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Who can sign off on using an ATD for training?

TL;DR Training: You need a CFII to sign off on Basic Aviation Training Device (BATD) hours that are used for the Instrument Rating or Commercial Certificate. You can use up to 10 hours in a BATD or 20 hours in a Advanced Aviation Training Device (AATD) CFI can sign off on up to 2.5 hours of training for private pilot single or multi-engine land.

TL;DR Endorsements: You cannot use a BATD or AATD to receive a complex, high performance, or tailwheel endorsement but you can use a full flight simulator or flight training device.

TL;DR Currency: You do not need to have an instructor present when using an Aviation Training Device to maintain IFR currency—§61.51 (f)(5). You cannot use a BATD or AATD for landing currency unless at a Part 142 center. You can’t use them for night currency.

BATDs and AATDs must be approved by the FAA. So your home flight sim, no matter how sophisticated, doesn’t work for training unless it is sold by one of the companies that jumped through the hoops got it approved.

A good place to start to figure out the differences between the different types of training devices is AC 61-136B Aviation Training Devices. This AC describes what is required for a device to be a Basic or Advanced Aviation Training Device but does not cover the more sophisticated Flight Training Devices or Full Flight Simulators that are used for type ratings and for recurrent training by the airlines and for high-end aircraft.

The device that I have been using, FlyThisSim, meets the qualifications of a BATD. You can find their Letter of Authorization (LOA) on their website. Even though I am running the same software on my computer, it doesn’t meet the requirements for an Aviation Training Device so none of the time is loggable. The Redbird systems are more sophisticated and are Advanced Aviation Training Devices.

A newly minted CFI that I know has a BATD and is going to rent it out for flight training. He also has an Advanced Ground Instrutor (AGI) certificate and thought that he was qualified to sign off on people using it while training for the Instrument Rating.

My first thought was that he can’t sign IFR students off since I would think you would need an IGI certificate to train for an instrument rating. Also, it is not ground training, so a Ground Instructor can’t sign off—even though the training happens on the ground. The FARs mention authorized instructor several times but don’t always specify who is authorized. The exception is providing training for the instrument rating which requires a CFII. That limitation on the privileges of a CFI seem to me to restrict who can sign off on ATD training.

If the Legal Interpretation in Beard is still the most recent, it confirms my reading of the FARs. A CFII is required for the instrument training required for the Instrument Rating and Commercial Certificate.

It has been the FAA’s consistent interpretation of §61.195(b) and (c) that, in order to conduct instrument flight training in an aircraft, a flight instructor must hold on his or her flight instructor certificate (1) aircraft category and class ratings for the aircraft in which the training is conducted, and (2) an instrument rating appropriate to the category of aircraft. Interpretation to Taylor Grayson, January 4, 2010. As § 61.195 was originally written before the rules permitted flight simulators and flight training devices to be used for training, it does not mention conducting instrument flight training in those devices. However, the FAA has interpreted the instructor requirements under this section to apply to instruction in flight simulators and flight training devices, as well, since these devices are designed to replicate flight by category and class of aircraft. The FAA will examine §61.195 to determine whether we need to clarify the regulation.

I have collected all of the FARs that apply to training. When it refers to authorized instructor, it means that the instructor has the ratings on their Flight Instructor certificate appropriate to the kind of training being given.

§61.1 Applicability and definitions.
Aviation training device means a training device, other than a full flight simulator or flight training device, that has been evaluated, qualified, and approved by the Administrator.

Pilot time means that time in which a person—
(i) Serves as a required pilot flight crewmember;
(ii) Receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device;

Training time means training received—
(i) In flight from an authorized instructor;
(ii) On the ground from an authorized instructor; or
(iii) In a flight simulator or flight training device from an authorized instructor.

§61.31 Type rating requirements, additional training, and authorization requirements.
(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane, unless the person has—
  (i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and … [received a one-time endorsement]

(f) Additional training required for operating high-performance airplanes. (1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has—
  (i) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a full flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane; and … [received a one-time endorsement]

§61.51 Pilot logbooks.
(4) A person may use time in a full flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate or rating 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.

(5) A person may use time in a full flight simulator, flight training device, or aviation training device for satisfying instrument recency experience requirements provided a logbook or training record is maintained to specify the training device, time, and the content.

(h) Logging training time.
  (1) A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.
  (2) The training time must be logged in a logbook and must:
   (i) Be endorsed in a legible manner by the authorized instructor; and
   (ii) Include a description of the training given, the length of the training lesson, and the authorized instructor’s signature, certificate number, and certificate expiration date.

§61.65 Instrument rating requirements.
(i) Use of an aviation training device. A maximum of 10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device may be credited for the instrument time requirements of this section if—
  (1) The device is approved and authorized by the FAA;
  (2) An authorized instructor provides the instrument time in the device; and
  (3) The FAA approved the instrument training and instrument tasks performed in the device.

§61.57 Recent flight experience: Pilot in command.
(2) Use of a full flight simulator, flight training device, or aviation training device for maintaining instrument experience. A pilot may accomplish the requirements in paragraph (c)(1) of this section in a full flight simulator, flight training device, or aviation training device provided the device represents the category of aircraft for the instrument rating privileges to be maintained and the pilot performs the tasks and iterations in simulated instrument conditions. A person may complete the instrument experience in any combination of an aircraft, full flight simulator, flight training device, or aviation training device.

§61.195 Flight instructor limitations and qualifications.
(c) Instrument rating. A flight instructor may conduct instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates if the following requirements are met:

(1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate, and—

§61.215 Ground instructor privileges.
(c) A person who holds an instrument ground instructor rating is authorized to provide:

(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;
(2) Ground training required for an instrument proficiency check; and
(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.

§61.65 Instrument rating requirements.
(5) Receive and log training on the areas of operation of paragraph (c) of this section from an authorized instructor in an aircraft, full flight simulator, or flight training device that represents an airplane, helicopter, or powered-lift appropriate to the instrument rating sought;

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

(i) Use of an aviation training device. A maximum of 10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device may be credited for the instrument time requirements of this section if—
  (1) The device is approved and authorized by the FAA;
  (2) An authorized instructor provides the instrument time in the device; and
  (3) The FAA approved the instrument training and instrument tasks performed in the device.

§61.109 Aeronautical experience.
(a) For an airplane single-engine rating.
(b) For an airplane multiengine rating.
(k) Permitted credit for use of a full flight simulator or flight training device. (1) Except as provided in paragraphs (k)(2) [Part 142] of this section, a maximum of 2.5 hours of training in a full 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.

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