Does Your CFI Have to Look Over Your Shoulder When You Are Maintaining Instrument Currency in a Simulator?

An instrument rating provides both options and opportunities that are not available to a VFR pilot. But in order for an instrument rated pilot to legally exercise the privileges of the instrument rating, he or she must be current. 14 C.F.R. § 61.57(c) lists the tasks that must be accomplished within the six calendar months preceding the month of the IFR flight, and logged under 14 C.F.R. § 61.51 in order for the pilot to be instrument legal for that flight.

But what happens if you are a pilot who lives in an area of the country where the weather, along with personal scheduling issues (since we few of us have the luxury of flying whenever we want, even though we wish we could) make it difficult to complete these tasks? Or maybe you are looking for a way to lower the cost of flying. Is it possible to safely stay instrument current while saving some money?

Well, one way to meet instrument currency requirements is to use a flight simulator, flight training device or aviation training device ("simulator"). In addition to the lower costs and safety benefits a simulator provides to a pilot, one of the specific advantages is that a pilot may use time in a simulator for instrument currency experience.

However, use of a simulator for logging instrument flight time isn't without conditions. First, the simulator must be "approved" by the FAA (a topic for another day, but if you are curious you can review the FAA's Advisory Circular AC 61-136 for more information). Second, and equally important, in order for a pilot to log simulator time and have it count towards instrument currency, 14 C.F.R. § 61.5l(g)(4) requires that "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."

As all instrument rated pilots should already be aware, this second condition is different than simply performing the necessary instrument approaches and procedures in an actual aircraft. In the aircraft, an instructor's presence is not required. And, unfortunately, some instructors and flight schools believe that if an instructor is not required to be present when a pilot is performing the necessary approaches etc. in an aircraft, then an instructor should not be required to be present when the pilot is performing the same tasks in a simulator. However, that is not the case.

Additionally, keep in mind 14 C.F.R. § 61.57(c)(3) requires that a pilot who accomplishes instrument experience exclusively in a simulator must have performed the instrument tasks and maneuvers listed in that section within two calendar months before the month of the flight.

If you are going to use a simulator for instrument currency, make sure you are familiar with the requirements that apply to your training. When in doubt, review the regulations and associated FAA guidance. If you still have questions, contact your CFI or a knowledgeable aviation attorney.