In a recent Legal Interpretation, the FAA reaffirmed its position that an individual acting as a check airman or flight instructor in a simulator must fly at least two flight segments for the type aircraft involved within the 12-month period preceding the performance to comply with 14 C.F.R. § 135.337(f). The Interpretation responded to an inquiry from a Part 142 Training Center asking whether a Part 135 check airman/instructor conducting turbine aircraft flight checks/flight instruction in a simulator could use a multi-engine piston aircraft to satisfy the requirements of §§ 14 C.F.R. § 135.337(f) or 14 C.F.R. § 135.338(f). Both sections require that the check airman/instructor
- Fly at least two flight segments as a required crewmember for the type, class, or category aircraft involved within the 12-month preceding the performance of any check airman or flight instructor duty in a flight simulator; or
- Satisfactorily complete an approved line observation program.
In its request the training center explained that it was either cost prohibitive or simply not feasible for a training center or contract check airman/flight instructor to be able to satisfy these requirements in an actual turbine aircraft. On the other hand, accomplishing the flight segments or line observation in a multi-engine piston aircraft was not only more economical, but was actually feasible given the availability of multi-engine piston aircraft for rent.
In response, the Interpretation states that
recency of experience in a light piston engine would not satisfy the recency requirements for serving as a check airman or instructor in an aircraft of a different type, class, or category aircraft. Because the purpose of the requirements is for experience in a similar aircraft, the aircraft type must be the same. If the aircraft does not have a type rating, then the class and category, in that order, must be the same.
So, if you are a conducting Part 135 flight checks or instruction in a simulator, you will need to make arrangements to obtain the required currency experience in a similar aircraft. Unfortunately, this will make it more difficult, and more expensive, for training centers to either obtain or maintain qualified check airmen/instructors.