I’m 55 yrs. old, approaching 1500 hrs. of total time (current total time is 1479 hrs.) My desire is to start a second career as an airline pilot after spending 30 years in airline Leadership.
I graduated from Ohio State University in 1991 - BA in Aviation, specializing in aircraft systems. I earned my commercial single & multi engine land instrument airplane certificate while at OSU. I’m aware I don’t qualify for the R-ATP because OSU wasn’t awarded the LOA until October 2013. That said, I’ve always been under the impression that a Part 141 flight school (OSU) flight simulator hours count towards total time.
My summary - 1405 flight hrs. + 74 sim hrs. = 1479 total time.
Do the 74 hrs. of sim time count towards the 1500 hrs. ATP total time requirement? I believe they do, because I’ve been granted all my certificates and ratings based on those sim hrs. Thoughts?
(4) 75 hours of instrument flight time, in actual or simulated instrument conditions, subject to the following:
(i) Except as provided in paragraph (a)(4)(ii) of this section, an applicant may not receive credit for more than a total of 25 hours of simulated instrument time in a full flight simulator or flight training device.
(ii) A maximum of 50 hours of training in a full flight simulator or flight training device may be credited toward the instrument flight time requirements of paragraph (a)(4) of this section if the training was accomplished in a course conducted by a training center certificated under part 142 of this chapter.
I’m still confused based on the below text from ATP:
According to the Federal Aviation Administration (FAA), a maximum of 25 hours of training in a full flight simulator representing the class of airplane for the rating sought may be credited toward the flight time requirement of 1500 hours total time as a pilot.
You can get up to 100 hours in an airplane full flight simulator or flight training device, if it was flown during an approved training course at a part 121, 135, 141, or 142 school.
You can get hired with 1475 hrs and use 25 hours from your sim/training to count towards your total time. [At ATP you will have about 200hrs of flight time and 50hrs of simulator time (50hrs of Sim can be used towards commercial requirements)
Be careful here because there is a difference in the simulators that can be used for time. It is different for a commercial certificate vs an ATP certificate. For a commercial certificate you can use up to 50 hours of simulator (FTD or AATD) time towards your 250 hours, which is what you would do as a student at ATP flight school (and sounds like what you did). Some simulator time can be used towards your ATP certificate. However, the simulator time that can be used is level D simulator, or “full flight simulator” time, providing it was part of an approved course. Generally this means that you can use some of the full motion sim time from your ATP-CTP course and your type rating training to cover some of the requirements, as discussed in the following:
14 CFR 61.159 (a)(3):
50 hours of flight time in the class of airplane for the rating sought. A maximum of 25 hours of training in a full flight simulator representing the class of airplane for the rating sought may be credited toward the flight time requirement of this paragraph if the training was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter. A flight training device or aviation training device may not be used to satisfy this requirement.
So you can credit 25 hours of the required 50 hours of required multi time, providing you completed it in an approved simulator and training course. This is why some airlines only require 25 hours of multi time at the time of hire, because your training will credit the rest.
To keep it simple, unless you have full motion sim time in a multi-engine airplane simulator, you cannot use that sim time towards the ATP cert.
The key sentence is “if the training was accomplished as part of an approved training course in parts 121, 135, 141, or 142”.
With that in mind you still need your ATP and that training will be part of your newhire training at a Regional, so I’d be reaching out to the airlines of your choice NOW, since you’re 121 sim training would count and you might not need the full 1500. Make sense?
I have 1405 flight time hrs - I would need an additional 70 flight hours to reach 1475. Upon reaching 1475, a regional airline would then get me to 1500 by way of 25 hrs in a full flight simulator?
I do understand as part of this equation is the ATP-CPT class that will provide some full flight simulator hrs. So maybe I don’t need 1475, but 1470 hrs before an airline will consider me ??
It depends on the airline and what actual flight time you currently have (total, instrument, XC, night, multi). I think Envoy allowed us to start training at 1460 total time and at least 25 hours of multi time. Most, as you mentioned, require 1475 and you will get the rest through CTP and their training. The simulator time can be confusing, so I just got the full 1500 before I started to be certain I was eligible. But most of my classmates used the simulator time from training.
It looks like you are in pretty good shape! I’d work to get to 1475 of total flight time (not including your sim time) and you should be good for a regional interview. Be certain that the SIC time you have logged is legal time because there has been some trouble with that in the past. Just curious, since you have multi-turbine time, what type of simulator time do you have?
Other hour exceptions are made to the ATP requirements for the restricted ATP. Here is a list of the other exceptions:
Total time:
100 hours of your total flight time requirement can be performed in a flight simulator or flight training device if the hours are flown as part of an approved training course at a Part 121, 135, 141, 142 flight school.
Each landing above 20 night landings counts as an hour of night flight time, up to a maximum of 25 hours.
25 hours of the 50 hours multi-engine flying time required can be performed in a full flight simulator as long as it is included in an approved the flight training program
25 of the 75 hours of instrument flight time can also be performed in a flight simulator or flight training device
Anyone in my position would feel frustrated if they attended a 4 yr university prior to 2014, completing the exact same Curriculum as they do today, only to find out that it’s not good enough for the Feds. Please!! Yes, I’m looking for loopholes because all of sudden my education dating back to the late 80s is not good enough.
With all due respect you graduated in '91. It was you who decided to wait over 20yrs to fly and now you’re frustrated because you don’t qualify for a loophole that wasn’t even anticipated at a time long before the 1500hr Rule? Should ALL the pilots now be frustrated because they need 1500hrs, when for decades you only needed your CPL to fly for an airline?
My degree from a 4 year university - Part 141 flight school is now worthless ($100k gone) according to the Feds. The college courses offered today at OSU are exactly what I completed years ago but for some reason the Feds deem them unacceptable for RATP. I don’t qualify for the 1000hrs and apparently I don’t qualify for the 1250 hrs - that in it self doesn’t make sense.
Yes, I’m looking for any Loopholes. I think you would too!
Speaking of loopholes, I’m curious about the language below - it’s appears the OSU FTDs I used were covered under this provision. Referencing back to my original question - do the sim hours I accumulated at OSU count towards total time? Help me understand why or why not.
TITLE: Qualification and approval of flight simulators and flight training devices.
SECTION RULE: (a) Except as specified in paragraph (b) or (c) of this section, each flight simulator and flight training device used for training, and for which an airman is to receive credit to satisfy any training, testing, or checking requirement under this chapter, must be qualified and approved by the Administrator for–
The training, testing, and checking for which it is used;
Each particular maneuver, procedure, or crewmember function performed; and
The representation of the specific category and class of aircraft, type of aircraft, particular variation within the type of aircraft, or set of aircraft for certain flight training devices.
Any device used for flight training, testing, or checking that has been determined to be acceptable to or approved by the Administrator prior to August 1, 1996, which can be shown to function as originally designed, is considered to be a flight training device, provided it is used for the same purposes for which it was originally accepted or approved and only to the extent of such acceptance or approval.
The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.
We can go back and forth as much as we want with regulations, advisory circulars, interpretations, etc… The only way you will know if the time counts is if you contact OSU for their letter of authorization for the simulator and then contact your local FSDO. They would be able to interpret whether or not the sim time is counted towards the ATP certificate. You could even call up some hiring departments at airlines and see what they think. I can only help you with what I find in FAA material, but as with many things in aviation, some of these items are up for interpretation. However, I can 100% guarantee you that if you plan on using any simulator time that wasn’t done in a part 121 training program or during your ATP-CTP course, an airline is going to want to see all of the proof and authorization for you to use that time. A letter of authorization for your sim should have been issued by the FAA explicitly saying how and what time can be logged using it. As for your degree, it was completed 30 years ago and the FAA has certainly revised its requirements and monitoring for part 141 schools several times over. It does not surprise me that you would no longer qualify for a reduction of hours.
I wish I had a definitive answer for you, but only the FAA can say ‘yes it counts’ or ‘no it doesn’t’. There are several classifications of sims, and you would need to figure out which one you used.
As the others have said, sure it might seem beneficial to fight to use this sim time, but personally I would rent a plane for 70 hours and get IFR proficient. I think that would solve your problems and get you prepared for interviews and new hire training.
I’m trying different avenues to get clarity before flying the additional 70 hrs. The suggestions you made about reaching out to the FAA, airlines and school have been made three months ago - with no responses.
You are correct, everything can be subject to interpretation. That’s why I’m looking for consistency in responses before making any financial decisions.
Concerning the LOA, it would appear to me, based on reg 61.4 - initial effective date 1978, the language in paragraph (b) indicates the following:
“(b) Any device used for flight training, testing, or checking that has been determined to be acceptable to or approved by the Administrator prior to August 1, 1996, which can be shown to function as originally designed, is considered to be a flight training device, provided it is used for the same purposes for which it was originally accepted or approved and only to the extent of such acceptance or approval.”
My interpretation - all my sim time from OSU would qualify - grandfathered. No mention of needing a LOA. Yes, there’s a LOA rule now but back then, maybe there wasn’t? That’s the info I’m seeking. I’m gathering as much feedback as possible so I create a solid “flight plan.” I’m just doing my due diligence.
It is unfortunate that your education doesn’t qualify for the current R-ATP. However, the time you spend fighting would be better used in flying those remaining 70 hours. Plus the currency and proficiency you gain will help better prepare you for airline training to come.
I completely agree with you. It’s unfortunate my degree means very little at this point. I get it…things change. Perfect example - In the past, I couldn’t get a first class medical but with advancements in medicine and technology, I’m now able to get the first class medical. This is one of the reasons why I haven’t flown as a commercial pilot for years. Now I have my chance.
I’ve flown 70 hrs in the past 3 months and will continue to do so. My skills are redeveloping and it feels good. As you can imagine, costs are a big consideration - therefore, it’s important for me to get a correct interpretation of my situation.
Regardless of how the FAA interprets your situation, the vast majority of airlines will not look at simulator time as flight time, I have never heard of one that does, regardless of the level of simulator.
I cannot believe that you logged 74 sim hours, nobody I know logs sim time beyond that which is allowed for the Instrument and Commercial license. And even that the vast majority of pilots do not attempt to count sim time as part of their total flight time.
I suggest you let this 74 hours of simulator time go. If I were on a hiring board, I would be a firm “no” on you based solely on your attempt to try and count sim time as flight time.