'd like to lock these folks in a room with one pistol.. Whoever comes out gets to say what the rule is.... Unless I disagree, in which case I shoot them. </sarcasm>

Welcome to my world.

 

[shenanigans]

Yes, but Lance's letter is LATER than the counsel letter. So as I see it, she sent it to Flight Standards for action, and they said... no CFII required.

I didn't notice that your letter was more recent.

So do opinions from Flight Standards take precedence over cousel interpretations? Or is it just whoever publishs the most recent opinion?

 

[RotorAndWing]

I didn't notice that your letter was more recent.

So do opinions from Flight Standards take precedence over cousel interpretations? Or is it just whoever publishs the most recent opinion?

If you read the General Council letter it defers back to Flight Standards.

We acknowledge that the preamble language indicates some intent to change the rule. For that reason, this issue has been forwarded to the Flight Standards Service.

 

[shenanigans]

If you read the General Council letter it defers back to Flight Standards.

I saw that, but I had interpreted it to mean they were informing Flight Standards so the regulation wording could be updated to match the intent, rather than sending it to them for an alternate interpretation.

 

[poadeleted20]

Someone already did last year, with predictable results.

Crap. As the Keller letter says:

However, when the rule and the preamble conflict, the rule controls. Accordingly, the regulatory text of §61.51(g)(4) is clear that 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.

As I understand it, the Chief Counsel is the final authority on interpretation of a FAR, in which case that email would be without legal force. So, unless/until Flight Standards either changes the wording in the reg or gets the Chief Counsel to withdraw that letter (and I wouldn't be surprised if one of those happens), I don't see how anyone can legally log that time/events for 61.57(c) purposes. In any event, the chief of AFS-810 (the branch responsible for this reg, and for which Mr. Nuckolls worked when he sent that email, although he's moved elsewhere since then) is aware of the issue, so we'll just have to see what happens next.

 

[JeffDG]

If you read the General Council letter it defers back to Flight Standards.

Crap. As the Keller letter says:
As I understand it, the Chief Counsel is the final authority on interpretation of a FAR, in which case that email would be without legal force. So, unless/until Flight Standards either changes the wording in the reg or gets the Chief Counsel to withdraw that letter (and I wouldn't be surprised if one of those happens), I don't see how anyone can legally log that time/events for 61.57(c) purposes. In any event, the chief of AFS-810 (the branch responsible for this reg, and for which Mr. Nuckolls worked when he sent that email, although he's moved elsewhere since then) is aware of the issue, so we'll just have to see what happens next.

Yes...the Chief Counsel's office made clear that the rule (instructor must be there) overrides the preamble.

They punted to Flight Standards in order that they can draft and submit a change to the rule, but so long as the rule reads as it does, the Chief Counsel's letter is controlling, regardless of date.

 

[JeffDG]

Wait a minute...

I'm seeing a subtle wording issue in the Keller letter...

Accordingly, the regulatory text of §61.51(g)(4) is clear that in order to log the time an instructor must be present...

For instrument currency, you care diddly-squat about logging time, you're logging Approaches, interception and tracking and holds. Could you argue that provided you log zero time, you're cool?

 

[poadeleted20]

Wait a minute...

I'm seeing a subtle wording issue in the Keller letter...



For instrument currency, you care diddly-squat about logging time, you're logging Approaches, interception and tracking and holds. Could you argue that provided you log zero time, you're cool?

You certainly could argue that, but whether that argument would be availing is quite unknown, and I sure wouldn't bet my ticket on it working.

 

[denverpilot]

I'm sure if the FAA can't get their crap together, the insurance companies will handle it for them. They have skin in the game.

 

[poadeleted20]

I'm sure if the FAA can't get their crap together, the insurance companies will handle it for them. They have skin in the game.

So far, I have not seen insurance companies get involved in this area for airplanes for which refresher training isn't otherwise required (e.g., cabin class twins, where they usually require formal annual refresher training including instrument work). That suggests they don't see method of compliance with 61.57(c) as an issue which is significantly affecting accident rates (i.e., their costs) in those lighter, simpler airplanes.