Regulation Text
§ 61.9 Inapplicability of simplified flight controls aircraft experience credit.
Notwithstanding the requirements specified in § 61.51(c), any pilot time acquired while operating an airplane or helicopter with a simplified flight controls designation may not be used to satisfy the following aeronautical experience requirements for a private, commercial, or airline transport pilot certificate, except for private pilot applicants who present an aircraft with the simplified flight controls designation to conduct the practical test—
(a) The solo flight time requirements in § 61.109(a)(5) or (c)(4);
(b) The PIC flight time requirements in § 61.129(a)(2)(i) and (c)(2)(i);
(c) The PIC flight time requirements in § 61.159(a)(5); and
(d) The PIC flight time requirements in § 61.161(a)(3).
Research Notes
Simplified Flight Controls Aircraft — MOSAIC Context
Section 61.9 was added as part of the MOSAIC (Modernization of Special Airworthiness Certification) rulemaking framework. "Simplified flight controls aircraft" refers to a new category of light-sport aircraft that may include simplified or augmented control systems — fly-by-wire with envelope protection, simplified throttle management, or similar features that reduce the stick-and-rudder skill demand.
The regulatory concern: pilots who train exclusively in simplified-controls aircraft would build logbook time without developing the manual stick-and-rudder proficiency required for certificates that involve operating conventional aircraft. § 61.9 addresses this by excluding simplified-aircraft PIC time from satisfying solo flight time requirements (§ 61.109), commercial PIC requirements (§ 61.129), and ATP PIC requirements (§§ 61.159, 61.161).
Exception: Private pilot applicants who bring a simplified-controls aircraft to their practical test may use that aircraft's PIC time to satisfy their solo requirements. This is the one carve-out — and it makes sense, since they're demonstrating proficiency in the actual aircraft they used.
Note: This section has limited practical application until MOSAIC implementation is fully underway. Most pilots will not encounter simplified-controls aircraft for some time.
Amendment History
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.
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.