135.243 IFR PIC "actual flight"

[zuka]

14 CFR 135.243 (c) (2) says 135 IFR PIC must have:

"75 hours of actual or simulated instrument time at
least 50 hours of which were in actual flight;"

When it says "actual flight" does this mean actual flight in aircraft or actual instrument conditions as in IMC?

I found one interpretation of this saying that it implies that only 25 hours of simulator time can be counted, and another that says you must have 50 hours in the clouds (actual IMC).

Any feedback?

 

[7B2]

50 hours in actual or simulated (=hood-time). That simple.
the other 25 can be in a sim

 

[midlifeflyer]

Wow! This is most poorly written FAR I've seen so far. I can see where the "actual instrument conditions" interpretation comes from.

The full section reads (with some emphasis)

==============================
Has had at least 1,200 hours of flight time as a pilot, including 500 hours of cross-country flight time, 100 hours of night flight time, and 75 hours of actual or simulated instrument time at least 50 hours of which were in actual flight; and
==============================

"Flight time" by definition, is =always= in an aircraft, =never= in a sim. Which would indicate that sim time doesn't count toward anything in that paragraph. Problem is that

==============================
75 hours of actual or simulated instrument time in an aircraft at least 50 hours of which were in actual flight;
==============================

doesn't make a heck of a lot of sense either. What the heck is logable "actual flight" time that's =not= in an aircraft?

Those problems are resolved if you read it to require 50 hours of actual IMC. But that doesn't make sense either. There are parts of the US where it's almost impossible to accumulate that number of actual IMC hours in anything short of a lifetime.

7B2's answer makes the most sense, bust that's =not= what the regulation says.

This is a =perfect= question for Doc's forum.

 

[JimNtexas]

""Flight time" by definition, is =always= in an aircraft, =never= in a sim. Which would indicate that sim time doesn't count toward anything in that paragraph. Problem is that "

Where is that written?

 

[transpac]

It appears that some posters on this BB have decided that simulator time never equals flight time. This is a logical point of view, but the FAA has other ideas: A limited amount of simulator time can be substituted for aircraft time to meet the aeronautical experience requirements for an instrument rating, as well as the total pilot time requirements for an ATP. Except for meeting certification and recency of experience requirements, the FAA doesn't give a whit about all the other issues involving logging simulator time.
In answer to the original post, 50 hours in an aircraft during actual or simulated conditions and 25 hours in a simulator and/or FTD meets the requirements of that particular FAR.

 

[midlifeflyer]

""Flight time" by definition, is =always= in an aircraft, =never= in a sim. Which would indicate that sim time doesn't count toward anything in that paragraph. Problem is that "

Where is that written?

"Flight time" is defined in FAR 1 as
==============================
Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing; or
==============================

No matter how sophisticated, so far, no simulator has reached "aircraft" ("Aircraft means a device that is used or intended to be used for flight in the air") status.

transpac said
It appears that some posters on this BB have decided that simulator time never equals flight time.

Only because it never does.

A limited amount of simulator time can be substituted for aircraft time

That's true, and it's even countable as "pilot time"(which has a different definition that includes simulator time). But it's still not "flight time."

 

[Timebuilder]

[a cut and paste from the same question under 135 charter]

The 75 hours are instrument time, which can be composed of actual instrument time (flight by reference to flight instruments) or simulated instrument time, which can be simulated in an airplane by use of a view limiting device or a simulator, which includes an approved FTD, or flight training device.

50 of those hours must be in actual flight, which is flight in an aircraft, as in actually flying.

They don't want all of your 75 hours to be spent sitting in something that isn't an airplane. 50 hours must be spent in some sort of flying, in either simulated or "actual" conditions.

 

[nosehair]

Government Speak

Part 61 allows for substitution of sim time to meet the requirements for the instrument rating or the ATP rating.
This 135.243 PIC requirement does not specifically allow substitution of this "flight time".
The way I read it, 1200 hours has to be in an actual aircraft, but of the required 75 hours instrument time, 25 can be in a simulator, but they could not be counted towards the total 1200.
I think it is a leftover from when the ATP was 1200 hours, and this was one of the first regs allowing use of sim time to fullfill specific instrument time requirements, but not total aircraft time.

 

[avbug]

There is nothing unclear about this regulation, at all.

75 hours of instrument time. 50 hours of those must be in flight. Actually in the airplane, in flight. Not in a simulator, but in flight.

Those 50 hours in actual flight, that is, in the airplane, must be in instrument conditions.

The instrument conditions may be actual ("IMC"), or simulated ("hood")...but 50 hours must be in actual flight, as opposed to a simulator.

As for the inclusion of simulator time as total flight experience...simulator time is NOT flight time, and this has been reinforced by the FAA.

One may use simulator time toward the requirements of a certificate or rating, but this time should not be included in total flight experience tabulations, as it is NOT flight experience. On applications, it should simply be listed as simulator/flight training device time...not as flight time.

 

[transpac]

I tend to agree with all who have opined that simulator time is never flight time, due to FAR 1 and common sense. But, I don't think it's quite that simple. When the FAR states that 1200 hours of required flight time can include 25 hours in a simulator, it appears that in at least this case the FAA has decreed that simulator time equals flight time. This regulation is pretty clear that the permitted simulator time is not being substituted for flight time, it is flight time. When I was a FAA Inspector (long time ago) we were taught that simulator time can be pilot time but can never be flight time. For example, 61.159 (ATP) requires 1500 hours of pilot time (not flight time) and permits 100 hours of it to be gained in a simulator. In my mind, 135.243 greatly muddies up the water by specifically requiring flight time (instead of pilot time) and permitting a portion of the required flight time to be gained in a simulator.