Short story regarding sim use for private pilot applicants:
I know a guy that had is private pilot certificate
revoked because his instructor used an
FAA approved flight sim for 2.5 hours of instrument, plus .5 in an airplane to "satisfy" the aeronautical experience of 61.109(a)(3).
61.109(a)(3) 3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments...
The CFI thought that this would be valid because of 61.109(k):
61.109(k) Permitted credit for use of a flight simulator or flight training device. (1) Except as provided in paragraphs (k)(2) of this section, a maximum of 2.5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section, if received from an authorized instructor.
The decision to revoke his certificate came from OKC when they received his 8710. They said that 61.109(a)(3) states very clearly that the training must be recevied in a single-engine airplane as bolded above. Fortunately for him, the FAA told him that if he would go get 2.5 hours of simulated instrument in a single-engine airplane with an instructor, then they would give him his certificate back, which he did.
Now, back to the OP's original question. 61.129(b)(3)(i) says that the commercial applicant must have "10 hours of instrument training of which at least
5 hours must be in a multiengine airplane" so I would think that you could use the Frasca for the other 5 hours. But don't take my word for it. Talk to your FSDO if there is any doubt.
