FYI: Latest interpretation from the FAA concerning an IPC in our AATD’s (Posted 2023-10-14)

The use of Aviation Training Devices (ATD) is governed by Letters of Authorization (LOA) issued in accordance with the guidance in AC 61-136B, FAA Approval of Aviation Training Devices and Their Use for Training and Experience. The LOA specifies the tasks that may be logged in the device. Using the Redbird family as an example, the TD2 is a Basic Aviation Training Device (BATD). Its LOA lists §61.57(c)(2) instrument currency among the authorized uses but it does not list the §61.57(d)(1) instrument proficiency check. It is even more explicit later in the document, where it says, “No portion of the practical test, type specific training credit or Instrument Proficiency Check can be conducted in a BATD.” (Emphasis added.) So, while we may maintain our “six in six” instrument currency in the BATD, we may not use it to satisfy any task required for an IPC, even with an instructor evaluating us. In contrast, the LOA for the Redbird FMX, an Advanced Aviation Training Device (AATD) lists both instrument currency and an IPC as permitted uses. Unlike the BATD, there is no limiting language—just a general grant of IPC authority. This has led some to conclude that a complete IPC may be accomplished in an AATD, including the circling approach and landing tasks. It cannot. The catch is in the wording of the LOA authorization. We may use the AATD to satisfy a “§61.57(d)(1) – Instrument proficiency check,” but only per the Instrument ACS. “Per the Instrument ACS” doesn’t only mean looking at the PC task table to determine which tasks need to be accomplished. We also need to look at limitations the ACS places on the use of various devices. We find this information in two places; in a footnote to the PC Task Table on page 46 of the current Instrument-Airplane ACS and in a highlighted note in the Appendix 8 discussion of the “Use of Aviation Training Devices” at page A-17. “Note: AATDs can be utilized for the majority of the IPC as specified in the Letter of Authorization issued for the device. However, the circling approach, the landing Task, and the multiengine airplane Tasks must be accomplished in an aircraft or FFS (Level B, C, or D).” Thus, despite a general grant of authority in an AATD LOA, we nevertheless cannot use it to circle or land. Nor can we use it for the single-engine inoperative tasks in a multi. Fortunately, instrument ratings are category, but not class-specific, so accomplishing an IPC in a single renews instrument currency in a twin. Why the difference between Basic and Advanced? Most BATD are not much more sophisticated than an uncertified home PC simulator like XPlane or Microsoft Flight Simulator. An AATD is held to more rigorous standards. The FAA has come a long way in permitting some training and self directed pilot currency with relatively minimal equipment. They probably want something more for the checkride-like evaluation in an IPC.