Commercial rating hour requirements question???

[joeschmoeheli]

This might be a stupid question but do your XC and solo hours that were required for your PPL in rotorcraft carry over to your Commercial? For example: you need a solo XC flight for your PPL, Does this count towards your COMM too or do you have to log another solo XC flight?

 

Also, the 20 hours of training related to 61.127( B )3 must be logged, does this mean that none of the PPL requirements transfer because the were training for 61.107 ( B )?

 

Is there anywhere that this is spelled out in plain english for me?

Edited December 20, 2008 by joeschmoeheli

[rick1128]

This might be a stupid question but do your XC and solo hours that were required for your PPL in rotorcraft carry over to your Commercial? For example: you need a solo XC flight for your PPL, Does this count towards your COMM too or do you have to log another solo XC flight?

 

Also, the 20 hours of training related to 61.127(B)3 must be logged, does this mean that none of the PPL requirements transfer because the were training for 61.107 (?

 

Is there anywhere that this is spelled out in plain english for me?

 

Welcome to the wonderful world of FAR's. Your hours do and do not transfer. The hours for your PPL are credited to the total hour requirements of the Commercial. However, the way 61.129 reads, the 20 hours of instruction must be for your Commercial and cover the items listed. I suggest a talk with your CFI on this.

[Jeff]

Just read the regulations. What Rick said about the 20 hours is subject to dispute. (You can find another thread where that subject was argued exhaustively.)

 

If the regs say you need a solo cross-country flight with ##-nm total distance and a leg that is at least ## nm from the point of departure, then if you can find a flight in your logbook that meets that requirement you can count it. If the FAA doesn't want something from a previous rating to count, then they will state it in the regs. A lot of people like to read into them requirements that don't exist, but that's not necessary.

 

~Jeff

[heli.pilot]

The XC flight requirements for the commercial certificate do read slightly differently to the XC flight requirements (or "parameters") for the private certificate. As a result, the XC you did for your private may not meet the requirements for your commercial. It would depend on exactly what you did for your private XC flight. I found myself taking a long XC flight the night before my commercial check ride because I didn't notice until the last minute that my XC flight for my private didn't quite fit the requirements for the commercial XC flight - I certainly could have planned that a little better, lesson learned. In terms of the 20 hours of training, most people will get there private somewhere around 50 hours PIC and their commercial at around 100 PIC - so there's 50 hours right there for most people to point at and say "that's my commercial training as related to 61.127".

[joeschmoeheli]

The 10 hours XC must be as PIC and since you are not PIC until after you recive your license then you must redo the XC requirements as PIC.

[rotormandan]

There was a huge debate on this a while ago. The 2 point of views are

 

1) If you have the flights logged then it meets they requirements regardless if it was pre or post private.

 

2) If flights are required by part 61.127 which are the commercial requirements then they are separate from the requirement under 61.107 which are private. A pre-req for the commercial rating is to have a private rating. Therefore you could not do a x-c required by 61.127 when working on your private even if the list of 61.127 and 61.107 are the same. The different part #s are what separates them.

 

I personally agree with the 2nd point of view but I guess it all comes down to what the local FSDO and your local DPE will accept. You have to build all that total time anyway so why not just do the flights.

Edited December 20, 2008 by rotormandan

[rotormandan]

The 10 hours XC must be as PIC and since you are not PIC until after you recive your license then you must redo the XC requirements as PIC.

 

 

Your solo time for your private rating was all PIC so those would definitely go towards your 100hr PIC requirement. Now if you believe that point of view 1 above is correct then you would not have to redo the x-c again if your solo x-c for private was long enough.

Edited December 20, 2008 by rotormandan

[Goldy]

The 10 hours XC must be as PIC and since you are not PIC until after you recive your license then you must redo the XC requirements as PIC.

 

Joe, if I am not PIC when flying solo as a student, who is ??

 

If you crash do you think the NTSB is going to list the PIC as "none". ???

 

Goldy

[joeschmoeheli]

Joe, if I am not PIC when flying solo as a student, who is ??

 

If you crash do you think the NTSB is going to list the PIC as "none". ???

 

Goldy

 

 

Not my point, I was refering to XC PIC hours not solo. The 35 PIC in helicopter and 10 hour XC PIC hours. So yeah, you can get about 10 hours PIC before your PPL but other than that you don't get any other PIC time until after your PPL.

 

Mainly what I'm trying to figure out is which of the two options given by rotormandan apply:

 

"1) If you have the flights logged then it meets they requirements regardless if it was pre or post private.

 

2) If flights are required by part 61.127 which are the commercial requirements then they are separate from the requirement under 61.107 which are private. A pre-req for the commercial rating is to have a private rating. Therefore you could not do a x-c required by 61.127 when working on your private even if the list of 61.127 and 61.107 are the same. The different part #s are what separates them."

 

 

This is for a student, not myself. I think in my training we went by the logic of #2 but I needed to get 200 hours in helicopters anyway so it didn't matter. In my students case, he has FW time and Helicopter time and just wants commercial and won't be flying robinsons and wants to do this in as little time as possible. I'm just trying to point him in the right direction.

 

 

SO, does 61.127 ( B ) 3 mean the student must recieve 20 hours training towards the commercial license?

Edited December 20, 2008 by joeschmoeheli

[rotormandan]

SO, does 61.127 ( B ) 3 mean the student must recieve 20 hours training towards the commercial license?

 

Once again in my opinion yes it does. I'm sure a few people here will tell you otherwise though. The 20 dual and 10 solo for 61.127((3) which applies to helicopters is required. (Post private in my opinion) That's only 30 pic towards the 35 pic required. With the 10 from private that's a whoppin' 5 hours extra. Pretty good if they can actually get in in the bare minimums. Once again though I'm sure you'll get a few different opinions so it all really comes down to your local FSDO and DPE. You should give them a call.

[Jeff]

Not my point, I was refering to XC PIC hours not solo. The 35 PIC in helicopter and 10 hour XC PIC hours. So yeah, you can get about 10 hours PIC before your PPL but other than that you don't get any other PIC time until after your PPL.

 

Mainly what I'm trying to figure out is which of the two options given by rotormandan apply:

 

"1) If you have the flights logged then it meets they requirements regardless if it was pre or post private.

 

2) If flights are required by part 61.127 which are the commercial requirements then they are separate from the requirement under 61.107 which are private. A pre-req for the commercial rating is to have a private rating. Therefore you could not do a x-c required by 61.127 when working on your private even if the list of 61.127 and 61.107 are the same. The different part #s are what separates them."

 

 

This is for a student, not myself. I think in my training we went by the logic of #2 but I needed to get 200 hours in helicopters anyway so it didn't matter. In my students case, he has FW time and Helicopter time and just wants commercial and won't be flying robinsons and wants to do this in as little time as possible. I'm just trying to point him in the right direction.

 

 

SO, does 61.127 ( B ) 3 mean the student must recieve 20 hours training towards the commercial license?

 

Joe,

 

61.129 ( c ) 3 states that one must log 20 hours of training in the areas listed in 61.127 ( b ) 3. The absolute minimum hours your student can get away with is 17 hours if he (or she) has a PPL Helicopter only. If there is an instrument rating involved, then 7 hours is the minimum. If this is a commercial add-on to an airplane rating, then there is the absolute minimum of seven (because some of the flight proficiency areas overlap with some of the airplane ones -- like navigation), but realistically it will probably take more than 20 hours if he has no helicopter experience.

 

As far as the rest of 61.129 ( c ) goes, the applicant must have all the listed hours logged in his logbook--period! It doesn't matter when the experience is obtained. The ONLY exception to that is specifically stated in 61.129 ( c )( 3 )( iv ), and that 3 hours of experience has to be within the 60 days prior to the practical test. If your student did his solo XC for his PPL, and it meets the requirements of the solo XC in 61.129, then it counts.

 

As an example, there is an instrument rating requirement for 50 hours PIC XC. It used to specify (when I got my intrument rating in 1987) that the 50 hours had to be experience obtained after the PPL. Today it doesn't say that. Therefore, one can surmise that it doesn't mater when you got the 50 hours, even if some of it was solo PIC prior to the PPL.

 

I suppose it is possible (though not recommeded) to take a PP ride one day and the CP ride later that day. Someone could come in with zero time, train to commercial pilot standards and requirements, making sure the student meets all the Private Pilot requirements too, take all the writtens, etc., then take the PP ride. After the successful completion of the PP ride, the examiner will issue a temporary PPL. The student now meets the final eligibility requirement for a CP. He can then take the CP checkride. I personally would never train somebody this way, but it is possible.

 

It seems that a lot of people like to add their opinions to the FAR's. This simply is not necessary. There are a few vaguarities here and there, but for the most part, FAR's are fairly simple to interpret. Keep in mind that the requirements for certification, as spelled out in Part 61, are minimum requirements only. The pilot must be trained to proficiency! And that minimum level is spelled out in the PTS.

 

~Jeff

[rick1128]

It seems that a lot of people like to add their opinions to the FAR's. This simply is not necessary. There are a few vaguarities here and there, but for the most part, FAR's are fairly simple to interpret.

~Jeff

 

Jeff,

 

Considering the number of 'Letters of Interpretation' the Legal Office of the FAA issues every year, IMO that statement is a little weak. According to FAA Lawyers I have known, they spend at least half their time writing these letters.

 

Unfortunately, one of the biggest problems is that many FSDO's make their own policies and interpretations and push these onto their DPE, operators, etc. without the benefit of council from FAA Legal. Which causes many of these different questions and answers that we find on these boards.

[rotormandan]

As an example, there is an instrument rating requirement for 50 hours PIC XC. It used to specify (when I got my intrument rating in 1987) that the 50 hours had to be experience obtained after the PPL. Today it doesn't say that. Therefore, one can surmise that it doesn't mater when you got the 50 hours, even if some of it was solo PIC prior to the PPL.

 

The 50 pic x-c for the instrument doesn't refer to another part like the commercial does. It is a general hour requirement so it can be done whenever just like the general hours required by (61.129(c))(1-2)(i-ii) 150 tt, 100 tt in aircraft, 50 tt in helicopters, 100 pic w/ 35 pic in helicopters and 10 x-c helicopters.

 

The 20 hours dual in a helicopter and 10 hours solo for commercial refer to a specific list of maneuvers under 61.127(b)(3) Which is very similar but still a completely different part than the private maneuvers under 61.107(b)(3)