How much simulator time can I use towards a part 61 instrument rating?

Question

I am doing Instrument Rating under part 61 with a CFII.

1. To meet the 50 hours cross country requirement (d 1), can I log some of the PIC time in a simulator?
2. There is a 20 hours limitation on the use of simulator (h 2). So, if I have 40 hours of simulator time and 15 of them are cross country, can I use those 15 hours towards the cross county requirement and the other 5 hours towards the 40 hours requirement (d 2)?

(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:

(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country flight time as pilot in command, of which 10 hours must have been in an airplane; and

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

(i) Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test; and

(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves—

(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.

(h) Use of full flight simulators or flight training devices. If the instrument time was provided by an authorized instructor in a full flight simulator or flight training device—

(1) A maximum of 30 hours may be performed in that full flight simulator or flight training device if the instrument time was completed in accordance with part 142 of this chapter; or

(2) A maximum of 20 hours may be performed in that full flight simulator or flight training device if the instrument time was not completed in accordance with part 142 of this chapter.

Answer 1

The simulator doesn’t meet the definition of aircraft.

§61.1 Applicability and definitions.

Cross-country time means—

(i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight—

(A) Conducted by a person who holds a pilot certificate;

(B) Conducted in an aircraft;

(C) That includes a landing at a point other than the point of departure; and

(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under §61.101 (c), time acquired during a flight—

(A) Conducted in an appropriate aircraft;

(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and

(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.