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Counting Military SIM time towards total time, ATP

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FAA Regulations

I've acquired a significant amount of SIM time in the Army, both in helicopters and airplanes. They were all full motion, and performed between 1989 and 1996. All were located at Ft Rucker, and I believe the helicopter flight SIMs belonged to the Army, but the U-21 SIM (FWMEQC) belonged to Flight Safety International, since they were the contractors at that time.

Most of the SIM time in helicopters was part of the Initial Entry Rotary Wing Course, while some was not. All of the fixed wing SIM time was acquired during the FWMEQC.

My questions are:

1) Does this Army SIM time count towards total flight time? 

2) Since up to 100 hours in a SIM can count towards an ATP, does this time qualify?

3) Regarding question 2, does all of the 100 hour SIM time have to be in a airplane, or can the helicopter SIM count?

1 Answers



  1. Kris Kortokrax on Nov 20, 2022

    Let’s start with the ATP requirements.

    61.160 (a) allows you, as a former military pilot, to qualify for a Restricted ATP with a minimum of 750 hours of total time as a pilot and 200 hours of cross country flight time, if you meet the qualifications in 61.160(a)(1) & (2). It does say that you still need to meet all the other requirements of 61.159.

    61.159 (a) requires
    1500 hours of total time as a pilot (750 for restricted ATP) (per 61.159(a)(6), not more than 100 hours of FSTD time may be credited toward the 1500 hour requirement in 61.159(a).
    500 hours of cross-country flight time (200 for restricted ATP),
    100 hours of night flight time,
    50 hours of flight time in class,
    75 hours of instrument flight time in actual or simulated IMC (25 hours of credit in FSTD, 50 if training was done under 142) and if the FSTD represents an airplane.

    Now let’s look at some definitions.

    1.1 defines “Flight time” as pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing.

    61.1 defines “Pilot time” as time when one “Receives training from an authorized instructor in an aircraft, full flight simulator, flight training device or aviation training device.”

    61.1 defines “Flight training” as “training, other than ground training, received from an authorized instructor in flight in an aircraft”.

    61.1 defines “Authorized instructor” as a person who holds a Ground instructor certificate issued under Part 61 and is in compliance with 61.217; a person who holds a flight instructor certificate issued under Part 61 and is incompliance with 61.197; or a person authorized by the Administrator to provide ground or flight training under Parts 61, 121, 135 or 142 when conducting training IAW that authority.

    Now we need to look at 61.41(a). It states that
    “A person may credit flight training toward the requirements of a pilot certificate or rating issued under this part, if that person received the training from:
    (1) A flight instructor of an Armed Force in a program for training military pilots of either –
    (i) The United States; or
    (ii) A foreign contracting State to the Convention on International Civil Aviation.”

    This would seem to indicate that simulator time acquired in the military could not be credited under 61.41, since it specifically refers to “Flight training” and the definition in 61.1 requires that it be time conducted in flight. The training would also need to be conducted by an “Authorized Instructor” and it appears that a military instructor would not qualify.

    So, answering your questions in the order presented:

    1. No Sim time, whether civilian or military would count toward total flight time, although it could be counted toward total time as a pilot in 61.159(a), if it is civilian Sim time.

    2. The 100 hours of Sim time as referenced in 61.159(a)(6), can only be used if acquired in an approved training program conducted under Parts 121, 135, 141 or 142.

    3. 61.159(a)(6) does state that the 100 hours of Sim time must be in an airplane, although this question is moot, because you can’t use the military Sim time.

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