FAR 91.109 — Simulated Instrument Flight
FAR 91.109 explains dual control requirements for flight instruction, safety pilot rules for simulated instrument flight, and ATP flight test seat requirements.
In Plain English
FAR 91.109 governs three related situations: giving flight instruction, flying under the hood (simulated instrument flight), and certain flight tests.
- Flight instruction generally requires the aircraft to have fully functioning dual controls. An exception allows instrument instruction in an airplane with a single throwover control wheel if the instructor judges the flight safe and the person manipulating the controls holds at least a private pilot certificate with appropriate ratings.
- A throwover-equipped airplane may also be used for a flight review (§61.56), recent experience, or an instrument proficiency check (§61.57) if rudder pedals exist at both stations, the pilot flying is qualified as PIC for the whole flight, and the instructor meets §61.195(b) and has at least 25 hours PIC in make and model.
- Simulated instrument flight requires a safety pilot in the other control seat with at least a private certificate (category/class appropriate), adequate forward and side vision (or a competent observer to supplement it), and fully functioning dual controls — with a throwover-wheel exception for single-engine airplanes.
- For an ATP flight test, class/type rating ride, or Part 121 proficiency check, the other pilot at the controls must be fully qualified to act as PIC.
This rule matters because hood time and instruction are core to building proficiency safely — knowing the safety pilot and equipment requirements keeps the flight legal and protects everyone on board.
Regulation Text
14 CFR § 91.109§ 91.109 Flight instruction; Simulated instrument flight and certain flight tests.
(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when—
(1) The instructor has determined that the flight can be conducted safely; and
(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by § 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by § 61.57 when—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;
(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;
(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of § 61.195(b), and has logged at least 25 hours of pilot-in-command flight time in the make and model of airplane; and
(4) The pilot in command and the instructor have determined the flight can be conducted safely.
(c) No person may operate a civil aircraft in simulated instrument flight unless—
(1) The other control seat is occupied by a safety pilot who possesses at least:
(i) A private pilot certificate with category and class ratings appropriate to the aircraft being flown; or
(ii) For purposes of providing training for a solo cross-country endorsement under § 61.93 of this chapter, a flight instructor certificate with an appropriate sport pilot rating and meets the requirements of § 61.412 of this chapter.
(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and
(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when—
(i) The safety pilot has determined that the flight can be conducted safely; and
(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft.
[Docket 18334, 54 FR 34294, Aug. 18, 1989, as amended by Amdt. 91-324, 76 FR 54107, Aug. 31, 2011; Amdt. 61-142, 83 FR 30281, June 27, 2018]
Oral Exam Questions a DPE Might Ask
Q1What are the requirements for a safety pilot during simulated instrument flight?
Per FAR 91.109(c), the safety pilot must occupy the other control seat, hold at least a private pilot certificate with category and class ratings appropriate to the aircraft, and have adequate forward and side vision (or a competent observer to supplement it). The aircraft generally must have fully functioning dual controls.
Q2Can flight instruction be conducted in an airplane with a single throwover control wheel?
Yes, but only for instrument instruction under FAR 91.109(a), provided the instructor determines the flight can be conducted safely and the person manipulating the controls holds at least a private pilot certificate with appropriate category and class ratings.
Q3On an ATP checkride, what qualifications must the other pilot at the controls have?
Under FAR 91.109(d), the pilot seated at the controls other than the applicant being checked must be fully qualified to act as pilot in command of the aircraft.
Studying for a checkride?
Related Sections in Part 91