TouchTrainer, X-Plane, Foreflight and PilotEdge

[BrianM]

Hi Keith,

I use a TouchTrainer and just joined PE and find the combination to be outstanding. Keep up the great work.

The only thing that could be better would be if I could log my instrument flying for my currency requirements. It seems that you have the technological capability to provide as service (as a premium service or on a per hour basis) whereby you have a CFI "observe" a currency flight and certify for logbook purposes.

There is quite a bit of uncertainty about using a BATD for currency but, as best as I can determine, a CFI is required to observe the session and certify the experience or endorse the log book.

As I’m sure you know, with respect to §61.51(g)(4), there is a discrepancy between the preamble to the 2009 rule change and the actual rule. The preamble suggests that a flight instructor does not need to be present for logging experience but the actual rule does require a flight instructor to sign the log book or training record.

The preamble provides:

Provided the person is instrument current or is within the second 6-calendar month period’’ (See § 61.57(d) for currency). A person would not need a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of § 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator. Only when a person is required to submit to an instrument proficiency check must a flight instructor or ground instructor be present. The rationale is that a person is not required to have a flight instructor or ground instructor present when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft. If the person is using a view-limiting device (i.e., hood device) when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft, only a safety pilot is required to be present. If a person is performing approaches, holding, and course intercepting/tracking tasks in an aircraft in IMC, it is permissible to log the tasks without a flight instructor being present. Therefore, a person who is instrument current or is within the second 6-calendar month period (See § 61.57(d) for currency) need not have a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of § 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator.

However, the rule states

(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument 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.

It would be great if PE offered a service that allows pilots to satisfy the experience requirement online. Note that the FAA has commented that an instructor need not always be sitting next to the pilot for the whole session:

27. This revision of Sec. 61.51(g)(4) conforms the rule for logging of instrument time in a flight simulator, flight training device, and aviation training device to existing policy.

This final rule amends Sec. 61.51(g)(4) to allow logging of instrument time in a flight simulator (FS), flight training device (FTD), or aviation training device (ATD) conforming to existing regulation or policy. An authorized instructor (See Sec. 61.1(b)(2)) must be present in the FS, FTD, or ATD when instrument training time is logged for training and aeronautical experience for meeting the requirements for a certificate, rating, or flight review (See Sec. 61.51(a)) [emphasis added]. The instructor must sign the person’s logbook verifying training time and session content. Examples of situations in which an authorized instructor will be considered present would be where an authorized instructor is seated at a center control panel in a flight simulation lab and is monitoring each student’s performance from control panel display. Another example would be a situation where an instructor assigns a student several instrument tasks and then leaves the room. In such cases, if the flight training device has a monitoring and tracking system that allows the authorized instructor to review the entire training session, the instructor need not be physically present. Another example would be a situation where one authorized instructor monitors several students simultaneously in the same room at a flight simulation lab.

For example, Pilot Edge could offer a separate service where the pilot wants to log the experience and they have a flight instructor monitor the session and send an email with a “training record” after the session. It appears from the above statement from the FAA that a single instructor could monitor multiple pilots simultaneously.

I reached out to Carl at FTS to see if they might do something but figured I would reach out to you as well. Would love your thoughts on this. Once again, awesome product!

[Keith Smith]

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