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Logging Simualated Instrument Time in a ATD or FTD

Asked by: 5457 views FAA Regulations, Flight Instructor, Instrument Rating

With the publication of AC 61-136B, it specifically states in Appendix D paragraph 3 that:    "Simulated instrument time can be logged in an ATD, but only during the time when the visual component of the training session is configured for instrument meteorological conditions (IMC) and the pilot is maintaining control solely by reference to the flight instruments."  This AC was published in September 2018 and I did my training for my instrument rating in 2012/2013.  My old instructor never logged simulated instrument time however, that's all we did in these sim sessions.  All practice approaches, BAI, etc. (all recorded in the remarks section). 

My question is, can I go back and retroactively log this time as "simulated instrument" and not just "flight simulator" time? 

 

5 Answers



  1. Kris Kortokrax on Feb 12, 2019

    If a given logbook entry was made by your instructor and endorsed by him, I would not change it. If your instructor entered something in error, it should be corrected in the timeframe in which the entry was made.

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  2. Mark Kolber on Feb 13, 2019

    It is partially a bookkeeping issue. Most pilots I know reserve the Simulated Instrument column for simulated instrument “flight” time, and time in a device doesn’t meet that definition.

    “Flight” time is in an “aircraft.” Even the best full motion simulators are not “aircraft.”

    Consider that the 8710-1 requires separate identification of flight time and device time. It’s not the only way, but logging “sim Instrument” under the hood and in a device separately is a common way of keeping The totals separate.

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  3. Matt B on Feb 15, 2019

    I actually just got the opinions of 2 FSDOs and both said the exact same thing. They both said add a memorandum into your logbook so the correction is clear and you can 100% go back and log it. Especially because the verbiage is also in the cancelled AC 61-136A mentions the same thing. As long as the Sim time was by “sole reference to instruments” then you can count it as simulated instrument

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  4. Matt B on Feb 15, 2019

    I actually just got the opinions of 2 FSDOs and both said the exact same thing. They both said add a memorandum into your logbook so the correction is clear and you can 100% go back and log it. Especially because the verbiage is also in the cancelled AC 61-136A mentions the same thing. As long as the Sim time was by \”sole reference to instruments\” then you can count it as simulated instrument

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  5. Pipe on Dec 23, 2020

    It is right in the current AC 61-136B Appendix D

    D.3 Logging Training Time and Experience.

    Authorized instructors utilizing an FAA-approved ATD for airmen training, pilot time, and experience requirements are required to log the time as dual instruction and as basic aviation training device (BATD) or advanced aviation training device (AATD) time appropriately. Any columns that reference flight time should remain blank when logging ATD time. ATD time can only be logged as Instruction Received (Dual), Instrument Time, or Total Time as reflected on the pilot time section of FAA Form 8710-1, Airman Certificate and/or Rating Application. Simulated instrument time can be logged in an ATD, but only during the time when the visual component of the training session is configured for instrument meteorological conditions (IMC) and the pilot is maintaining control solely by reference to the flight instruments. Logging time in this fashion will allow a pilot to credit this time towards the aeronautical experience and instrument experience requirements as specified in part 61 or part 141. It is required under § 61.51(b)(1)(iv) that the type and identification of the ATD be included when logging pilot time as described in the letter of authorization (LOA). It is the responsibility of the flight instructor, student, or certificated pilot to verify the device is qualified and approved for training or experience requirements. It would be appropriate for the person using the ATD to retain a copy of the LOA. Evaluators such as Designated Pilot Examiners (DPE) are instructed to request a copy of the LOA from applicants logging ATD pilot time, to verify the time acquired in the trainer qualifies for the minimum experience requirements for a certificate or rating.

    Note: There are no restrictions on the amount of training accomplished and logged in training devices. However, the regulatory limitations on maximum credit allowed for the minimum pilot certification requirements are specified by parts 61 and 141 and in the LOA. No approvals or authorizations are provided for aircraft type ratings using ATDs.

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