Flight Time: The Flight Simulator Controversy

When can a simulator replace an airplane and is simulator time logged the same way as flight time? Many questions come up about the use of flight simulators and how this time should be used. Here are some answers…

TERMINOLOGY: The Airplane Simulator
First, it is important to get the words right. According to FAA Advisory Circular 120-45A, an ‘Airplane Simulator is a full size replica of a specific type or make, model and series airplane cockpit, including assemblages of equipment and programs necessary. The device must simulate the airplane in ground and flight operations, a force cueing system which provides cues at least equivalent to that of three degrees of freedom motion system.’ This definition describes a machine that would start at $25 million.

Translation: Most flight schools do not have anything like this.

Full-Motion Flight Simulators are usually found in military and major airline training facilities. These simulators are boxed-in cockpits that stand high above the floor on hydraulic legs. The entire box can pitch, roll and yaw in response to the pilots control inputs and simulated weather conditions. These are well outside the price range of General Aviation.

TERMINOLOGY: The Airplane Training Device
Advisory Circular 120-45A offers another definition. ‘An Airplane Training Device is a full scale replica of an airplane’s instruments, equipment, panels, and controls in an open flight deck or an enclosed airplane cockpit, including assemblage of equipment and programs necessary to represent the airplane in ground and flight conditions to the extent of the systems installed in the device; does not require a force (motion) cueing or visual system.’ This means that training devices do not move and are generic; they do not need to be an exact replica of a particular airplane.

Translation: Based on these definitions most flight students use Training Devices not Flight Simulators.

Can any airplane simulator or training device time be used as flight time? The answer is definitely — no.

FAR Part 1.1 defines flight time as, ‘the time from the moment the aircraft first moves under its own power for the purpose of flight until the moment it comes to rest at the next point of landing.’ Therefore actual flight time can only be recorded if it takes place in an aircraft that moves. Part 1.1 further defines an aircraft as, ‘a device that is used or intended to be used for flight in the air.’

Translation: A flight simulator/training device cannot move under its own power with the intention of flight — nor can it be used for flight in the air — therefore, it can not be used to log flight time.

There are still some instructors and even examiners who count simulator time as flight time. Where does the confusion come from? FAR 61.65 (e) details the flight experience needed to qualify for the Instrument Rating. The regulation says that the applicant must have had 40 hours of actual or simulated ‘instrument time.’ Important: It does not say ‘flight time.’

Of these 40 hours:

  • 20 hours can be in an approved instrument ground trainer (airplane training device) as long as this instruction is provided by an authorized instructor.
  • 15 hours of the 40 must be ‘flight‘ instruction with an Instrument Flight Instructor (CFII).

Translation: The applicant therefore must have 20 hours in an aircraft, and can have up to 20 hours in the ground trainer — this time can not be logged as flight time. The 20 flight hours must all be with an instructor, and 15 of those 20 hours with a CFII.

MORE REGS, MORE CONFUSION… Commercial Training
FAR 61.129 deals with the requirements for a Commercial Pilot Certificate and Section (a) of this regulation requires, ‘at least 250 hours of flight time as pilot.’ This rules out the use of simulators/devices … but wait … section (i) brings simulators back in. Section (i)(1)(i) says that a maximum of 50 hours credit can be awarded for simulator/devise time toward the 250 hours flight time requirement.

Translation: In practice this regulation allows for 50 hours of simulator time in lieu of 50 hours flight time. Therefore an applicant can legally go to the Commercial checkride with 200 hours of flight time and 50 hours ground trainer time.

Flight simulator/ground trainer time is logged under the column in most logbooks listing titled ‘Training Device‘ or ‘Simulator.’ It also can be counted under ‘Instruction‘ or ‘Dual Received‘ for the purpose of proving an applicant has had the allowed 20 hours toward an instrument rating or to prove they are current for flight under IFR.

Simulator/Ground trainer time can NEVER be logged under ‘Total Duration of Flight‘ or ‘Flight Time.’

Translation: When you log simulator/ground trainer time, those columns are left blank.

A ground or flight instructor must sign off all simulator/training device time. FAR 61.189 requires the instructor to certify the time spent in a ground trainer by signing his name and giving his certificate number. There is no such thing as ‘solo simulator.’ If you operate a simulator/ground trainer alone the time spent cannot be used toward an instrument rating or to maintain instrument currency.

Translation: Home computer programs that portray ‘Flight Simulation‘ (even with rudder petals and joystick) cannot be used for instrument currency or to meet certification requirements.

BOTTOM LINE: If you have been logging simulator/ground trainer time as flight time and that time is now included in what you are calling your ‘total time,’ your logbook is in error. Double check your logbooks and subtract any false total time. Do not let the FAA or a job interviewer spot this problem before you do!