Reviewing 61.159(a)(6), it mentions that an applicant cannot credit more than 100 hours in simulator towards their total aeronautical experience as long as it was conducted as part of a 141, 142, 121, 135, etc. course. I have 33.3 hours (dual received under part 141) of time I logged while a student at a 141 school. I also instruct at a Part 141 school and have 45 hours (dual given under part 141).

Can I use all this time - received plus given - towards my total aeronautical experience for ATP?

All the sims have current LOAs and are maintained by a very big sim department at my 141 School.

  • 1
    $\begingroup$ Just to clarify, you've given 45 hours of dual as an instructor in an AATD/FTD at a part 141 school. You're asking if those 45 hours of dual given in a sim count towards the sim time allowed for an ATP candidate. Is that correct? $\endgroup$
    – Pondlife
    Feb 24, 2022 at 16:14

3 Answers 3


Since FAR 61.159 (a) requires 1500 hours total time as a pilot, it's my opinion that the 33.3 hours of "dual received" time, in a properly qualified and FAA approved AATD/FTD, that you received in your training (conducted under an FAR Part 141 approved training course and provided the device represents an airplane) would count towards the required 1500 hours of total time.

Also, in my opinion, the 45 hours that you were in the AATD/FTD giving instruction would not count toward the 1500 hours of total time as a pilot. While giving instruction as a CFI, FAR 61.51 (e)(3) allows you to log PIC time (which is pilot time). But you need to be in an "aircraft" and it must be "flight time," criteria that are not satisfied in an AATD/FTD.

(I would also recommend that you visit your local FSDO or ATP Designated Examiner to ensure that they would recognize the total time in the same manner as I have expressed in my answer.)

14 CFR 61.159: Airplane category rating for an ATP (pertinent part)

§ 61.159 Aeronautical experience: Airplane category rating.

(a) Except as provided in paragraphs (b), (c), and (d) of this section, a person who is applying for an airline transport pilot certificate with an airplane category and class rating must have at least 1,500 hours of total time as a pilot that includes at least:

(6) Not more than 100 hours of the total aeronautical experience requirements 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.

61.51 Pilot logbooks (pertinent part)

§ 61.51 Pilot logbooks.

(e) Logging pilot-in-command flight time.

(3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

  • $\begingroup$ I like this answer. I am, however, in disagreement about the dual given not counting. Pilot Time is defined in 61.1 as (1) required crewmember, (2) receiving instruction, (3) providing instruction, or (4) SIC under 135.99. I would allow that time if the applicant could explain why, it should be counted. $\endgroup$
    – wbeard52
    Feb 23, 2022 at 23:25
  • $\begingroup$ @wbeard: as I see it, pilot time acquired while giving instruction as a CFI in a simulator would not qualify because 61.51 (e) (3) requires the CFI to be instructing in an "aircraft." FAR Part 1.1 defines aircraft as "...a device that is used or intended to be used for flight in the air." I don't believe an AATD/FTD qualifies as an aircraft. Also 61.51 (e)(3) requires the CFI time to be "flight time." See FAR 1.1 on the definition of "flight time." $\endgroup$
    – user22445
    Feb 24, 2022 at 0:03
  • $\begingroup$ I agree with you. Sims, etc. are not aircraft. I think we disagree on this point. We aren't talking about logging PIC time to get to 1500 hours. The instructor can't do that per 61.51. He can use that aeronautical experience though to count towards the 1500 hours pilot time which is different than logging PIC time. It is interesting because the ATP is the only certificate that uses the wording pilot time. All the other aeronautical experience certificates specify in an aircraft or total flight time. $\endgroup$
    – wbeard52
    Feb 24, 2022 at 0:07
  • $\begingroup$ @wbeard: but is there a regulation supporting your point? $\endgroup$
    – user22445
    Feb 24, 2022 at 0:10
  • $\begingroup$ I don't understand your question. I am quoting the regulations. What part is confusing that pilot time is not the same as logging PIC time? I've quoted 1.1 for definition of pilot time and you quoted the definition of PIC time. How do you rectify the use of the term pilot time in 61.159(a) and the use of PIC flight time in 61.159(a)(5)? Also see 61.159(c)(4) for the term pilot time again. Obviously, a SIC in this situation isn't logging PIC time but they can use that experience towards the 1,500 hour pilot time requiremement $\endgroup$
    – wbeard52
    Feb 24, 2022 at 2:43

You would have to check with your school to see what parts of your "aeronautical experience as part of an approved training course" counts towards your experience. 141 flight schools with have differences in their flight training courses, so someone who is more familiar with your school's 141 course will be able to give you a better answer on this.


It would all depend on the school you were to pursue an ATP through. For a Part 61 program, you can only use a maximum of 50 sim or FTD hours toward an ATP per §61.159(4)(ii). For a part 141 school it may be different depending on the approved curriculum.

  • $\begingroup$ Part 121 Airline is the next stop $\endgroup$ Feb 23, 2022 at 20:33

You must log in to answer this question.

Not the answer you're looking for? Browse other questions tagged .