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Our local FSDO has released this interpretation of the new 61.129( c )3(1) for Commercial Aeronautical Experience:

 

The 5hrs (10hrs airplane) of instrument flight required for aeronautical experience towards a Commercial Rating must be obtained independently of training for an Instrument Rating. You must fly a specific 5hrs towards a Commercial Rating including attitude flying, instrument navigation, unusual attitude recovery and partial panel, and it does not have to be in an IFR aircraft, nor does it have to be with a CFII. Further, these 5 hours can count toward an Instrument Rating (but not vice versa).

 

We practice all of this ad nauseam during IR training, at least 5hrs worth.

How could the training for (and earning of) an Instrument Rating not satisfy the minimum instrument experience requirement for a Commercial Rating? I thought the point of the change was to specify type of aircraft, which makes complete sense.

 

A student with Private/Instrument Ratings was turned away from a commercial check ride this weekend based on this interpretation. It seems purely a matter of syntax - being able to point out where the time is logged as "Instrument/Commercial training".

 

This seems completely illogical. Am I missing something?? :huh:

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Heligirl,

 

Welcome to the Disney World of the FAA. There is nothing in the regulation that precludes you from getting the required instrument training of (3)c(i) during instrument training of any sort. If you look at the same section of the SE Airplane and ME Airplane, you will see that the applicant must have at least 5 of the 10 hours in the same Category and class aircraft as they're being tested in. The helicopter applicant is not so restricted.

 

Personally I would ask your FSDO to show where it is in the regs. They are way off base. Another option would be to write FAA Legal and ask for their interpretation. Interpretations issued by Legal are the only ones that have any force of 'law' behind them.

 

I also find it interesting that they are saying it doesn't have to be an IFR aircraft. How can you flight on instruments if you don't even have a needle and ball?

 

Our local FSDO has released this interpretation of the new 61.129( c )3(1) for Commercial Aeronautical Experience:

 

The 5hrs (10hrs airplane) of instrument flight required for aeronautical experience towards a Commercial Rating must be obtained independently of training for an Instrument Rating. You must fly a specific 5hrs towards a Commercial Rating including attitude flying, instrument navigation, unusual attitude recovery and partial panel, and it does not have to be in an IFR aircraft, nor does it have to be with a CFII. Further, these 5 hours can count toward an Instrument Rating (but not vice versa).

 

We practice all of this ad nauseam during IR training, at least 5hrs worth.

How could the training for (and earning of) an Instrument Rating not satisfy the minimum instrument experience requirement for a Commercial Rating? I thought the point of the change was to specify type of aircraft, which makes complete sense.

 

A student with Private/Instrument Ratings was turned away from a commercial check ride this weekend based on this interpretation. It seems purely a matter of syntax - being able to point out where the time is logged as "Instrument/Commercial training".

 

This seems completely illogical. Am I missing something?? :huh:

Edited by rick1128
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I also find it interesting that they are saying it doesn't have to be an IFR aircraft. How can you flight on instruments if you don't even have a needle and ball?

 

Well, as far as I remember the FAR just states IFR is "that flight time that is accomplished by sole reference to the instruments" - doesn't tell you which instruments you have to use. Speaking of odd interpretations... :P

As far as their interpretation goes that it "doesn't have to be accomplished in an IFR aircraft" I assume that they are refering to "it doesn't have to be an IFR certified aircraft", i.e. your trusty old Schweizer or R-44 would do the job. Preferably with the required instruments of 91.205(d), of course ;)

 

Other than that this FSDO's interpretation is REALLY odd. I second Rick's advice to write the FAA, I'm pretty sure that's not what they meant when they wrote it in there.

Edited by Hawkeye0001
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My guess is that the "reasoning" here is, that this training should be part of your commercial _training_

 

For example, they probably don't want the 5 hours of IFR flying that you did back in 1984 in an old Cessna to count towards your Commercial Helicopter training in 2010, which is understandable. My guess is that with that same reasoning, they won't accept any Instrument training time that has not specifically been logged as part of commercial training.

 

This can probably be fixed by maintaining proper, seperate training records for IFR and Com, and specifically logging those 5 hours as Commercial IFR training in your Com training records. Obviously, the 5 hours must then be done AFTER the Commercial training record has been started.

Edited by lelebebbel
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My guess is that the "reasoning" here is, that this training should be part of your commercial _training_

 

For example, they probably don't want the 5 hours of IFR flying that you did back in 1984 in an old Cessna to count towards your Commercial Helicopter training in 2010, which is understandable. My guess is that with that same reasoning, they won't accept any Instrument training time that has not specifically been logged as part of commercial training.

 

This can probably be fixed by maintaining proper, seperate training records for IFR and Com, and specifically logging those 5 hours as Commercial IFR training in your Com training records. Obviously, the 5 hours must then be done AFTER the Commercial training record has been started.

 

If you read the reg carefully, there is no restriction on when this training has to done. Further more, it doesn't even have to be done in a helicopter at all.

 

Personally, I would write to FAA Legal and request a Letter of Interpretation on this. Then when the FSDO gets all high and mighty, show them the letter. I talked with my POI yesterday and his comment was 'WHAT?'. But it is a standard case of FAA standardization. I you ask 10 FAA guys for an interpretation, you'll get at least 20 different answers.

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Since we're on the IFR subject. Is 'simulator' time PIC? :huh:

 

Short answer is no.

 

For the reasons listed below, and what you train in is not a simulator. It is a flight training device. Unless you go to a 142 program that utilizes a true flight sim.

 

 

61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

 

(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

 

(ii) When the pilot is the sole occupant in the aircraft;

 

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

 

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

 

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

 

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

 

( 1 ) Preflight preparation;

 

( 2 ) Preflight procedures;

 

( 3 ) Takeoff and departure;

 

( 4 ) In-flight maneuvers;

 

( 5 ) Instrument procedures;

 

( 6 ) Landings and approaches to landings;

 

( 7 ) Normal and abnormal procedures;

 

( 8 ) Emergency procedures; and

 

( 9 ) Postflight procedures;

 

© The supervising pilot in command holds—

 

( 1 ) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

 

( 2 ) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

 

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.

 

(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

 

(3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

 

(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 solo flight endorsement as required under §61.87 of this part; and

 

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

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If you read the reg carefully, there is no restriction on when this training has to done. Further more, it doesn't even have to be done in a helicopter at all.

 

 

 

 

I am aware of that. I am merely guessing where the FAAs interpretation of the rules differs from what we read.

 

I have come across a similiar problem with the night flight time required for a commercial license. The question there was, can the night cross country flight you do for your private license count towards the night requirements for a CPL if it met the distance requirements?

 

The interpretation we got was: "no, because the flight you did was a night training flight for a private license. To count towards the requirements for a commercial license, the flight has to be done and logged specifically as part of your commercial training. Do another night XC."

 

Personally, I would write to FAA Legal and request a Letter of Interpretation on this.

 

I agree.

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We have all along been given the same interpretation as lelebebbel for the night x-c but no one ever disputed the fulfillment of the IFR requirement by IR training until now.

 

So, here are the nuts and bolts of the explanation (as previously outlined by lelebebbel):

 

The first two sets of requirements (1 and 2, in BOLD) are the overall requirements to be eligible for Commercial Certification. The second two sets of requirements (3 and 4, in ITALICS, including the IFR and night x-c) are the aeronautical experiences that must be accomplished specifically during training for Commercial Certification. The distinction is made by the underlined wording, specifying that the training listed must be done under THIS part, no other.

 

My only problem with this is that the location of the IFR requirement hasn't changed yet the interpretation has...

 

Not that the indecision surprises me :P

____________________________________________

 

61.129

( c) For a helicopter rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with a rotorcraft category and helicopter class rating must log at least 150 hours of flight time as a pilot that consists of at least:

 

(1) 100 hours in powered aircraft, of which 50 hours must be in helicopters.

 

(2) 100 hours of pilot-in-command flight time, which includes at least—

(i) 35 hours in helicopters; and

(ii) 10 hours in cross-country flight in helicopters.

 

(3) 20 hours of training on the areas of operation listed in §61.127( b )(3) of this part that includes at least—

(i) Five hours on the control and maneuvering of a helicopter solely by reference to instruments using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device;

(ii) One 2-hour cross country flight in a helicopter in daytime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure;

(iii) One 2-hour cross country flight in a helicopter in nighttime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure; and

(iv) Three hours in a helicopter with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

 

(4) Ten hours of solo flight time in a helicopter or 10 hours of flight time performing the duties of pilot in command in a helicopter with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph ( c)(2) of this section), on the areas of operation listed under §61.127( b )(3) that includes—

(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).

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We have all along been given the same interpretation as lelebebbel for the night x-c but no one ever disputed the fulfillment of the IFR requirement by IR training until now.

 

So, here are the nuts and bolts of the explanation (as previously outlined by lelebebbel):

 

The first two sets of requirements (1 and 2, in BOLD) are the overall requirements to be eligible for Commercial Certification. The second two sets of requirements (3 and 4, in ITALICS, including the IFR and night x-c) are the aeronautical experiences that must be accomplished specifically during training for Commercial Certification. The distinction is made by the underlined wording, specifying that the training listed must be done under THIS part, no other.

 

My only problem with this is that the location of the IFR requirement hasn't changed yet the interpretation has...

 

Not that the indecision surprises me :P

____________________________________________

 

61.129

( c) For a helicopter rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with a rotorcraft category and helicopter class rating must log at least 150 hours of flight time as a pilot that consists of at least:

 

(1) 100 hours in powered aircraft, of which 50 hours must be in helicopters.

 

(2) 100 hours of pilot-in-command flight time, which includes at least—

(i) 35 hours in helicopters; and

(ii) 10 hours in cross-country flight in helicopters.

 

(3) 20 hours of training on the areas of operation listed in §61.127( b )(3) of this part that includes at least—

(i) Five hours on the control and maneuvering of a helicopter solely by reference to instruments using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device;

(ii) One 2-hour cross country flight in a helicopter in daytime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure;

(iii) One 2-hour cross country flight in a helicopter in nighttime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure; and

(iv) Three hours in a helicopter with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

 

(4) Ten hours of solo flight time in a helicopter or 10 hours of flight time performing the duties of pilot in command in a helicopter with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph ( c)(2) of this section), on the areas of operation listed under §61.127( b )(3) that includes—

(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).

 

First of all, it appears that there are Inspectors that are forcing their interpretation of the regs on the area of their authority. If you take their interpretation literally, then the 150 hours would have to be done after the applicant finishes the Private. And that is not the case. Several years ago, it was possible to get a Commercial without getting the Private. When the prerequisites were changed, the reg itself was not significantly changed. Someone is reading things between the lines that is not there. No where in 61.129 does it state that these requirements are over and above the Private requirements. Just that they must be done prior to the issuance of the Commercial.

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