PSA: Logging private pilot instrument sim time

[GauzeGuy]

This is a public service announcement.

If you have hours in an approved flight training device, be aware that you cannot count those hours towards your 3 hour flight by reference to instruments requirement. It must be in the aircraft. My CFI and I figured that out yesterday as a result of a call to the Denver FSDO.

Guess who got to spend the better part of an hour under the hood in turbulence yesterday as a result?

Of course, not much choice in the matter since my check ride was this morning. More on that later...

 

[denverpilot]

What regulation did they cite?

Just curious.

DEN isn't usually in the game of "Let's make up things that aren't in the regs at the FSDO" like a number of others are, so I'm just curious.

 

[GauzeGuy]

What regulation did they cite?

Just curious.

DEN isn't usually in the game of "Let's make up things that aren't in the regs at the FSDO" like a number of others are, so I'm just curious.

This is what was quoted. Emphasis on the "in a single-engine airplane."

Sec. 61.109

(3) 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;

Before this point I thought the 2.5 hours that was allowed in the sim toward the private pilot requirements could be used for this purpose... In any event though, we were in no position to argue. lol

 

[poadeleted20]

Unless DEN FSDO's copy of the FAR's is missing paragraph (k)(1) of 14 CFR 61.109:

(k) Permitted credit for use of a flight simulator or flight training device. (1) Except as provided in paragraphs (k)(2) of this section, a maximum of 2.5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section, if received from an authorized instructor.

...they are confused. In particular, note that it says "may be credited toward the flight training time," not just "aeronautical experience." That means you can get all but 0.5 of the required 3.0 in an approved flight simulation device.

Have your instructor suggest they check with Marcel Bernard in AFS-810 (he's the guy managing Part 61 sim issues there) because they are doing the Denver aviation community a disservice and embarassing themselves by their stand.

 

[bobmrg]

This is a public service announcement.

If you have hours in an approved flight training device, be aware that you cannot count those hours towards your 3 hour flight by reference to instruments requirement. It must be in the aircraft. My CFI and I figured that out yesterday as a result of a call to the Denver FSDO.

Guess who got to spend the better part of an hour under the hood in turbulence yesterday as a result?

Of course, not much choice in the matter since my check ride was this morning. More on that later...

Calling the FSDO treats the symptom, not the underlying cause. I realize that you are new to this, but you should understand that different FSDOs interpret regulations differently, and different ops inspectors within a given FSDO can come up with competing explanations. Bottom line: Don't hang your hat on what you learn from a ops inspector; only the Office of the General Counsel can give you answers that you can rely on.

Bob Gardner

 

[poadeleted20]

Calling the FSDO treats the symptom, not the underlying cause. I realize that you are new to this, but you should understand that different FSDOs interpret regulations differently, and different ops inspectors within a given FSDO can come up with competing explanations. Bottom line: Don't hang your hat on what you learn from a ops inspector; only the Office of the General Counsel can give you answers that you can rely on.

On this issue, which is an internal Flight Standards training problem, you can rely on what AFS-810, which wrote and manages Part 61, says to the FSDO, and all that has to happen to achieve that is for the Inspector concerned to do what AFS-1 has decreed for situations like this and contact AFS-810 for guidance. The involvement if the Chief Counsel is not necessary where an individual FSDO or Inspector is concerned -- just run it up the chain of command and do as directed by their own bosses.

 

[GauzeGuy]

On this issue, which is an internal Flight Standards training problem, you can rely on what AFS-810, which wrote and manages Part 61, says to the FSDO, and all that has to happen to achieve that is for the Inspector concerned to do what AFS-1 has decreed for situations like this and contact AFS-810 for guidance. The involvement if the Chief Counsel is not necessary where an individual FSDO or Inspector is concerned -- just run it up the chain of command and do as directed by their own bosses.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/list/AC%2061-65E/$FILE/AC61-65E.pdf

16. PRIVATE PILOT CERTIFICATION. Specific knowledge, flight proficiency, flight experience, and endorsement requirements for the private pilot certificate are located in part 61,
subpart E.
[...]
d. The 3 hours of flight training in a single-engine or multiengine airplane on the control
and maneuvering of an airplane solely by reference to instruments (see sections 61.109(a)(3) and (b)(3)) and the 3 hours of flight training in a powered-lift on the control and maneuvering of a powered-lift solely by reference to instruments (see section 61.109(e)(3)) do not have to be
conducted by a certificated flight instructor—instrument (CFII). However, the training must be in an aircraft and not in a flight simulator or a flight training device unless it was performed in accordance with a 14 CFR part 142 approved training program.

So am I to take that the above quote (in italics) means that a part 61 applicant cannot in fact use the simulator hours towards flight by reference to instruments?

 

[RotorAndWing]

Have your instructor suggest they check with Marcel Bernard in AFS-810 (he's the guy managing Part 61 sim issues there)

On this issue, which is an internal Flight Standards training problem, you can rely on what AFS-810, which wrote and manages Part 61, says to the FSDO, and all that has to happen to achieve that is for the Inspector concerned to do what AFS-1 has decreed for situations like this and contact AFS-810 for guidance.

And good luck on getting any response from AFS-810, or anyone in -800 for that matter. Communication is not their forte.

just run it up the chain of command and do as directed by their own bosses.

You seriously do not understand the "chain of command" within the FAA. AFS-800 is not in that chain, they are simply advisory, and that's only when you can get any of them to pick up the phone, answer an email or a letter.

 

[poadeleted20]

And good luck on getting any response from AFS-810, or anyone in -800 for that matter. Communication is not their forte.

I've never heard of any FSDO having any problem in that regard before.

You seriously do not understand the "chain of command" within the FAA. AFS-800 is not in that chain, they are simply advisory, and that's only when you can get any of them to pick up the phone, answer an email or a letter.

My error -- the proper path is, per the AFS-1 memo dated March 31, 2006, for the FSDO to contact the regional Flight Standards office which if necessary then elevates the issue to AFS-800. I'm sure you've seen that memo, which also says "AFS-800 continues to be the final point of resolution in all policy matters concerning the Part 61 and Part 141 regulations."

 

[poadeleted20]

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/list/AC%2061-65E/$FILE/AC61-65E.pdf

16. PRIVATE PILOT CERTIFICATION. Specific knowledge, flight proficiency, flight experience, and endorsement requirements for the private pilot certificate are located in part 61,
subpart E.
[...]
d. The 3 hours of flight training in a single-engine or multiengine airplane on the control
and maneuvering of an airplane solely by reference to instruments (see sections 61.109(a)(3) and (b)(3)) and the 3 hours of flight training in a powered-lift on the control and maneuvering of a powered-lift solely by reference to instruments (see section 61.109(e)(3)) do not have to be
conducted by a certificated flight instructor—instrument (CFII). However, the training must be in an aircraft and not in a flight simulator or a flight training device unless it was performed in accordance with a 14 CFR part 142 approved training program.

So am I to take that the above quote (in italics) means that a part 61 applicant cannot in fact use the simulator hours towards flight by reference to instruments?

AC's don't trump regs.

 

[RotorAndWing]

I've never heard of any FSDO having any problem in that regard before.

Well, considering you do not work for, or within the FAA I could certainly understand that...........

My error -- the proper path is, per the AFS-1 memo dated March 31, 2006, for the FSDO to contact the regional Flight Standards office which if necessary then elevates the issue to AFS-800. I'm sure you've seen that memo, which also says "AFS-800 continues to be the final point of resolution in all policy matters concerning the Part 61 and Part 141 regulations."

Yep, seen it before. That's why nothing usually gets resolved because it falls into the quagmire known as AFS-800.

If bullsh)t was brass AFS-800 would be a band.

 

[nosehair]

Guess who got to spend the better part of an hour under the hood in turbulence yesterday as a result?

Maybe someday you'll appreciate that.