How can Simulator Time be applied towards Minimum Flight Time Requirements for Commercial Certificate ?

7 Answers

1. 
   

   
   

   Bryan on Mar 14, 2022

   You were almost there. In 61.129…keep scrolling down to (i). There’s no differentiation between part 61 and part 141 schools–only part 142 (training centers) and everything else. For purposes of this discussion, I don’t think you’re at a part 142 training center and you’re most likely talking about airplane rather than helicopters, so we’ll focus on 61.129(i)(1)(i):

   (1) Except as provided in paragraph (i)(2) of this section, an applicant who has not accomplished the training required by this section in a course conducted by a training center certificated under part 142 of this chapter may:

   (i) Credit a maximum of 50 hours toward the total aeronautical experience requirements for an airplane or powered-lift rating, provided the aeronautical experience was obtained from an authorized instructor in a full flight simulator or flight training device that represents that class of airplane or powered-lift category and type, if applicable, appropriate to the rating sought;

   So the direct answer to your question is that a maximum of 50 hours may count toward the total requirement of 250 as long as the simulator or training device represented the same class of airplane (ASEL, AMEL, etc.) that the commercial certificate sought will be. You can also pick up simulated instrument time in the simulator as per 61.65(h) and (i) and 2.5 hours can count toward aeronautical experience for a private certificate per 61.109(k). But note that each of these requires you to do it with an authorized instructor. So if you go in there alone, it doesn’t count.

   Sim time is flight time (even though you’re not flying) so long as it meets the requirements of the applicable regulation. But you cannot get cross country time in a sim–only total time or instrument time per the regs cited above.

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   PedroThePilot on Mar 14, 2022

   Thank you Bryan.

   Yes, like most students I am at a Part 61 operation, and in an ASEL, not a helicopter.

   It was the fifty hour XC PIC time requirement that I was most concerned about. Thank you for your help in reviewing the CFR with a more in depth analysis. So if I understand your comments correctly, the following time building is permissable in a properly rated FAA approved SIM.

   #1 With a properly rated CFII, I can log dual instrument time.

   #2 For purposes of building overall skills and ” total aeronautical experience requirements “, I can use the SIM in either solo mode, or with an instructor, but regardless of which manner, such time may not be designated as XC PIC time for the purposes of fulfilling any minimum Commercial certificate or Instrument rating XC PIC requirements.

   And finally, if I may ask one related follow up question.

   Once all XC PIC requirements for the Commercial and/or Instrument have been met via actually flying time in the air in an airplane, I assume any SIM time beyond that for the purposes of continuing to build more ” total aeronautical experience ” may be designated as XC PIC time as long as it is not being applied towards any sort of Rating or Certificate.

   Is that a correct interpretation?

   Bryan, I struggle a lot trying to properly interpret the many Regulations. So your help, and that of so many others on this website, is deeply appreciated.

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3. 
   

   
   

   Bryan on Mar 14, 2022

   No worries. The regulations can be tricky to read sometimes.

   Your #1 statement is correct. You can also count approaches flown or holds performed in the simulator for purposes of instrument currency under 61.57(c)(2) or even an instrument proficiency check (IPC) under 61.57(d)(2)(ii). The currency requirements can be satisfied without an authorized instructor, but the IPC has to have an instructor.

   Your #2 statement is close. What you missed is the requirement to be with an instructor. For the private certificate per 61.109(k)(1) (“received from an authorized instructor”), for the instrument rating per 61.65(h) and (i) (“an authorized instructor provides the instrument time”), and for the commercial certificate per 61.129(i)(1)(i) (“obtained from an authorized instructor”), you cannot count hours in the simulator toward aeronautical experience unless you were with an instructor for that sim time.

   If you remember back to 61.51, the only time you have to log is what you will use toward a certificate or to satisfy recency requirements, right? Taken together, these regs are saying that simulator time used to get any certificate or rating must be with an authorized instructor. An IPC necessarily involves an instructor whether it happens in a plane or a simulator. The only thing you can do in a simulator alone and log for any effect is keeping current for instrument recency under 61.57.

   For your question logging XC time, let’s go back to 61.1:

   Cross-country time means –

   (i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight –

   (A) Conducted by a person who holds a pilot certificate;

   (B) Conducted in an aircraft;

   (C) That includes a landing at a point other than the point of departure; and

   (D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

   Because the definition of cross-country includes “time acquired during flight” that is also “conducted in an aircraft,” you are not going “cross-country” unless you are actually flying. Thus, you cannot log any sim time as cross-country.

   When 61.129(a)(2)(ii) says you have to have 50 hours cross-country of which 10 hours must be in airplanes, the other 40 could be in powered lift, helicopter, etc. But it must be in an aircraft–not a simulator.

   I hope that helps. Good job asking first because the FAA does not look kindly on asking forgiveness later.

   Happy flying!

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   Mark Kolber on Mar 14, 2022

   >>You can also count approaches flown or holds performed in the simulator for purposes of…an instrument proficiency check (IPC) under 61.57(d)(2)(ii).

   It depends on the “simulator.” You need to read the Letter of Authorization. For example, the Redbird B190X AATD can be used for an IPC but the TD2 BATD cannot.

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5. 
   

   
   

   Russ Roslewski on Mar 15, 2022

   Mark, to avoid giving people the wrong idea, I always make sure to specify that an AATD like the Redbird B190X or FMX can be used for “parts” of an IPC, but not the whole thing.

   Redbird, in their LOA, doesn’t make this particularly clear, just saying it can be used for the “Instrument proficiency check, per the Instrument ACS”. That “per the Instrument ACS” statement, of course, lets them account for any future changes to the ACS without having to change the LOA itself.

   But the current ACS says you can’t do the circling approach, landing, and multiengine tasks in the AATD. ACS, page A-19.

   I am 100% positive that not everybody realizes this and that there are many IPC’s being signed off in a Redbird AATD.

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6. 
   

   
   

   Kris Kortokrax on Mar 17, 2022

   Bryan,

   Sim time is not flight time. Flight time is defined in Part 1.
   The time spent in a Sim or training device may be credited toward the aeronautical experience requirements, but may not be logged as flight time.

   See Order 8900.1, Volume 11, Chapter 10, Section 1, Paragraph 11-10-1-21C.

   C1 states ” Any columns in a pilot record that reference flight time should remain blank when logging ATD time.”

   It also states “Simulated instrument time can be logged in an ATD, but only during the time when the visual component of the training session is configured for instrument meteorological conditions (IMC) and the pilot is maintaining control solely by reference to the flight instruments.”

   C2 states “ATD time can only be logged as total time, instruction received (dual), and/or instrument time, as provided on FAA Form 8710-1, Airman Certificate and/or Rating Application, Section III, Record of Pilot Time.”

   Logbooks can create a problem. I just went back and looked at my logbooks. The earlier two have a column that is labeled “Total time”. All the Jeppesen ones after that have a column titled “Total duration of flight”.

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7. 
   

   
   

   Mark Kolber on Mar 17, 2022

   Correct and a great point, Russ.

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