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4 Answers

Crediting Sim Time Towards 250 Hours Required For Commercial

Asked by: 880 views Commercial Pilot

Hi, I am confused on the regs' requirements for the Commercial. I keep finding sources online (in forums) stating that up to 50 hours of sim time can be counted towards the 250 for the commercial. I.e.: 200 in airplanes, 50 hours sim, as opposed to doing all 250 hours in a plane. I have 23 hours in a sim, all with CFI endorsement, and will probably have about 40 by the time my instrument rating is finished. None of the forum threads I've read so far have cited a source, besides saying it's under "part 61". When I open my FAR/AIM I cannot find the language anywhere that states that sim time can be used. Can somebody help clarify? Thanks!

4 Answers



  1. Mark Kolber on Feb 25, 2017

    Since you are working on the commercial certificate, my answer is intentionally not pointing you at exactly the reg. And, since we don’t know each other, I may speak in terms that are unnecessarily simplistic. If I do, I apologize. At this point, you really need to know how to look at them. Big hint: go find the table of contents for Part 61. Look at how it’s broken down. It’s a big outline with parts and subparts organized in a reasonable, almost logicel, fashion.

    That said, go to the reg that lists the aeronautical experience requirements for commercial pilots.

    You mah have already looked at it. The trouble with that reg is it lists the requirements from the commercial certificate with every aircraft category/class rating available. But way down at the bottom is a subsection called “Permitted credit for use of a flight simulator or flight training device.”

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  2. Victorino Omar Rasmussen on Mar 01, 2017

    Found it, thanks for sending me on the search- and you’re right, it was easy to find, just have to know how to search. After reading it, I got excited that I’d be able to log the time, but when I pointed it out to my instructor, he pointed out that it has to be specifically time in a flight sim or flight training device only. All my sim time is in an atd, so no benefit for me on this one.

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  3. Mark Kolber on Mar 03, 2017

    Don’t give up hope just yet, Victorino! It depends on the ATD.

    The FAA has a catch-all reg about devices, FAR 61.4(c) tells us, “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.”

    I don’t know which ones they are, but I fairly certain there are Letters of Authorization out there permitting certain ATDs to be used to satisfy commercial requirements. Like so many things in aviation, a lot of it is about paperwork.

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  4. Victorino Omar Rasmussen on Mar 03, 2017

    Mark, thanks for that. As a matter of fact, since leaving my last comment, I did more digging and ended up finding out directly from the FAA’s simulator certification program director, that some ATD’s in fact can be used for the commercial requirements. As you said, it has to be spelled out in the LOA. So his response gave me hope, which prompted me to call the manufacturer of the simulator itself (Redbird). They looked up the model by the flight school’s purchase history, and did in fact confirm that the Redbird LD model will satisfy up to 50 hours of flight time.

    Funny thing is, the flight school was unaware of this, so they have not been marketing it as such.

    Thanks for your assistance!

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