Legal Interpretations
Stewart 2014
Page 1
0 --- ··U.S. Department of Transportation Federal Aviation Administration OCT {() 2014 Mr. Andrzej Stewart
Dear Mr. Stewart:
Office of the Chie·I Counsel 800 Independence Ave., S.W.
Washington. D .C. 20591 This letter is in response to your inquiry regarding the use of flight simulators in maintaining instrument currency under 14 C.F.R. §61.57(c), and whether a flight instructor is required to. . be present when conducting instrument cunency training in a flight simulator, flight training device or aviation training device.
YOU have asked whether a flight instrnctor is required to be present when a pilot is maintaining instrument currency in a flight simulator, flight training device or aviation training device. · Title 14.Code of F:ederal Regulations § 61.51(g)(4) allows a person to use time in a flight simulator, flight training device or aviation training device for acquiring instrum~"ii.t 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." This question was answered extensively in a letter of interpretation to Mr. Terrence Keller (August 6. 2010). I have enclosed a copy of that letter for your info1mation. The aviatio~ trahiing device you asked about, a Precision Flight Controls Modular Flight Deck Advanced Aviation Trailling Device (AATD) is qual~:fied and approved by the FAA as an aviation training device. If a pilot accomplishes instrument experience exclusively in an ATD, then§ 61.57(c)(3) requires that, within the preceding two months, the pilot must have performed the instrument tasks and maneuvers listed in that section. We hope this response has been helpful to you. If you have any additional questions or further inforn.1.ati?n, please contact my staff at (202) 267-3073. This response was prepared by Neal O'Hara, an Attorney in the International Law, Legislation and Regulations Division of the Office oHhe Chief Counsel, and was coordinated with the General Aviation and Commercial Division of the Flight Standards Service.
ur Assistant Cbief Co 1 or International Law, Legislation and ~egulations Divis1 n, AGC-200 Enclosme
Retrieved from ecfr.gov on July 18, 2026.