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Logging Sim Time

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Flight Instructor, Instrument Rating

FAR 61.51(g)(4) Logging Instrument Time requires "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."  I infer from this language that the CFI doesn't have to be conducting instruction that could be logged as dual (training) time and doesn't have to be sitting next to the pilot watching the session.  The minimum would be periodic checking sufficient to confirm "the time and the content of the training session."  I'd like to be able to ask a fellow CFI at the school at which I'm employed to observe me in our AATD so that I can maintain my currency without having to pay that CFI for dual instruction while that CFI is conducting other duties, but can check in with me every so often (how often) "to verify".

Is my inference correct?  How can another CFI and I comply with this logging requirement short of conducting a dual lesson in the AATD or FTD?  What are the implications for me and for the CFI?

2 Answers



  1. Kris Kortokrax on Jun 03, 2016

    I think we’re getting in to Bill Clinton territory, where instead of debating the meaning of “is”, we need to determine the meaning of the phrase “present to observe that time”. To me present means the CFI needs to be right by the simulation device, not just in the same building. “Observe that time”, to me, means that the CFI must observe the time that will be logged.

    There is a proposed rule change to Part 61 which would allow logging time in a simulation device without having an instructor present.

    The new rule might be issued before the debate suggested above is completed.

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  2. toddski74 on Dec 08, 2016

    Does the “authorized instructor” have to be a CFII or is a CFI sufficient for just observing the time required for currency?

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