FAR DECODED — TITLE 14 CFR

Use of Simulator or Ftd for Instrument or Type Rating

Regulation Text

§ 61.64 Use of a flight simulator and flight training device.

(a) Use of a flight simulator or flight training device. If an applicant for a certificate or rating uses a flight simulator or flight training device for training or any portion of the practical test, the flight simulator and flight training device—

(1) Must represent the category, class, and type (if a class or type rating is applicable) for the rating sought; and

(2) Must be qualified and approved by the Administrator and used in accordance with an approved course of training under part 141 or part 142 of this chapter; or under part 121 or part 135 of this chapter, provided the applicant is a pilot employee of that air carrier operator.

(b) Except as provided in paragraph (f) of this section, if an airplane is not used during the practical test for a type rating for a turbojet airplane (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must—

(1) Hold a type rating in a turbojet airplane of the same class of airplane for which the type rating is sought, and that type rating may not contain a supervised operating experience limitation;

(2) Have 1,000 hours of flight time in two different turbojet airplanes of the same class of airplane for which the type rating is sought;

(3) Have been appointed by the U.S. Armed Forces as pilot in command in a turbojet airplane of the same class of airplane for which the type rating is sought;

(4) Have 500 hours of flight time in the same type of airplane for which the type rating is sought; or

(5) Have logged at least 2,000 hours of flight time, of which 500 hours were in turbine-powered airplanes of the same class of airplane for which the type rating is sought.

(c) Except as provided in paragraph (f) of this section, if an airplane is not used during the practical test for a type rating for a turbo-propeller airplane (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must—

(1) Hold a type rating in a turbo-propeller airplane of the same class of airplane for which the type rating is sought, and that type rating may not contain a supervised operating experience limitation;

(2) Have 1,000 hours of flight time in two different turbo-propeller airplanes of the same class of airplane for which the type rating is sought;

(3) Have been appointed by the U.S. Armed Forces as pilot in command in a turbo-propeller airplane of the same class of airplane for which the type rating is sought;

(4) Have 500 hours of flight time in the same type of airplane for which the type rating is sought; or

(5) Have logged at least 2,000 hours of flight time, of which 500 hours were in turbine-powered airplanes of the same class of airplane for which the type rating is sought.

(d) Except as provided in paragraph (f) of this section, if a helicopter is not used during the practical test for a type rating in a helicopter (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must meet one of the following requirements—

(1) Hold a type rating in a helicopter and that type rating may not contain the supervised operating experience limitation;

(2) Have been appointed by the U.S. Armed Forces as pilot in command of a helicopter;

(3) Have 500 hours of flight time in the type of helicopter; or

(4) Have 1,000 hours of flight time in two different types of helicopters.

(e) Except as provided in paragraph (f) of this section, if a powered-lift is not used during the practical test for a type rating in a powered-lift (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and have 500 hours of flight time in the type of powered-lift for which the rating is sought.

(f) If the applicant does not meet one of the experience requirements of paragraphs (b)(1) through (5), paragraphs (c)(1) through (5), paragraphs (d)(1) through (4), or paragraph (e) of this section, as appropriate to the type rating sought, then—

(1) The applicant must complete the following tasks on the practical test in an aircraft appropriate to category, class, and type for the rating sought: Preflight inspection, normal takeoff, normal instrument landing system approach, missed approach, and normal landing; or

(2) The applicant's pilot certificate will be issued with a limitation that states: “The [name of the additional type rating] is subject to pilot in command limitations,” and the applicant is restricted from serving as pilot in command in an aircraft of that type.

(g) The limitation described under paragraph (f)(2) of this section may be removed from the pilot certificate if the applicant complies with the following—

(1) Performs 25 hours of flight time in an aircraft of the appropriate category, class (if a class rating is required), and type for which the limitation applies under the direct observation of the pilot in command who holds a category, class (if a class rating is required), and type rating, without limitations, for the aircraft;

(2) Logs each flight and the pilot in command who observed the flight attests in writing to each flight;

(3) Obtains the flight time while performing the duties of pilot in command; and

(4) Presents evidence of the supervised operating experience to any Examiner or Flight Standards office to have the limitation removed.

[Docket FAA-2006-26661, 76 FR 78143, Dec. 16, 2011, as amended by Docket FAA-2018-0119, Amdt. 61-141, 83 FR 9170, Mar. 5, 2018; FAA-2023-1275, Amdt. 61-157, 89 FR 92485, Nov. 21, 2024]

Research Notes

Research Notes

§ 61.64 addresses use of flight simulators and training devices for instrument and type ratings. Key document: AC 61-136B (Flight Simulation Training Device Approval Guide) outlines qualification levels and how credit applies. Important distinction: A Level 6 or higher FTD qualifies for some instrument time credit; only a Level C or D FFS qualifies for 100% instrument time substitution in certain conditions. NTSB relevance: Currency gaps revealed after accidents have included simulator time logged in unqualified devices — know your device's qualification level. AC 61-136B — FAA

CFI Commentary

Highlighted phrases in the regulation text above link to instructor notes at the bottom of this page. Look for the amber or blue highlights — each one flags a gotcha or a pro tip worth knowing.

Amendment History

2025-01-21
Substantive amendment to § 61.64. Amendment date: 2025-01-21; issue date: 2025-01-21.
Amendment: 61.64
2025-01-21
Non-substantive update to § 61.64. Re-issued 2025-04-09 (editorial/formatting only).
Amendment: 61.64
2024-11-21
Substantive amendment to § 61.64. Amendment date: 2024-11-21; issue date: 2024-11-21.
Amendment: 61.64
2018-03-05
Substantive amendment to § 61.64. Amendment date: 2018-03-05; issue date: 2018-03-06.
Amendment: 61.64
2018-03-05
Non-substantive update to § 61.64. Re-issued 2023-03-31 (editorial/formatting only).
Amendment: 61.64
2016-12-30
Substantive amendment to § 61.64. Amendment date: 2016-12-30; issue date: 2017-01-01.
Amendment: 61.64

AOA Notes

These notes correspond to the highlighted phrases in the regulation text above. Each one flags something worth knowing — a common misread, a checkride gotcha, or a practical pro tip.

Pro Tip: FFS vs. FTD: The Credit Is Not the Same
A full flight simulator (FFS) and a flight training device (FTD) are not interchangeable for logging purposes. An FFS is the highest-fidelity device and typically has the most generous credit — up to 100% of the instrument time in some scenarios. An FTD grants partial credit. Know which device you're using and what it's qualified for before you log the time.
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Gotcha: The Instructor Must Be Qualified in the Device
The flight instructor who gives you training in a simulator or FTD must be authorized for that specific device and for the operation being simulated. An instructor who's great in the airplane is not automatically authorized to give you simulator time that counts toward your rating. Confirm their authorization before the session.
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