Legal Interpretations
Rossman 2012
Summary
The Question
May a pilot seeking an initial commercial pilot certificate with a multiengine class rating credit time in a flight training device representing a single-engine airplane toward total flight time?
Background
A pilot seeking a commercial pilot certificate with an airplane category multiengine class rating had 40 hours of aeronautical experience in a flight training device that represents a single-engine airplane.
The FAA’s Interpretation
No. 14 CFR 61.129(i)(1)(i) lets a pilot who trains outside a part 142 training center credit up to 50 hours in a flight simulator or flight training device toward total aeronautical experience only if the device represents the class of airplane for the rating sought. Time in a device representing a single-engine airplane cannot count toward the 250 hours of total flight time for a multiengine rating.
- Requester
- Rossman
- Issued
- December 13, 2012
- Subjects
- Pilot Certification & Privileges · Training Schools & Centers
Regulations Cited
Page 1
U.S. Deportment
of Tronspooatlon
Federal Aviation
Administration
DEC 13 2012
Fihm.i Rossman
Dear Mr. Rossman:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This letter responds to your request for legal interpretation that you mailed to my office on August 2, 2012. You have asked how a pilot seeking a commercial pilot certificate with an airplane category multiengine class rating may credit flight time in a flight training device (FTD) that represents a single-engine airplane. For the purpose of this interpretation, we asswne the pilot is seeking an initial commercial. pilot certificate and rating. Section 61.129(i)(l)(i) permits a pilot who completes training outside of a part 142 training center to credit a maximum of 50 hours in a flight simulator or flight training device toward the total aeronautical experience requirements for an airplane rating if the aeronautical experience was obtained from an authorized instructor in a flight simulator or flight training device that represents the class of airplane appropriate to the rating sought. Because you are applying for a commercial pilot certificate with an airplane category multiengine class rating, the 40 hours of aeronautical ex:perience that you obtained in a flight training device that represents a single-engine airplane cannot be credited toward the 250 hours of total flight time.
This response was prepared by Anne Moore, an attorney in the International Law, Legislation, and Regulations Division of the Office of the Chief Counsel, and has been coordinated with the Airman Certification and Training Branch of Flight Standards Service. If you have any additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.
Sincerely,
~~;;h~.w2--Assistant Chief Counsel for International Law,
Legislation and Regulations Division, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.