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Should a CFII log sim instruction in their CFI column?

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FAA Regulations, Flight Instructor

Hi! I am a CFII. I often give instruction in various BATDs and AATDs as part of an instrument ratings before doing the lessons in an actual aircraft.

61.1 defines "flight training", "instrument training", "ground training", and "training time".  The FAA clearly defined the training, but not what counts as instruction for an instructor to log it, nor is this mentioned in 61.51. In my eyes, if I'm giving anything that counts as "flight training" or "instrument training", especially since the definition of "training time" includes specifically "(iii) In a flight simulator or flight training device from an authorized instructor.", and I'm signing a student's logbook for "dual received," which requires a flight instructor certificate to make that signature, then I can log this as CFI or "dual given".

My question is simple, but I have yet to see a letter of interpretation on this specifically, so please help me out: should I log the simulator instruction given in my CFI column in my paper logbook, alongside flight training given in aircraft, that counts toward my total dual given? I don't need the ours for anything and it's easy enough to separate it out on my electronic logbook as needed, but I don't want to mess up my paper logbook or have any questions come up later on.

Thansks!

2 Answers



  1. KDS on Sep 11, 2019

    Other than for the purpose of keeping a ground instructor certificate current, I can’t think of any reason to log the time. However, in a little bit Mark will come along and give both of us the definitive answer.

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  2. Kris Kortokrax on Sep 11, 2019

    You are correct that 61.51 is silent on the subject.

    141.35 and 141.36 contain qualification criteria for chief and assistant chief instructors. There are requirements for a certain number of hours of experience as a flight instructor. There is an old interpretation from 1992 that refers to 141.35(d)(2), but it is addressing PIC time. The current 141.35(d)(2) addresses instruction time.

    If you don’t think you will ever seek a job as a 141 chief or assistant chief, it doesn’t matter much.

    Another consideration is including the number in a “Total Time” type column.
    61.1 contains a definition of “Pilot time” which includes time spent providing training in a simulation device.
    1.1 contains a definition of “Flight time” which must be in an aircraft.

    If you are planning on a job with the airlines, they may or may not want the simulator instruction time included in a total time figure.

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