Logging sim time towards ATP
 

(6) Not more than 100 hours of the total aeronautical experiencerequirements of paragraph (a) of this section or § 61.160 may be obtained in a full flight simulator or flight training device provided the device represents an airplane and the aeronautical experience was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter.

Looking at 61.159 for the ATP it appears that you can count up to 100 hours in an approved sim towards your total time for ATP. So as an instructor in the sim giving the 141 instruction can we count this towards our total time as well?

In the sim you are providing dual only and not able to log sim time for any kind of currency or for any rating. Basically as an instructor the only benefit of logging may be that you can use the time towards being a DPE at some point. Keep in mind, one of the advisory circulars says the instructor should log the time as dual given when. Using FTDs.

Dual given only, nothing goes in total time. There are very few sims in the 141 world that are even approved. There even fewer airlines willing to accept those sims for experience credit to your total time. It’s not worth postponing your airline career because the company can’t be convince the time is legal.

Awesome think you. That was what my understanding was but we got in a debate about it.

Those guys are right on. About the only sim you'd be allowed to apply towards an ATP might be a few hours of level D sim during airline new-hire training. I'm aware of at least some regionals allowing you to start training with 1475 TT / 25 ME, since you get the last 25 in their sim before the checkride.

Dual given in an FTD or ATD is “ground instruction”.
If memory serves me right you don’t even need a CFI only a Ground Instructor certificate.
I could be wrong as it’s been a while.

* and I was wrong.
FAA council ruling:

https://files.redbirdflight.net/hubf...rpretation.pdf

We always used CFII's for any loggable FTD/ATD training. Looks the FAA made it official.

Most schools that I've seen own Frasca, Redbird, or FlyThisSim devices. All of which are certified for 141 use by the manufacturer. Individual schools can elect to make them into FTD level [X] if they want to go through that process. However what you'll usually find is the same letter of authorization hanging on the wall near a sim and it's the same exact letter that is found at another school.

Pay attention to some exceptions here, including the definition of approved course. You need 50 hours multiengine time for a multiengine ATP, only 25 of which may come from a simulator used in an approved course. 75 hours of instrument time, 25 max from any approved FTD and 50 max from 142 only. As others have mentioned the 'approved program' doesn't have to accept the hours so if you plan to push the absolute minimums pay a DE for your ATP so where ever you are applying doesn't have to scour your logbook.

​​​​​​My humble opinion is hiring will be subdued long enough you will have far more than the minimums before any job that requires an ATP will hire you but if you can slip through the cracks, more power to you.

Yes, and none of those devices meet the definition or requirements to log them as flight time for the aeronautical experience requirements for an ATP certificate.

Actually that's not true. You're confusing different parts of the ATP reg.

61.159(a)(3) allows 25 hours towards the category+class requirements in a full-flight sim. FTD no bueno there.

61.159(a)(4)(i) allows 25 hours towards the instrument requirements in a full-flight sim or FTD. I doubt this comes up often, most folks get the instrument in actual or hood during training or time-building. But if necessary (and the airline's mins allowed it) you could use FTD time or the new-hire sim time.

Well yes, definitely not total flight time, but you can credit up to 100hrs of this time towards ATP if it was done through 141 training.

FTD/ATD and ATP cross country 50 miles point to point time, is very sticky. Yes it’s legal, and it meets the requirements per the FAR. But, I’ve heard of more and more companies not accepting it for their requirements, and be careful as well. I know a few people
who went to INDOC using those times because the recruiters signed off on it, only to be sent home by training when they got there.

Rick - you are the one confused. He wants to use dual given in an FTD for TT towards an ATP. The answer is a hard “no”.

I agree that's not a good idea.

But your statement was categorical and thus not quite correct. Sim (and FTD) can be used for certain specific ATP aeronautical experience requirements, including Cat/Class (25 hours sim), Instrument (25 hours sim/FTD). Additionally 61.159(a)(6) allows up to 100 hours of sim/FTD towards the "total" requirements of 61.159(a).


Also, this an important distinction which frequently confuses people:

Sim (or FTD) time is NEVER under ANY circumstances "Flight Time". Never, ever.

Far 1.1 defines "Flight Time" as time in a airplane moving under it's own power for the purpose of flight.

Where the FAR's allow the SUBSTITUTION of sim/FTD time for Flight Time experience, that does NOT mean you can log sim/FTD as flight time... it ONLY means that you can substitute that time in LIEU OF the specified Flight Time. So if you're using the 25 hour sim allowance for ME, you would go to the checkride with 25 hours of AMEL Flight Time logged plus 25 hours of AMEL sim logged in your book and on the 8710.

To make it even more confusing... there is a definition of "Pilot Time" in 61.1 which includes sim/FTD time and ALSO dual given in a sim/FTD.

Further point of confusion: There is no FAR definition of "Total Time". Left undefined, you might make a case that "Pilot Time" can be counted as "Total Time". Now to really blow your mind: Pilot Time includes sim dual given! So now we're back to where we started, and maybe you can make a case that sim dual given, while not specifically allowed, is also not specifically prohibited towards the ATP TT requirement. But I personally would not try it because it would confuse employers and examiners. Maybe there's an FAA legal interp. on that.

For most pilots, what we log as "Total Time" is really "Flight Time". Best to keep any "Pilot Time" in separate columns. Most employers don't want non-airplane time mixed up in your total time.

This aspect of the regs is a poop-show, and I'm sorry for subjecting you to it. I'll buy you a beer if we ever meet.

This is exactly what I’m talking about. It is like there isn’t a set defined rule against it but also not a clear cut rule for it. It is a lot like the rule where you can use night landings towards night flight time but you don’t log the time as you would if it were in flight but you just count the landings in lieu of.

It's fun to discuss the nuances of the regulatory language.

But the real-world right answer is pretty easy: employers do not expect to see sim dual given towards ATP mins.

Sounds right. Kind of like how you can log night landings towards the night hour requirement for ATP, but can't log additional night hours just because you did some night landings.

Yup, that's it.

More than a few people screw that up, which can result in a rescheduled checkride so they can fix their logs.