From MARKBOYD@aol.com Thu Sep 5 09:28:25 2002 Date: Thu, 05 Sep 2002 00:56:47 -0400 From: MARKBOYD@aol.com To: mjboyd@cse.ucsc.edu Subject: Fwd: Re: ATP 1500 hours total time and FTDs Mark, See remarks below: MARKBOYD@aol.com To: K Allan Pinkston/AMC/FAA@FAA 08/28/2002 02:20 cc: mjboyd@cse.ucsc.edu PM Subject: ATP 1500 hours total time and FTDs K.Allan.Pinkston@faa.gov Dear Sir, I want to know to what extent Frasca/PCADT/level "D" sim time can be applied to the part 61.159 ATP requirements. Specifically, I have over 300 hours of time giving or receiving instruction in a Frasca, approved PCATD, or level "D" 737 simulator, and want to know if this can be applied to apply for the ATP requirements. None of this time was under part 142. I believe this is "Pilot time" as defined by 61.1(a)(12). Yes, this is "pilot time." However, that does not necessarily make the time "aeronautical experience" usable to meet the requirements for a certificate or rating per Title 14 CFR part 61. I also have just over 1200 hours of flight time, all of it either as dual given, dual received, or solo. I have no SIC or flight engineer time. I have also met the night, cross-counry, and instrument flight requirements of section 61.159 unambiguously. Does the 300 "Pilot time" plus the 1200 flight time meet the requirement of 61.159(a) of "1,500 hours of total time as a pilot"? Sorry, but no, that doesn't work. Section 61.159(a) requires a total of 1,500 hours total time as a pilot "that includes at least:" And the only application of simulator or flight training device (sim/FTD) time to the requirement is found in 61.159(a)(3) and (a)(5). Under these provisions the sim/FTD time may be used as though it was actual pilot flight time even though this "pilot time" can not be logged as flight time. You could have used 25 hours to meet the 75 hour instrument time requirement of 61.159(3), but you say you already meet the instrument time in actual flight so you don't need and therefore can not even use 25 hours of your sim/FTD time to meet the 1,500 hour requirement. Specifically, does the 100 hour limitation of section 61.159(a)(5) apply only to part 142 sim/FTD time, or was the intent to limit sim/FTD time in general? The 100 hours allowed per 61.159(a)(5) applies only to persons being prepared in Training Center (part 142) approved courses. Actually they are able to credit a total of 150 hours of simulator time as though it were flight time [this 100 hours plus the 50 per 61.159(a)(3)(ii)] toward the 1,500 hours. This is a benefit (selling point) for someone like you who may want a type rating, etc., and already has 1,400+ flight hours when entering the course [or 1,350+ if they do not have more than 25 hours instrument time]. Many can not apply the 100 hours if they already have, or nearly have, the 1,500 hours in flight. And, like you, they may not be able to even use any (or all) of the 50 hours toward the instrument time requirement. Incidentally, as a reminder, per Advisory Circular 61-126, paragraph 5. b. training acquired and properly logged using a PCATD is only usable toward the instruction required for the instrument rating per 61.65, and for only 10 hours of that requirement. It can not apply to commercial or ATP requirements or currency. There is no restriction on how much of any sim/FTD or PCATD time may be logged by any pilot as simulated instrument instruction received or given. All such instruction is valuable and no one should be discouraged in using these devices. The sim/FTD time may be used toward 61.57(c) currency. But, the sim/FTD & PCATD time can not properly be logged as flight time and only limited amounts may be used toward certificate or rating requirements as discussed. I'm asking because I intend to take the ATP flight test soon and wish to avoid any embarrassment with the designee. I suspect you may have to delay your practical test, then. I realize my answers are not what you wanted, but I hope I have helped. Allan Pinkston, AFS-640 Phone (405) 954-6472 Sincerely, Mark J. Boyd 602 Chestnut #1 Santa Cruz, CA 95060 (831) 425-2693 markboyd@aol.com