ATD/FTD use for Private Pilot training

5/4/2015

Part 61 allow for 2.5 hours of training in an ATD or FTD to be used as part of the 40 hours of flight time towards the private pilot certificate. (subject to the requirements I posted in my April 2015 blog) Some private pilot applicants have used this ATD/FTD time to be counted as part of the required 3 hours of instrument time. Unfortunately, this isn't allowable.

FAR 61.109(a)(3) states a private pilot must have at least 3 hours of flight training in an airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight.

Mark M.

5/9/2015 02:12:37 am

Hi Chris,

Questions for you...

1. Does the 3 hours of instrument training during PPL training count toward the 40 hours required for the instrument rating?

2. If that training was given by a CFII does it count toward the 15 hours of training required for the instrument rating?

3. If the above answers are no, how come it is possible to work on a combo private & instrument rating?

I've heard arguments both ways on questions 1 and 2 but have yet to find something official from the FAA. Thanks for your help!

Chris Anderson

5/10/2015 02:16:58 pm

Hi Mark!

Great questions but first the disclaimer!

This is just my opinion, I may be wrong!

1. Does the 3 hours of instrument training during PPL training count toward the 40 hours required for the instrument rating?

Yes, the 3 hours of hood work acquired during the PPL training can count towards the 40 hours of instrument time required for the instrument rating.

2. If that training was given by a CFII does it count toward the 15 hours of training required for the instrument rating?

Maybe. In my opinion it could count. I don't see anything in Part 61 or any FAA legal interpretations that prohibits it. If you look at 61.109 and 61.65 you would see the wording is very similar. If the training required by 61.109 (a)(3) was done by a CFII then I don't see why it cant be used towards the 15 hours of dual by a CFII for the instrument rating.

3. If the above answers are no, how come it is possible to work on a combo private & instrument rating?

The combined private and instrument program turned out to be a big pile of dog excrement. I've never done a combo ride but I've heard it has a very high failure rate.

Regarding your question, the combined private/instrument required the instrument training be done by a CFII. So in some cases two instructors would be required.

Thanks for the questions!

Chris

Mark M.

5/10/2015 10:07:56 pm

Thanks Chris. This is very helpful information. As I mentioned before, I came across a number of varying opinions on aviation-related Internet forums. There doesn't seem to be an official opinion from the FAA (or at least one I can find). I'm going to assume for now that I'm good to go since there isn't a reg prohibiting the crediting of this time toward an additional rating.

ATD/FTD use for Private Pilot training

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