FTD Time
#1
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Joined APC: Jun 2007
Position: Student
Posts: 20
FTD Time
I am working on building hours for my commercial and intend on taking advantage of the 50 hours allowed in FTDs part 61. I have a few question that maybe you all could answer. I used an AATD and a MFD CAT IV at DCA. They logged it a FTD but are they considered FTDs and do they count towards the 50 hours? I also did most of the time before I pass my instrument check ride. Will the FTD time I did before the instrument apply to the commercial? And just your opinion, I only need 20 hours till I start commercial training do you feel it is beneficial for me to do most of it in the sim or a real airplane? FTD would be most beneficial financially but flying a real airplane will defiantly be more educationally beneficial and more fun! Thanks.
#2
All your hours count. You don't start over with each additional rating. Now, whether the devices you listed are "Approved Flight Training Devices", that's a FSDO matter. Call DCA and ask them if their sims are approved as such.
Why don't you consider doing the commercial 141. If you are looking for the best financial decision in aviation, its not flying 250 total when you don't have to. Also, the FAA seems to hand out 141 certs to anyone who can write a syllabus. No matter what anyone says on here, most syllabi are not as constricting as they are made out to be...AND you could have your CFI with just over 200 hrs rather than just your commercial with 250.
The whole point of training is to do it in the fewest amount of hours (hours=money). Time building happens after that.
Why don't you consider doing the commercial 141. If you are looking for the best financial decision in aviation, its not flying 250 total when you don't have to. Also, the FAA seems to hand out 141 certs to anyone who can write a syllabus. No matter what anyone says on here, most syllabi are not as constricting as they are made out to be...AND you could have your CFI with just over 200 hrs rather than just your commercial with 250.
The whole point of training is to do it in the fewest amount of hours (hours=money). Time building happens after that.
#3
As far as whether the sim you used is legal to count towards your ratings...
You need two things...
The make and model sim/FTD must be approved by the FAA for those purposes.
Additionally, the sim in question must be maintained and function properly. A sim operator is required to display an approval certificate from the FSDO, it is usually found in a frame on the wall. This cert is only valid for one or two years (I forget), and must be renewed.
If you are logging sim/FTD time to apply towards a rating, I would make and keep a photocopy of that certificate (check the date!)
You need two things...
The make and model sim/FTD must be approved by the FAA for those purposes.
Additionally, the sim in question must be maintained and function properly. A sim operator is required to display an approval certificate from the FSDO, it is usually found in a frame on the wall. This cert is only valid for one or two years (I forget), and must be renewed.
If you are logging sim/FTD time to apply towards a rating, I would make and keep a photocopy of that certificate (check the date!)
#4
On a related note, is an authorized instructor required to be present for a pilot to log approaches for the purpose of instrument currency? My part 141 school says no. Here's what I've come up with:
61.51(g)(4) says "A flight simulator or approved flight training device may be used by a person to log instrument time, provided an authorized instructor is present during the simulated flight."
AC 61-136 Appendix 2, #2 (Authorized Use) says "An authorized instructor must administer and properly endorse [flight simulation device] training to satisfy the regulatory requirements."
---however---
My school is going with an email we got from a guy known only as Lance from Washington FAA who says if you are trying to satisfy 61.57(c), you don't need an instructor present to log the BATD time.
If I had to choose between the FAR + AC, and Lance, I know what I'd pick, but I'm interested to hear if any other schools are doing this.
I don't know if it has to do with a LOA our school has (boss says there is one; can't find it), or if it has to do with whether you need to log "instrument time" when you're logging approaches for currency.
61.51(g)(4) says "A flight simulator or approved flight training device may be used by a person to log instrument time, provided an authorized instructor is present during the simulated flight."
AC 61-136 Appendix 2, #2 (Authorized Use) says "An authorized instructor must administer and properly endorse [flight simulation device] training to satisfy the regulatory requirements."
---however---
My school is going with an email we got from a guy known only as Lance from Washington FAA who says if you are trying to satisfy 61.57(c), you don't need an instructor present to log the BATD time.
If I had to choose between the FAR + AC, and Lance, I know what I'd pick, but I'm interested to hear if any other schools are doing this.
I don't know if it has to do with a LOA our school has (boss says there is one; can't find it), or if it has to do with whether you need to log "instrument time" when you're logging approaches for currency.
#5
Bernoulli, I downloaded the AC you reference here:
http://www.flyelite.ch/downloads/docs/ac61_136.pdf
You quote "AC 61-136 Appendix 2, #2" but you leave out that is subparagraph (a). Read subparagraph (b) just below. In my mind, "Use in performing instrument recency of experience requirements of § 61.57(c)(1)", would make me tend to agree with Lance. So, the big question is, does subparagraph (a) apply to ALL of subparagraph (b), or is it seperate? You'll notice the verbage in (b) does mention training time with respect to use under 61 and 141, but, the word "training" is missing from the 61.57 verbage. That would be my argument that yes, you can use the BATD without a CFI for 61.57 currency.
Interesting stuff and total news to me. I've always felt you HAD to have a CFII to use a ground trainer, period.
RickAir. You mention needing FSDO approval and a "letter on the wall". In page 8 of this AC, it does mention local FSDO approval for each unit but that is only for part 141, not 61. Here is the reference:
"NOTE: A part 141 certificated pilot school must obtain a specific authorization for the use of the ATD as part of that pilot school’s approved training curriculum. This authorization must come from the FAA FSDO assigned to that pilot school"
http://www.flyelite.ch/downloads/docs/ac61_136.pdf
You quote "AC 61-136 Appendix 2, #2" but you leave out that is subparagraph (a). Read subparagraph (b) just below. In my mind, "Use in performing instrument recency of experience requirements of § 61.57(c)(1)", would make me tend to agree with Lance. So, the big question is, does subparagraph (a) apply to ALL of subparagraph (b), or is it seperate? You'll notice the verbage in (b) does mention training time with respect to use under 61 and 141, but, the word "training" is missing from the 61.57 verbage. That would be my argument that yes, you can use the BATD without a CFI for 61.57 currency.
Interesting stuff and total news to me. I've always felt you HAD to have a CFII to use a ground trainer, period.
RickAir. You mention needing FSDO approval and a "letter on the wall". In page 8 of this AC, it does mention local FSDO approval for each unit but that is only for part 141, not 61. Here is the reference:
"NOTE: A part 141 certificated pilot school must obtain a specific authorization for the use of the ATD as part of that pilot school’s approved training curriculum. This authorization must come from the FAA FSDO assigned to that pilot school"
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