Commercial Pilot Training - AATD Simulator

[labbadabba]

So, I can log up to 50 hours in an FAA-approved AATD simulator towards my commercial rating.

I currently sit at 160 hours TT SEL.

Under Part 61.129(a) I need: 250 total hours of 'flight time' with 100 hours in a SEL and 100 hours PIC

How do these two things reconcile? I spoke to my DPE and he would consider the 50 hours in the sim as part of of the 250 total hours for the rating but I'm not sure how I would log it. When doing sim work for my instrument rating, I logged it under 'Ground Trainer' and 'Simulated Instrument' so the instrument time contributed towards my 40 hours of instrument training but I didn't count those hours towards my 'Total Time.'

If I need 250 hours total 'flight time', do I then count my sim time towards the 250 as part of my Total Time? If it doesn't count towards your total time, then what's the point of stating that you can count up to 50 hours in in a sim towards the rating?

 

[MauleSkinner]

First, is "total time" shown in your logbook, or "total flight time"? Mine says "total time", and everything adds into it.

Second, now would be a good time to determine whether your logbook will show everything possible for you to legally log, or will show your times in a manner that make this stuff easier.

It's obvious when someone looks at my logbook that simulator time IS included in total time, because everything adds up across the bottom of the page...ASEL, AMEL, ASES, GGlider, & Sim add up to total. PIC, SIC, & Dual Received add up to total (I didn't log both PIC and Dual Received, even though I could...I logged whoever one the flight was about.)

In your case, it doesn't matter if sim time is included in total or not, as long as it can be easily shown which way you went.
You go into your checkride with 200 hours in airplanes and 50 hours sim time, it doesn't matter whether your logbook says 200 total time as long as the examiner can easily see that your sim time is not included in the 200 hours.

Whichever way you go, make life easy for the examiner...said an examiner.

 

[labbadabba]

First, is "total time" shown in your logbook, or "total flight time"? Mine says "total time", and everything adds into it.

Second, now would be a good time to determine whether your logbook will show everything possible for you to legally log, or will show your times in a manner that make this stuff easier.

It's obvious when someone looks at my logbook that simulator time IS included in total time, because everything adds up across the bottom of the page...ASEL, AMEL, ASES, GGlider, & Sim add up to total. PIC, SIC, & Dual Received add up to total (I didn't log both PIC and Dual Received, even though I could...I logged whoever one the flight was about.)

In your case, it doesn't matter if sim time is included in total or not, as long as it can be easily shown which way you went.
You go into your checkride with 200 hours in airplanes and 50 hours sim time, it doesn't matter whether your logbook says 200 total time as long as the examiner can easily see that your sim time is not included in the 200 hours.

Whichever way you go, make life easy for the examiner...said an examiner.

My Total Time column reads as 'Total Duration of Flight'.

At this point, I've not been including sim hours in that total. It may be easier just to keep them separate and show my sim time separately.

But you're reading the regs the same way though right? That the 50 hours SIM contributes to the 250 total hours for the rating? I'm kind of hung up on the part where it says in the FARs that there has to be 250 hours of flight time, but flight time is not explicitly defined....

 

[MauleSkinner]

What's the reference that says the 50 hours can be counted?

 

[labbadabba]

What's the reference that says the 50 hours can be counted?

§ 61.129 Aeronautical experience.
(a)For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.

(2) 100 hours of pilot-in-command flight time, which includes at least -

(i) 50 hours in airplanes; and

(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.

Flight Time is ill-defined and not sure if someone would contest sim time as not being flight time. I've already run it past my DPE so I think I'm okay, I just want to make sure I can defend the position if questioned.

 

[mtuomi]

§ 61.129 Aeronautical experience.
(a)For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.

(2) 100 hours of pilot-in-command flight time, which includes at least -

(i) 50 hours in airplanes; and

(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.

Flight Time is ill-defined and not sure if someone would contest sim time as not being flight time. I've already run it past my DPE so I think I'm okay, I just want to make sure I can defend the position if questioned.

Flight Time is NOT ill-defined.

"
Flight time means:

(1) 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; or"

"an aircraft moves". AATD is not an aircraft, so you cannot log Flight Time in one unless you can find a Chief Counsel letter than disagrees with that.

Note the different wording in ATP requirements. That says "Total Time as a pilot", and then specifies the amount allowed for sim time.

I doubt you can use AATD time towards your flight time requirement for CP.

 

[Axtel4]

I always took it as "powered aircraft". Fifty hours must be in airplanes and the balance could be in rotorcraft and airships. Thus the sim time doesn't count as it is not a powered aircraft. The time in a rotorcraft or airship could be counted towards the 250 hours.

And yea, the 250 hours can take awhile.

 

[BrianNC]

Thus the sim time doesn't count as it is not a powered aircraft.

I have read somewhere in times past that you can use 50 hours of sim time toward the commercial. I've had discussions in the past with others that agreed. I can't find it now.

 

[BrianNC]

I always took it as "powered aircraft". Thus the sim time doesn't count as it is not a powered aircraft.

I doubt you can use AATD time towards your flight time requirement for CP.

Here it is, down at the bottom of all the requirements:

(i)Permitted credit for use of a flight simulator or flight training device.

(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 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; and

 

[MauleSkinner]

Flight Time is ill-defined and not sure if someone would contest sim time as not being flight time. I've already run it past my DPE so I think I'm okay, I just want to make sure I can defend the position if questioned.

As @mtuomi stated, fight time has a very specific definition that does not include simulators/FTDs.

This is what I was looking for...

Here it is, down at the bottom of all the requirements:

(i)Permitted credit for use of a flight simulator or flight training device.

(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 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; and

...which basically says that up to 50 hours of sim/FTD time can be substituted for flight time requirements of aeronautical experience.

 

[mtuomi]

Here it is, down at the bottom of all the requirements:

(i)Permitted credit for use of a flight simulator or flight training device.

(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 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; and

Good find Brian, that's OPs question answered.

 

[BrianNC]

Good find Brian, that's OPs question answered.

I have no idea why it's all the way at the bottom of all those requirements. I knew I had read it before somewhere because I was going to use my sim time for my CP too. lol.

 

[MBDiagMan]

Okay, not to hijack the thread, but add into the discussion, what is the typical number of flight hours of instruction before your flying precision is up to the checkride level.

IOW, how many hours after instrument rating and necessary flight time is typically flown with an instructor before being ready for the checkride?

 

[BrianNC]

Okay, not to hijack the thread, but add into the discussion, what is the typical number of flight hours of instruction before your flying precision is up to the checkride level.

IOW, how many hours after instrument rating and necessary flight time is typically flown with an instructor before being ready for the checkride?

I think many do it in 6-8 hours. I saw an ATP video where they allowed the guy 6-7 hours for the instruction. I think @mtuomi here did it in about 6 or 7 I believe.

 

[Axtel4]

Here it is, down at the bottom of all the requirements:

(i)Permitted credit for use of a flight simulator or flight training device.

(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 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; and

Thanks for the research and update. Who needs the Chief Counsel when we have Crowd Sourcing?

 

[MauleSkinner]

Okay, not to hijack the thread, but add into the discussion, what is the typical number of flight hours of instruction before your flying precision is up to the checkride level.

IOW, how many hours after instrument rating and necessary flight time is typically flown with an instructor before being ready for the checkride?

I did mine in 10 hours dual, but I didn't have my instrument yet, and so that included 4 hours of instrument instruction that I needed to qualify for the commercial.

 

[neilw2]

Okay, not to hijack the thread, but add into the discussion, what is the typical number of flight hours of instruction before your flying precision is up to the checkride level.

IOW, how many hours after instrument rating and necessary flight time is typically flown with an instructor before being ready for the checkride?

It took me about 15 hrs dual to checkride. But I was training in 2 airplanes (my 182 and a Arrow). I already had my instrument and a complex checkout. It was harder learning all the maneuvers in both planes. I would think less than 10 hrs if I stuck to 1 plane.

 

[bobmrg]

The November/December 2017 issue of FAA Safety Briefing (dedicated to flight simulation) indicates that new FAA regulations proposed in May 2016 will be published in December 2017. In particular:

“With another new rulemaking effort in the works, expected in December 2017, the FAA proposes to allow pilots to accomplish instrument currency pilot time in a FFS, FTD, or ATD without an instructor present to verify the time, as well as allow ATD time to accomplish instrument currency requirements to be identical to the tasks and requirements described for an aircraft, FFS, or FTD.”

The other big change for many flight schools is allowing TAA to be used for commercial/CFI training in lieu of aircraft with retractable landing gear. The new rules would define TAA as "including a PFD, MFD and an integrated two axis autopilot."

The NPRM includes changes to the loggability of ATD time toward certificates.

(Courtesy of Bruce Williams)

Bob Gardner

 

[neilw2]

The November/December 2017 issue of FAA Safety Briefing (dedicated to flight simulation) indicates that new FAA regulations proposed in May 2016 will be published in December 2017. In particular:

“With another new rulemaking effort in the works, expected in December 2017, the FAA proposes to allow pilots to accomplish instrument currency pilot time in a FFS, FTD, or ATD without an instructor present to verify the time, as well as allow ATD time to accomplish instrument currency requirements to be identical to the tasks and requirements described for an aircraft, FFS, or FTD.”

The other big change for many flight schools is allowing TAA to be used for commercial/CFI training in lieu of aircraft with retractable landing gear. The new rules would define TAA as "including a PFD, MFD and an integrated two axis autopilot."

The NPRM includes changes to the loggability of ATD time toward certificates.

(Courtesy of Bruce Williams)

Bob Gardner

Wow, that is a big change! When you say it will be published in December, does that mean starting sometime in December I will be able to keep current in a sim without an instructor present?

 

[denverpilot]

The November/December 2017 issue of FAA Safety Briefing (dedicated to flight simulation) indicates that new FAA regulations proposed in May 2016 will be published in December 2017. In particular:

“With another new rulemaking effort in the works, expected in December 2017, the FAA proposes to allow pilots to accomplish instrument currency pilot time in a FFS, FTD, or ATD without an instructor present to verify the time, as well as allow ATD time to accomplish instrument currency requirements to be identical to the tasks and requirements described for an aircraft, FFS, or FTD.”

The other big change for many flight schools is allowing TAA to be used for commercial/CFI training in lieu of aircraft with retractable landing gear. The new rules would define TAA as "including a PFD, MFD and an integrated two axis autopilot."

The NPRM includes changes to the loggability of ATD time toward certificates.

(Courtesy of Bruce Williams)

Bob Gardner

Wow, that is a big change! When you say it will be published in December, does that mean starting sometime in December I will be able to keep current in a sim without an instructor present?

I’d hold off on getting too excited until they actually do it. Bruce is hopeful and usually has decent info on these insider things, but with holidays and very little heavy pressure or motivation for them to do this, it could be soon... or it could still be months out. Nobody knows.

 

[bobmrg]

Wow, that is a big change! When you say it will be published in December, does that mean starting sometime in December I will be able to keep current in a sim without an instructor present?

Watch the Federal Register (skip the sports pages and comics) to see what it says about effective date.

Bob

 

[denverpilot]

Watch the Federal Register (skip the sports pages and comics) to see what it says about effective date.

Bob

Or just wait until AOPA gushes over the changes and claims they caused them on social media, if one doesn’t have time to refresh the Federal Register web page all day.

That announcement will come right to your smartphone wherever you are if you follow them, and you don’t even have to be a member!

 

[BrianNC]

So would an ATC 610/710 be an approved simulator for the commercial time that many of us used back in the day to get simulator time for our instrument? According to "...or flight training device that represents that class of airplane or powered-lift category and type, if applicable, appropriate to the rating sought;"?

 

[EricVKX]

So would an ATC 610/710 be an approved simulator for the commercial time that many of us used back in the day to get simulator time for our instrument? According to "...or flight training device that represents that class of airplane or powered-lift category and type, if applicable, appropriate to the rating sought;"?

Don't quote me on it (I don't have the info in front of me,) but as I recall it needs to be an ATD(AATD) and it has to be on the LOA as well.