Legal Interpretations
Stewart 2014
Summary
The Question
Must an authorized instructor be present when a pilot uses a flight simulator, flight training device, or aviation training device to maintain instrument currency?
Background
An individual asked whether instrument currency training under 14 CFR 61.57(c) in a flight simulator, flight training device, or aviation training device requires a flight instructor, naming a Precision Flight Controls Modular Flight Deck Advanced Aviation Training Device.
The FAA’s Interpretation
Yes. 14 CFR 61.51(g)(4) allows time in a flight simulator, flight training device, or aviation training device to be used for instrument recency experience provided an authorized instructor is present to observe that time and signs the logbook or training record. If instrument experience is done exclusively in an ATD, 14 CFR 61.57(c)(3) requires the listed tasks within the preceding two months.
- Requester
- Stewart
- Issued
- October 10, 2014
- Subject
- Pilot Certification & Privileges
Regulations Cited
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 information. 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.
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Assistant Cbief Co 1 or International Law, Legislation and ~egulations Divis1 n, AGC-200
Enclosme
Regulations Referenced
Snapshot retrieved August 6, 2026.