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Commercial requirements question.....


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Well I've started training for my commercial and getting some requirements out of the way, but I was wondering why there is a lot of required solo time as opposed to pic time w/o dual (for example, taking a friend up). It just seems odd to me seeing as once you're pic, you are making all the decisions and if you were to have another person in the cockpit who is not a pilot it would not affect anything anyway. Just curious as to opinions on why this is.

Chris

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Well I've started training for my commercial and getting some requirements out of the way, but I was wondering why there is a lot of required solo time as opposed to pic time w/o dual (for example, taking a friend up). It just seems odd to me seeing as once you're pic, you are making all the decisions and if you were to have another person in the cockpit who is not a pilot it would not affect anything anyway. Just curious as to opinions on why this is.

Chris

 

 

Cobra,

 

This is out of 14CFR61,129©

(4) 10 hours of solo flight in a helicopter on the areas of operation listed in §61.127(B)(3) of this part, which includes at least—

 

(i) One cross-country flight with landings at a minimum of three points, with one segment consisting of a straight-line distance of at least 50 nautical miles from the original point of departure; and

 

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern)

 

It's only 10 hours SOLO. 5 of which have to be at night. The reason they want solo is because they have no idea who your passenger is. I acted as a voice activated autopilot for 7 hours. My "passenger" was a Helo ATP. Was I PIC yes for logging purposes. Did I learn alot? Heck Yeah. But I did not make any of the decisions and I did not call the shots.

I think this is exactly what the FAA had in mind.

Chris

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Part 61.129

© 35 hours of pilot in command

©(4) 10 hours of solo

 

You already did the 10 hours of solo during you PPL.

 

I tell you this now, but you should really start thinking for yourself and reading the FAR's if you want to be a commercial pilot.

 

Wesp CFI(H)

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Wesp, I think you need to read 61.123 a little more carefully.

 

§ 61.123 Eligibility requirements: General.

 

To be eligible for a commercial pilot certificate, a person must:

 

(a) Be at least 18 years of age;

 

( b ) Be able to read, speak, write, and understand the English language. If the applicant is unable to meet one of these requirements due to medical reasons, then the Administrator may place such operating limitations on that applicant's pilot certificate as are necessary for the safe operation of the aircraft.

 

(c ) Receive a logbook endorsement from an authorized instructor who:

 

(1) Conducted the required ground training or reviewed the person's home study on the aeronautical knowledge areas listed in §61.125 of this part that apply to the aircraft category and class rating sought; and

 

(2) Certified that the person is prepared for the required knowledge test that applies to the aircraft category and class rating sought.

 

(d) Pass the required knowledge test on the aeronautical knowledge areas listed in §61.125 of this part;

 

(e) Receive the required training and a logbook endorsement from an authorized instructor who:

 

(1) Conducted the training on the areas of operation listed in §61.127( B ) of this part that apply to the aircraft category and class rating sought; and

 

(2) Certified that the person is prepared for the required practical test.

 

(f) Meet the aeronautical experience requirements of this subpart that apply to the aircraft category and class rating sought before applying for the practical test;

 

(g) Pass the required practical test on the areas of operation listed in §61.127( B ) of this part that apply to the aircraft category and class rating sought;

 

(h) Hold at least a private pilot certificate issued under this part or meet the requirements of §61.73; and

 

(i) Comply with the sections of this part that apply to the aircraft category and class rating sought.

 

That innocuous line means that the solo, and dual hours you logged as a private pilot DO NOT COUNT except for meeting specific hour requirements. i.e. 40 hours total time, 10 hours dual, etc, count for the hour requirements, BUT they do not count for the specific training in 61.129. Further, the X/C requirements for the commercial are different than the private requirements.

 

So, to boil it down, you have to do the 20 hours of dual, and 10 hours of solo, and those hours have to be solo.

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In regard to wesp's post, SVrider is right... the xc requirements are different and seperate from those you completed for your PPL. For instance at least two 2 hour XC as PIC. When doing your PPL XC's they were no logged as PIC time.

 

To sum the commercial flying requirements up, at least what i can remember, you need 150 hours total time, 100 of which are PIC (at least 35 in helicopter), 10 hours XC as PIC (which includes a 2 hour day and 2 hour night flight, both vfr), 10 hours SOLO (as in the sole occupant of the aircraft) including 1 XC with a 50 mile leg and 5 vfr night with 10 landings in a pattern. It's a lot to take in.

 

Going back to svtcobra66's initial question, solo can only be logged when you are the sole occupant of the aircraft, so no friends on that long boring cross country. If it's ok with your school, be sure to enjoy your flying and plan some PIC time for taking friends and gorgeous women :) on joy flights. Remember though, you may not be compensated for your time as pic. However, I don't think the FAA could say a thing if a gorgeous women decided she owed you a little "something something" for the experience. :)

 

Oh, and two more things, can someone direct me to an online copy of the FAR/AIM, cutting and pasting would make for much easier posting. And to svrider, are you riding a suzuki sv? That's my current bike and i'm in love. Copper 03 650s!

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Thanks for the info, thats what i figured... looks like some fun solo XC for me. I understand that it is important to make decisions on your own, its just more fun with someone along for the ride, and it still seems odd that they would require more solo instead of PIC, though I suppose they could never really know who you were flying with, and the burden of the decision making really should be on you.

Chris

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Remember though, you may not be compensated for your time as pic. However, I don't think the FAA could say a thing if a gorgeous women decided she owed you a little "something something" for the experience. :)

 

Oh, and two more things, can someone direct me to an online copy of the FAR/AIM, cutting and pasting would make for much easier posting. And to svrider, are you riding a suzuki sv? That's my current bike and i'm in love. Copper 03 650s!

 

Helizach is correct that you cannot be compensated, BUT, a passenger can pay up to 50% (i believe the reg says a pro rata share) of the cost of the flight. 61.113 ( c )

 

Here is your link...http://ecfr.gpoaccess.gov/cgi/t/text/text-...14/14tab_02.tpl

 

Yes, I ride an SV. It's a Blue 05 650S. I love my bike! B)

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Hey Cobra,

 

I'm just going off the top of my head here, but I think it could be either PIC or solo time. Many of the schools that I have checked out allow you to do PIC time building in a Bell 206 while doing charters so you can get that needed "PIC" time for your commercial... Hope I'm right, I'll double check...

 

Jake

 

How can you be doing charter work if you do not have a commercial license? I have a feeling that someone is trying to blow smoke up your skirt if they are telling you that you are going to get to do charter work with only a private license.

 

Doug

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How can you be doing charter work if you do not have a commercial license? I have a feeling that someone is trying to blow smoke up your skirt if they are telling you that you are going to get to do charter work with only a private license.

 

Doug

Hi Doug,

 

From what I've seen from a few of these places (HeliClass for example) is that you get your PPL and then you can do timebuilding in a 206 for $160 hour... I'm not sure how they do this, but I've heard its doing "charter" work (I'm not sure if its with the passengers aboard or after they get dropped off :blink: Or maybe some other things (tours maybe) that you help the company out with... maybe you experienced guys can help me out here. Also, just to clarify, I have NOT talked to any of these schools, I'm just going by what I see on their web sites, and it could be some bad interpretation on my part! :o I'm not planning on attending any of the schools that do this, I was only going off of the "top of my head" as I mentioned, and it looks like I might be wrong after all!

 

Jake

 

I just checked HeliClass' website and it says that you do timebuilding during "sightseeing tours"... http://www.heliclass.com/pages/frameset.html

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Make sure it's not under "CHARTER".......because that's illegal. Charter is 135 and you cannot give dual instruction under 135. Regardless of whether or not pax are on board, if it is a 135 flight--no dual. That includes cargo or the empty run back home after you've dropped off the pax or cargo.

 

If you're doing tours, power/pipeline inspections, etc that's another story. You can legally receive dual during those flights. However, if you never touch the controls, your PIC time might be debatable in a court of law. If you're a CFI and your giving the more experienced tour guide "dual" so you can log PIC & dual given, that's debatable too.

 

The regs are written pretty loosely, so you can TRY both of these and probably get away with it. HOWEVER, if you ever end up in a situation where they audit your flight time, those loosely written regs are going to be interpreted a different way by the feds. And now you're going to spend major $$$$ to defend yourself--probably more cash than if you would have just spent for the straight dual. And you risk losing all those hours and your certificate. It's a great deal, just like BOATPIX, but you're taking a gamble that all FSDO's honor their interpretation of the FARs.

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Delorean,

 

This is exactly what I was thinking.

 

The 'charter' aspect makes it Part 135 operations.

 

Also the idea of one of the pilots being an instructor is dodgy as you now have a dual-purpose for the flight (the tour and the instruction).

 

I can't see how a PPL can log any (useful) time without violating 61.113

 

Some might say that because you are paying $160/hour you aren't receiving compensation. However, I may be wrong, but I think even the 'greatly reduced aircraft rates' are considered a form of compensation by the FAA, especially if a company advertises this.

 

So, as I said before, if anyone can explain how these 'timebuilding' schemes work, the I'd love to know.

 

Joker

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If you are doing sightseeing tours and staying within 25 SM of the departure point and passengers are only allow to disembark at the original point of departure, then the flight can be done under Part 91. I know of one operator in the Los Angeles area that will have you flying tours and another that has you flying traffic reporters around. Both were CFI's and flying with you the entire time. If you check in the classified ads in Pacific Flyer under 'Helicotper Instruction' you will find one of them listed.

 

Doug

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HH60,

 

Thanks for that. However, the 135 / 91 issue is not at question. Even if it is Part 91, what useful time can a PPL legally log here?

 

Here are some possible scenarios.

 

1. PPL is flying tours or powerline inspections - According to Part 61.113 this PPL cannot act as PIC as the company is advertising tours or powerline inpsections (so it is not incidental) and receiving money for the tours. 61.113(B)(2) says that a PPL may not act as PIC in an aircraft that is carrying pax or payload for compensation or for hire. A tour passenger is presumably paying the company for the tour, so this rule is invoked here. SIC time is not loggable under 61.51 With the powerline inspection company, the person doing the inspection is a passenger who is being carried for hire. Furthermore, if the company advertises that it can do powerline inspections, then this flight is NOT incidental to the business.

 

2. PPL is flying with an instructor here and logs Dual Instruction (at the same time as a fare paying passenger is getting his tour - This to me is a dual-purpose flight. I don't think a court would look favourably on the private pilot and instruction in an incident where a passenger paying for a tour was injured because a 'training accident' happend. Again, 61.113(B)(2) comes into question here, not to mention the irresponsible act of 'training' while you had a pax paying for a tour.

 

3. The PPL pays $160/hour to fly. - This greatly reduced rate for flight time, is a form of compensation. Again a breach of 91.113. (I'll need to find it, but I have seen a legal opinion where reduced rates on flight time can count as compensation.)

 

4. PPL acts as an observer for say, a traffic reporting company. - Well, great, but what's the point if he can't act as PIC.

 

So, I still can't see what time the PPL can log in any of these situations.

 

I suppose there must be an interpretation (correct or not) that allows for it, otherwise these companies wouldn't get away with openly advertising 'hour building'on their websites....it's just that I can't see it at the moment.

 

Joker

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The more I think about it, the CFI offering cheap time is a JetRanger is also the traffic reporter. I can't remember if the time is logged as dual or PIC. If someone is interested enough, PM me and I'll send you his name and number.

 

Doug

 

Doug - I know of two in LA that do this; are you thinking of the french guy or Commander Chuck? At least when I was there, Chuck was not a CFI....

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You can create as many scenarios as you like, but when you get busted for something and the FAA takes a gander at your logbook they'll just have something else to TRY to bust you on.

 

The FAA will always interpret the regs in the most stringent way and it will be up to you to pay to defend yourself.

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Don't forget.... acting PIC and logging PIC are two different animals.

 

If allowed under part 91 during the sightseeing scenario, you can log PIC as sole manipulator of the controls as long as you are rated in that category and class of aircraft. The CFI/commercial pilot in the other seat will be the actingPIC, as he is responsible for the safe outcome of the flight.

 

Logging PIC as sole manipulator is fine and is allowable as PIC time for additional ratings, etc. However, it's the acting PIC that is important to claw your way up the commercial pilot food chain.

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Don't forget.... acting PIC and logging PIC are two different animals.

 

If allowed under part 91 during the sightseeing scenario, you can log PIC as sole manipulator of the controls as long as you are rated in that category and class of aircraft. The CFI/commercial pilot in the other seat will be the actingPIC, as he is responsible for the safe outcome of the flight.

 

Logging PIC as sole manipulator is fine and is allowable as PIC time for additional ratings, etc. However, it's the acting PIC that is important to claw your way up the commercial pilot food chain.

 

WARNING!!! THIS POST IS REALLY LONG! FAR in black, important stuff in red, what I have to say is in blue.

 

Wow, wonder where you get this from...

 

I would love to see the FAR you read from, must be a great read. Here is the one I read from...

 

From CFR 14, § 1.1 General definitions

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight;

(2) Has been designated as pilot in command before or during the flight; and

(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

 

Wait just a second. Didn't you say both pilots could log PIC?

 

From CFR 14, § 61.51 Pilot logbooks

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.

(3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor.

(4) A student pilot may log pilot-in-command time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

(ii) Has a current solo flight endorsement as required under §61.87 of this part; and

(iii) Is undergoing training for a pilot certificate or rating.

 

Here is where a CFI can log PIC. But doesn't it say when acting as an authorized instructor? Whats that!?

 

From CFR 14, § 61.1 Applicability and definitions.

2) Authorized instructor means—

...(ii) A person who holds a current flight instructor certificate issued under part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate...

 

Now hold on just one second. How can an instructor act as an authorized instructor, while ALSO acting as PIC of a tour flight? Whats that? Oh...he can't.

 

Furthermore, if the sightseeing passengers are paying for the ride, a private pilot cannot act as PIC. Why? I thought you would never ask...

 

From CFR 14, § 61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs ( b ) through (g) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

( b ) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

© A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers, provided the expenses involve only fuel, oil, airport expenditures, or rental fees.

(d) A private pilot may act as pilot in command of an aircraft used in a passenger-carrying airlift sponsored by a charitable organization described in paragraph (d)(7) of this section, and for which the passengers make a donation to the organization, when the following requirements are met:

(1) The sponsor of the airlift notifies the FAA Flight Standards District Office with jurisdiction over the area concerned at least 7 days before the event and furnishes—

(i) A signed letter from the sponsor that shows the name of the sponsor, the purpose of the charitable event, the date and time of the event, and the location of the event; and

(ii) A photocopy of each pilot in command's pilot certificate, medical certificate, and logbook entries that show the pilot is current in accordance with §§61.56 and 61.57 of this part and has logged at least 200 hours of flight time.

(2) The flight is conducted from a public airport that is adequate for the aircraft to be used, or from another airport that has been approved by the FAA for the operation.

(3) No aerobatic or formation flights are conducted.

(4) Each aircraft used for the charitable event holds a standard airworthiness certificate.

(5) Each aircraft used for the charitable event is airworthy and complies with the applicable requirements of subpart E of part 91 of this chapter.

(6) Each flight for the charitable event is made during day VFR conditions.

(7) The charitable organization is an organization identified as such by the U.S. Department of Treasury.

(e) A private pilot may be reimbursed for aircraft operating expenses that are directly related to search and location operations, provided the expenses involve only fuel, oil, airport expenditures, or rental fees, and the operation is sanctioned and under the direction and control of:

(1) A local, State, or Federal agency; or

(2) An organization that conducts search and location operations.

(f) A private pilot who is an aircraft salesman and who has at least 200 hours of logged flight time may demonstrate an aircraft in flight to a prospective buyer.

(g) A private pilot who meets the requirements of §61.69 may act as a pilot in command of an aircraft towing a glider or unpowered ultralight vehicle.

 

Thats a lot to chew on, so I highlighted the important part. If the passengers are paying for the ride, a private pilot cannot act as pilot in command. Oh, I should also take this time to point out that the FARs don't distinguish between a pilot ACTING as PIC and a pilot LOGGING PIC. Why? Because, you cannot log PIC unless you ACTED as PIC. And if there are passengers for hire, a private pilot cannot act as PIC.

 

I think thats enough for now...

 

Here's a poser for all y'all - do you need to be a CFI to sell PIC time to rated pilots in your aircraft while you ride along in the command seat?

 

That depends on what the pilot is rated in.

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