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2 Answers

How to log simulator time towards my commercial license

Asked by: 1965 views Commercial Pilot, FAA Regulations, Flight Instructor

I am a private pilot with a newly acquired instrument rating. I did some of my instrument training with an instructor who has his multi-engine CFI and is also CFII. He is not single engine CFI. 

I have already done 20 hours sim time with him working towards my instrument rating. Since I can use 50 hours simulator time towards my commercial license (single engine), I wanted to take advantage of that and do more sim time with this instructor, but not sure how I could log it. We could do multi-engine training, but would that be able to count towards singe engine commercial time? Or if we did more instrument training could I count that time towards the 250 hrs? (Even though I already have my instrument rating)

Any insight would be appreciated. Thanks!

2 Answers



  1. John Scarry on Mar 07, 2021

    An instructor with a multi-engine CFI can’t give instruction in a single engine aircraft, so any sim training in a single-engine aircraft that you have with him can’t be logged at all.

    §61.51 Pilot logbooks.
    (v) Training received in a full flight simulator, flight training device, or aviation training device from an **authorized instructor**.

    §61.195 Flight instructor limitations and qualifications.
    (c) Instrument rating. A flight instructor may conduct instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates if the following requirements are met:

    (1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating ***appropriate to the aircraft used*** for the instrument training on his or her flight instructor certificate, and—

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  2. awair on Mar 08, 2021

    John,

    The paragraph you’ve quoted is for the Instructor’s Instrument Rating – there is only one for airplanes: there is no differentiation between SEL & MEL.

    Para (c)(1)(ii) then covers the exemption to the aircraft rating required [in (b)]: which for SEL (& SES) Instrument training does not require a CFI – if the pilot is already rated.

    So a CFII can give training as an authorised instructor in specific circumstances, as stated in (c).

    This is then re-stated in 61.195 (l) [that’s lowercase L…], which permits more general training.

    While (c) could be read to only permit the 10 hours from 61.129(a)(3)(i), para 61.195(l) appears to cover the 50 hours in 61.129(i).

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