Confirming two things about instrument requirements

Kevin.Held

Kevin.Held

Well-Known Member
I'm looking at the instrument requirements and just wanted to confirm a few things.

First of all, I have 3.7 hours in an approved FTD from my private training, but my instructor did not have his CFII at the time. Can i use this time toward the 40 hour requirement? 61.65(e) says up to 20 hours "with an authorized instructor".

Also, I've heard both sides. Is it true that as a PPL, one can log instrument instruction as PIC seeing as how he/she is "the sole manipulator of the controls of an aircraft for which the pilot is rated or has privilages"?

Thanks a lot for your help
 
If you are appropriately rated in category and class you can log the time as PIC.

Now, as far as that 3.7 in an FTD with a non-II instructor, during your PPL training. . .I'm not really too sure on the correct answer for that one.

How are the rest of your instrument requirements? Have th XC? Have the 40 hours?

Do you need this 3.7 to count so you can cut your training short and get on off to a checkride? Are you ready for the checkride? How much time do you have from an II?
 
Kevin.Held said:
First of all, I have 3.7 hours in an approved FTD from my private training, but my instructor did not have his CFII at the time. Can i use this time toward the 40 hour requirement? 61.65(e) says up to 20 hours "with an authorized instructor".
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No. All training, airplane or FTD, that you use to count toward instrument rating requirements need to be with a CFII (or instrument ground instructor in the case of sim or FTD time)

Also, I've heard both sides. Is it true that as a PPL, one can log instrument instruction as PIC seeing as how he/she is "the sole manipulator of the controls of an aircraft for which the pilot is rated or has privilages"?
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Yes. Despite the "both sides" you hear, there is only one correct side - the answer the FAA has been giving for more than 25 years.
 
Ok, thank you for the responses.

I probably should have prefaced the question by telling you that I'm shopping for a place to do instrument through commercial and trying to make up my budget. I'm not actually planning on needing that 3.7 hours but I was more curious than anything else when I read the reg.

MidlifeFlyer said:
No. All training, airplane or FTD, that you use to count toward instrument rating requirements need to be with a CFII (or instrument ground instructor in the case of sim or FTD time)
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I understand the training does not count, but what about the 40 hours of simulated/actual instrument time. If I can go under the hood with a safety pilot, it just seems strange that sim time with a CFI wouldn't count (as long as its an approved FTD).

On a side note, I know the requirement for instrument instruction is 15 hours, but would it be reasonable to think I can get it done in 30 with a good instructor?
 
Kevin.Held said:
On a side note, I know the requirement for instrument instruction is 15 hours, but would it be reasonable to think I can get it done in 30 with a good instructor?
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What instrument instruction for 15 hours are you referring to? Are you talking about the requirements for an instrument rating? i.e. 35 hours 141, 40 hours 91?

And referring to the good instructor... how good the instructor is depends on how well you understand him/her or how well you two get along. It all depends on the student. I had two students start at the exact same time, they both have 33 hours in a 141 program. One is just about ready for the check ride and the other is almost to his cross-countries. Now, I may not be the greatest instructor in the world, but two students with the same hours are not always at the same point. It all depends on you.
 
Maybe I'm misinterpreting the reg. 61.65 requires a total of 40 hours of actual or simulated instrument time to include 15 hours of instrument flight training, 3 hours of prep for the checkride and an IFR xc of greater than 250nm with three different types of approaches.

The way I understand it, you can technically recieve 15 hours dual (which includes the 3 hours prep and the xc) and get an additional 25 hours under the hood with a safety pilot and have met the aeronautical experience requirements. I don't, however, think this is feasible or prudent. Am I wrong about this?

I realize that having a "good instructor" is relative so I guess I'll find out how many hours it will take me. Thanks again for your replies.
 
Kevin.Held said:
Maybe I'm misinterpreting the reg. 61.65 requires a total of 40 hours of actual or simulated instrument time to include 15 hours of instrument flight training, 3 hours of prep for the checkride and an IFR xc of greater than 250nm with three different types of approaches.

The way I understand it, you can technically recieve 15 hours dual (which includes the 3 hours prep and the xc) and get an additional 25 hours under the hood with a safety pilot and have met the aeronautical experience requirements. I don't, however, think this is feasible or prudent. Am I wrong about this?

I realize that having a "good instructor" is relative so I guess I'll find out how many hours it will take me. Thanks again for your replies.
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Correct 61.65 requires only 15 hours with a CFII, all the other sim instrument time can be with a safety pilot. Though I highly recommend flying with an instructor BEFORE flying with a safety pilot. I have had to spend a lot of time getting students to unlearn bad habits they picked up from a buddy. It actually took one guy a whole lot longer to get his IR because of that.

Fly with the instructor, learn the right way to scan, then go practice it. If I have a student that is just getting it, I will send him to get the required time with a safety pilot and save him some cash. Guys that aren't getting it, it can sometimes take all 40 hours and more with me to get them proficient.
 
Kevin.Held said:
I understand the training does not count, but what about the 40 hours of simulated/actual instrument time. If I can go under the hood with a safety pilot, it just seems strange that sim time with a CFI wouldn't count (as long as its an approved FTD).
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Seems reasonable to me, but it is only 3.7 hours.
 
Kevin.Held said:
I understand the training does not count, but what about the 40 hours of simulated/actual instrument time. If I can go under the hood with a safety pilot, it just seems strange that sim time with a CFI wouldn't count (as long as its an approved FTD).
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I have never seen an official answer to whether FTD time done with a single-I under 61.109(k), so this is strictly my opinion and worth what you paid for it:

No, it doesn't even count toward the instrument time that does not need to be with a CFII. I say that because,

(a) from what I have seen, generally, in order to count as instrument time, sim/FTD time needs to be done with a CFII (or instrument ground instructor); and

(b) the use of sim/FTD time toward the private is under 61.109(k) which uses the language "may be credited toward" flight training requirements. That type of language appears in other regs and is, to me a a phrase that roughly translates into, "we know that under normal circumstances, this type of activity doesn't count for anything, but we will let you count it only for this limited purpose."

Safety pilot time is something completely different and I agree with bdhill's suggesting that it be done after you have been trained to know what you are doing. My own view is that being under the hood with a safety pilot is instrument training's version of solo and should only be done as a part of the training program.
 
MidlifeFlyer said:
(a) from what I have seen, generally, in order to count as instrument time, sim/FTD time needs to be done with a CFII (or instrument ground instructor); and
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That is correct. I cannot currently quote the reg, but at our 141 school, it is enforced that if ANY training is done in our Frasca 142 FTD that you want in your logbook, it HAS to be logged with a CFII. And as a side note, you can only log simulator time, ground training/flight training. NOTHING ELSE! No SEL/MEL, no simulated inst, no pic, no landings, and no TT! The advantage of a FTD is for Instrument lessons, a few private lessons, extra practice and also currency for instrument. At our school, CFIs can use the FTD for free, so I go in there and practice ME procedures, and also, like recently, I just got instrument current.

As for the no simulated instrument time, we had this controversy for a while. We finally got an answer from our FSDO and they said no Sim inst.
 
JulietBravo said:
As for the no simulated instrument time, we had this controversy for a while. We finally got an answer from our FSDO and they said no Sim inst.
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Did you reference 61.51(a)(3)(iii)? i am curious as to what they said about it.
(3) Conditions of flight--
(i) Day or night.
(ii) Actual instrument.
(iii) Simulated instrument conditions in flight, a flight simulator, or a flight training device.
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and also, 61.51(g)(4)

A flight simulator or flight training device may be used by a person to log instrument flight time, provided an authorized instructor is present during the simulated flight.
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mojo6911 said:
Did you reference 61.51(a)(3)(iii)? i am curious as to what they said about it.


and also, 61.51(g)(4)
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FSDOs are notorious for making up their own rules, despite what the regs say.

Whether or not to log sim training in the simulated instrument column or not is more of a bookkeeping question than a reg one - do you want to have to subtract all the entries when filling out an 8710 or anything else asking for your instrument =flight= time (sim time is never "flight time" - check your second quote - it's wrong).

That's probably why so many logbook companies use the term "Hood" rather than simulated instrument and a lot of pilots keep them separate.

Heck if you stick just by the regs, there's probably no need for separate actual and simulated instrument columns to begin with.
 
MidlifeFlyer said:
I have never seen an official answer to whether FTD time done with a single-I under 61.109(k), so this is strictly my opinion and worth what you paid for it:

No, it doesn't even count toward the instrument time that does not need to be with a CFII. I say that because,

(a) from what I have seen, generally, in order to count as instrument time, sim/FTD time needs to be done with a CFII (or instrument ground instructor); and

(b) the use of sim/FTD time toward the private is under 61.109(k) which uses the language "may be credited toward" flight training requirements. That type of language appears in other regs and is, to me a a phrase that roughly translates into, "we know that under normal circumstances, this type of activity doesn't count for anything, but we will let you count it only for this limited purpose."
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..aaand here's my opinion which is worth exactly the same:

61.109(k) says: "A maximum of 2.5 hours of training in a flight simulator or ftd representing cat., class, and type of aircraft appropriate to the rating sought, may be credited..."

It doesn't say instrument training, and it says "appropriate to the rating sought", which is a PP cert., not an instrument rating.

The 3 hours of instrument time required for the PP cert. is not "instrument training", it is "control of the aircraft by reference to instruments", which can be done by a CFI-A only. It is not required to be an II. In this case, the reference to "authorized instructor" is a CFI-A only when the training is not for an instrument rating.

THEREFORE, the simulated instrument time aquired in a sim is countable as simulated instrument time the same as the 3 hours hood time that would otherwise occur in an airplane.

No matter how you cut it, 15 hours with an II is the minimum requirement. All other simulated time counts towards the 40 total instrument hours.
 
You can quote any reg you want to, but once the FSDO gets involved, it's all over. Like MidlifeFlyer said, FSDOs make up their own rules and you have to go by them. It sucks, but that's the FAA. You love how they hand out licenses, but hate how they regulate! :laff:
 
JulietBravo said:
You can quote any reg you want to, but once the FSDO gets involved, it's all over. Like MidlifeFlyer said, FSDOs make up their own rules and you have to go by them. It sucks, but that's the FAA. You love how they hand out licenses, but hate how they regulate! :laff:
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Amen to that JB!:yup:
I like to 'analyze' these regs as best as I can, partly for the fun of it and partly because I have to teach them. Over the years I've learned to 'submit' to the local FAA way, but to be aware and teach that the rules may change in another locale.

...or another time.

...or in a slighly different situation....

...you know how each instructor is different?...

...well, instructors become DE's, and FSDO Inspectors....

.....aaaand the beat goes on....
 
Kevin.Held said:
I'm looking at the instrument requirements and just wanted to confirm a few things.

First of all, I have 3.7 hours in an approved FTD from my private training, but my instructor did not have his CFII at the time. Can i use this time toward the 40 hour requirement? 61.65(e) says up to 20 hours "with an authorized instructor". Thanks a lot for your help
Click to expand...

61.65(a)(5) references that the flight 'training' (referenced under 61.65(c) as with respect to 'flight proficiency') must be received from an 'authorized instructor'. okay, so 'training' flights, which count towards the 15 'training hours' required under 61.65(d)(2)(i) must be with a cfii. okay.

61.65(a)(5) further says that some of this 'training' may be accomplished in a fs or ftd, representative of the aircraft. more on that later..

61.65(d)(2) specifies the 40-hour time requirement, not total 'training' time.

61.65(e)(1) specifies that a max of 30 hours in the fs or ftd may be performed if the 'training' was accomplished in accordance with part 142. 61.65(e)(2) says 20 hours if not. so not all of the 40-hours may be in a fs or ftd, but if these particular 20 or 30 hrs are used, they must be performed under the supervision of an 'authorized instructor' because again, they reference 'training'..and 'loggable training' may only be given by a cfii. if greater than 20 hours are logged to apply towards the instrument rating requirements, as in the 61.65(e)(2) example, then all 20 hrs. need to be with a cfii. hour '21' in the fs or ftd may be counted towards the total of 40.

also, while it may be possible to take the practical in a fs or ftd per 61.65(a)(8)(ii), there's no getting around the requirement to fly a 'real airplane' sometime per 61.65(d)(2)(iii).

61.109(k), as nosehair mentioned, references limitations for use of a fs or ftd for a pp certificate. poor wording in my opinion though..they reference what's actually a certificate being sought as '..the rating sought'.

as others have mentioned, make certain that you have the 15 hours of required 'training time' from a cfii.
 
Just a quick question popped in my head, If using the sim for PPL licence, if its simulated instrument time, can that be used to sastisfy the 3 hours instrument time required for the PPL.
It just seem to be more effective to teach VOR tracking, intercepting, etc, doing simulated instrument in the sim
 
Fly_Unity said:
Just a quick question popped in my head, If using the sim for PPL licence, if its simulated instrument time, can that be used to sastisfy the 3 hours instrument time required for the PPL.
It just seem to be more effective to teach VOR tracking, intercepting, etc, doing simulated instrument in the sim
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I think that's the whole idea. There isn't much else you can do with the typical FTD available at the private level other than flight by reference to instruments and navaid tasks.
 
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