14 CFR 61.129(a)(3)(ii) lists the aeronautical experience requirements for a commercial certificate. It says:

(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

With the changes to this regulation to allow TAAs, does the FAA allow simulator (FFS) hours in place of the TAA hours?

  • $\begingroup$ This question seems better posed to the FAA, than to random strangers on the Internet who may or may not know what they are talking about... $\endgroup$
    – user
    Dec 8, 2018 at 15:18
  • $\begingroup$ I'm not sure what you're asking, can you expand your question? Are you asking if FFS time can be used in lieu of TAA time for the requirements in (a)(3)(ii)? If you can quote the specific part of the regulation that you're asking about, that would be very helpful. $\endgroup$
    – Pondlife
    Dec 8, 2018 at 15:49
  • $\begingroup$ Yes, that is exactly what I'm asking @Pondlife. Basically the answer if an "airplane" can be considered also Full Flight Simulator (Class D for example) the way I can log landings and approaches to satisfy currency requirements. $\endgroup$
    – PIXP
    Dec 8, 2018 at 15:53
  • $\begingroup$ I'm still confused: 61.129 is about the requirements for a commercial pilot certificate; currency requirements are in 61.57. Are you asking about using a simulator to maintain instrument currency? $\endgroup$
    – Pondlife
    Dec 8, 2018 at 16:00
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    $\begingroup$ Thanks for clarifying your question! I've edited it to match what you just said in the comments; if I got it wrong then of course please roll back or edit further as needed. $\endgroup$
    – Pondlife
    Dec 8, 2018 at 18:29

1 Answer 1


You can't use a simulator for this time because the regulation specifically requires training time in an airplane; there's no mention of using a simulator. If you look at some of the wording in the currency regulations in 61.57 (for example) you can see that when the FAA allows you to use a simulator they state it explicitly:

The takeoffs and landings required by paragraph (a)(1) of this section may be accomplished in a full flight simulator or flight training device that is [...]

A pilot may accomplish the requirements in paragraph (c)(1) of this section in a full flight simulator, flight training device, or aviation training device provided [...]

  • $\begingroup$ It would require a lot of digging to come up with proper citations, but a flight school can contract with a certificated part 142 training center as part of its curriculum. The part 142 school can provide type specific training on a sim. What I'm gathering is that what the op asks can be done through part 142 as long as both training centers have FAA-approved curricula. I can't find anything, though, about training outside an FAA-approved flight school. $\endgroup$
    – TomMcW
    Dec 8, 2018 at 20:18
  • $\begingroup$ @TomMcW I think we have a question or two about sim hours in a part 141 course, but I can't remember any part 142 questions here offhand. It might make a good self-answered question if you can dig up the details :-) $\endgroup$
    – Pondlife
    Dec 8, 2018 at 20:44
  • $\begingroup$ The problem is, part 141 and 142 stuff is all done by the FAA on a case-by-case basis. The curriculum has to be submitted and approved, so each training center would have its own set of rules as to what it can and can't do. FWIW, I'd say that's what part 142 is all about. Certifying sim training centers so that all training facilities don't need to have all types of aircraft. I'd be willing to bet if you contacted a 142 center they would have a way to do what the op is asking, but it may require that they get the rest of their CPL training through a part 141 school. $\endgroup$
    – TomMcW
    Dec 8, 2018 at 21:08
  • $\begingroup$ We operate a Part 142 school with three sims (2 x Level C and one Level D) and we get asked all the time about this. Bottom line is that the sim use has to be spelled out in the regs or be part of an approved Part 142 training program. $\endgroup$
    – Richard
    Jan 9, 2019 at 2:24

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