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Bringing back a dead horse


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Thinking I'm going to go knock out the private fixed wing addon.

 

Reading the FAR's and doing some browsing of old posts, i came across one in 06' that discussed this and flingwing came up with a legal interpretation from a NY FSDO that brought the requirements down to 22 hrs in a plane. I can't open his link, and as some of us know, I can't msg him.

 

Anyone know where I may find a copy, or does anyone have it?

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Direct from the FAR

Sec. 61.109

Aeronautical experience.

(a) For an airplane single-engine rating. Except as provided in paragraph (k) of this section, a person who applies for a private pilot certificate with an airplane category and single-engine class rating must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation listed in Sec. 61.107(B)(1) of this part, and the training must include at least--

 

(k) Permitted credit for use of a flight simulator or flight training device.

(1) Except as provided in paragraphs (k)(2) of this section, a maximum of 2.5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section, if received from an authorized instructor.

(2) A maximum of 5 hours of training in a flight simulator or flight training device representing the category, class, and type, if applicable, of aircraft appropriate to the rating sought, may be credited toward the flight training time required by this section if the training is accomplished in a course conducted by a training center certificated under part 142 of this chapter.

(3) Except when fewer hours are approved by the Administrator, an applicant for a private pilot certificate with an airplane, rotorcraft, or powered-lift rating, who has satisfactorily completed an approved private pilot course conducted by a training center certificated under part 142 of this chapter, need only have a total of 35 hours of aeronautical experience to meet the requirements of this section.

And the flight school has two different pages saying different requirements for transitioning from a helicopter. So either no one has a clue to the requirements or the FAA changed them recently.
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I don't know about the NY FSDO interpretation, but I did a PPL fixed wing addon, let me know if you have any questions.

I'm near Houston, so the NY FSDO isn't my final say so... But maybe with their interpretation, I can present it here.

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No need for legal interpretations, all the answers are in Part 61.

 

As noted above 61.109.a states "40 hours of flight time..." note that it does not specify how you got that flight time, that is the key. You should already have 40 hours of flight time from rotorcraft training. So now you just need to look in 61 for airplane specific items.

 

61.109.a.1 - "3 hours of cross-country in a single-engine airplane"

61.109.a.2, 2i & 2ii - "3 hours of night flight in a single-engine airplane that includes" 100 nm xc and 10 TO&L

61.109.a.3 - "3 hours... in a single-engine airplane... solely by reference to instruments..."

 

You should get the idea now.

 

Technically you could combine the 3hrs XC training, 3hrs Night and 3hrs Instrument into one flight and then get signed off for solo and do the 10 hours solo work. Good luck being that good and better luck finding an instructor willing to do such a thing and really do you think you would be a safe fixed wing pilot with that little experience ?

 

It is reasonable if you adapt well to expect 20 - 25 hours for a transition.

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I agree with Jaybee. Airplanes ARE different categories of aircraft and have their own flight characteristics. If you're current in helicopters, I would expect 25 hours or so in an airplane just to feel competent. But otherwise, the PPL add-on is pretty straight forward.

 

Understand the FAR's and what your current experience is prior to meeting with an instructor, odds are you'll have to teach them what the add-on requirements are.

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I usually disagree with most people on this one because I read the regs literally as they are written.

 

They say 40 hours flight time

.... Anything counts

20 hours of training and 10 solo in the areas of operation listed in 61-107-b-1

 

That means you need 20 hours of airplane specific training and 10 hours of airplane solo.

 

Helicopter stuff doesn't count because helicopter training doesn't fall under 61-107-b-1. Helicopter stuff is 61-107-b-3.

 

Therefore, your helicopter training doesn't satisfy the regs as they are written.

 

However, the only opinion that technically matters is the DPE you go to (and the person who endorses you before you go).

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This is how I was taught it, the guy who taught it to me owned the FBO outside the gates of Mother Rucker and has a stack of 8710s thicker than the FAR/AIM book (in other words has done more add-ons than you can shake a stick at) and last but not least if he were wrong than I need to give all my certificates back and I'm not about to do that.

 

61.109.a "Except as provided..."

  1. "...must log 40 hours of flight time"
  2. "...that includes 20 hours of flight training..."
  3. "...and 10 hours of solo flight training in the areas of operation listed in 61.107.b.1"
  4. "...and the training must include..."

 

So to summarize numbered list -

 

  1. is checked off by previous training
  2. is checked off by previous training
  3. is checked off by 61.109.a & a.5
  4. is checked off by 61.109.a

As I said, this is how it was taught to me, it is how I obtained my license and of course people are free to interpret it a different way.

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I read 61.109 (a) as stating 40 hour flight time (aka total time), which must include 20 hours of training and 10 hours of solo, according to parts 1, 2, 3, 4, and 5 which specifically states single-engine airplane.

 

So my read is 40 hours TT, 20 hours of training in a single-engine airplane and 10 hours solo in a single-engine airplane. 10 hours of your helicopter time counts towards the fixed wing add-on.

 

I would talk with your DPE prior to your check ride to satisfy him.

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Here is the precedence -



http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/o'mara%20-%20(2012)%20legal%20interpretation.pdf



"In your lettter you indicate that an examiner you spoke with stated that all of the aeronautical experience requirements specified in 61.109(j), to include the 40 hours of flight time, 20 hours of flight training, and 10 hours of solo flight training must be completed in a weight-shift-control aircraft. That statement was incorrect."



"The definition of flight time does not include a reference to any particular category and class of aircraft. Any reference to flight time in a regulation, unless otherwise specifically qualified, therefore does not include a limitation that the time be obtained in any particular category and class of aircraft. Accordingly, the requirement for an applicant for a weight-shift-control aircraft rating to have 40 hours of flight time may be met by obtaining flight time in any category and class of aircraft."

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I usually disagree with most people on this one because I read the regs literally as they are written.

 

They say 40 hours flight time

.... Anything counts

20 hours of training and 10 solo in the areas of operation listed in 61-107-b-1

 

That means you need 20 hours of airplane specific training and 10 hours of airplane solo.

 

Helicopter stuff doesn't count because helicopter training doesn't fall under 61-107-b-1. Helicopter stuff is 61-107-b-3.

 

Therefore, your helicopter training doesn't satisfy the regs as they are written.

 

 

Did you really read that literally as it's written

 

§61.109 Aeronautical experience.

 

(a) For an airplane single-engine rating. Except as provided in paragraph (k) of this section, a person who applies for a private pilot certificate with an airplane category and single-engine class rating

 

must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor

 

and 10 hours of solo flight training in the areas of operation listed in §61.107[1] of this part, and the training must include at least—

 

 

"the training must include at least" That's the part you should read. That's what needs to be done in the airplane.

Edited by iChris
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As a matter of fact iChris, I did. I'm pretty good at understanding the role that punctuation plays in a sentence. I also understand what the term "literally" means. Therefore, I literally take what the regs say, literally.

 

If they want them to mean something other than what they say, then they need to learn how to write.

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Here is the precedence -

http://www.faa.gov/a...erpretation.pdf

"In your lettter you indicate that an examiner you spoke with stated that all of the aeronautical experience requirements specified in 61.109(j), to include the 40 hours of flight time, 20 hours of flight training, and 10 hours of solo flight training must be completed in a weight-shift-control aircraft. That statement was incorrect."

"The definition of flight time does not include a reference to any particular category and class of aircraft. Any reference to flight time in a regulation, unless otherwise specifically qualified, therefore does not include a limitation that the time be obtained in any particular category and class of aircraft. Accordingly, the requirement for an applicant for a weight-shift-control aircraft rating to have 40 hours of flight time may be met by obtaining flight time in any category and class of aircraft."

 

 

"Unless otherwise specifically qualified", you skipped that part. Subsections 1-5 specifically qualify single-engine airplane for the PPL.

 

It seems we may all have different interpretations of the regulations. Reasonable minds may differ. I would still consult with a DPE prior to an add-on check ride.

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"Unless otherwise specifically qualified", you skipped that part. Subsections 1-5 specifically qualify single-engine airplane for the PPL.

 

It seems we may all have different interpretations of the regulations. Reasonable minds may differ. I would still consult with a DPE prior to an add-on check ride.

 

I didn't skip it per say, as the letter is a whole letter - just tried to highlight the pertinent information. For the record, not trying to argue or sway anyone's opinion on the matter. I just know how I did it, which is the same way that the guy that taught me has done it, many, many times over. As it stands, the FSDO I used concurs that "...in an airplane..." is exactly what it means, only when it says it - as explained in the O'Mara Chief Counsel Opinion Letter.

 

In fact it goes on to say -

..."Flight training is defined in 61.1 as 'training, other than ground training, received from an an authorized instructor in flight in an aircraft.' Similar to the definition of flight time, it also does not include a limitation that the training be obtained in any particular category and class of aircraft."

 

I left that part out, also. ;)

 

"It seems we may all have different interpretations of the regulations."

No offense, but I'll take the Chief Counsel's opinion.

 

PS - fixed linky in first post

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Wurd. I think we agree regarding "flight time" being ANY time unless specifically qualified in a particular category/class of aircraft.

 

So this post really is about beating a dead horse...awesome.

 

eh, I think we can flog it a few more times for good measure :D

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If you want to be a career helicopter pilot and hope to get hired at a robbie school, you'll need 200 hours in helicopters so I don't think getting the private in an airplane would save any money.

 

If you just want to fly for fun, why bother with airplanes they suck!

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Why people don't get their private in an airplane to begin with is beyond me. Save yourself 10k right off the bat.

Because I wanted a career in helicopters, so that's what I focused on.

 

Now that I can afford to go play after work, it's time to do that.

 

I just can't understand why someone who is focused on being a commercial HELICOPTER pilot would want to waist time in airplanes....

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