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2 Answers

Flight simulator time for commercial requirements

Asked by: 946 views Commercial Pilot, FAA Regulations

I know 61.129 (I)(I) allows me to use so many hours on a training devices towards my rating. Is this total time or can I use the simulator for my 10 hours of complex/TAA time that I need for commercial?

2 Answers



  1. Kris Kortokrax on Feb 10, 2023

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

    It contains the following two statements:

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

    “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.”

    Any uses allowed for the device will be outlined in the Letter of Authorization (LOA), which is required to be posted near the device. It likely would not be allowed because flight training is required for the complex endorsement and 61.1 defines “flight training” as time acquired during flight. While you can log instruction received in an FSTD, it would not be flight training.

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  2. Mark Kolber on Feb 11, 2023

    The one area in the excerpt Kris mention I would watch out for is “total time.” While total “pilot” time includes device time, total “flight” time does not (both are defined in the FAR). Like simulated instrument, it may be more about bookkeeping than regulation. Either can be justified in the regs but they will need to be separated for applications and checkrides, so be consistent.

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