Commercial add-on

[DizzyD]

I have a question for the reg experts. When a commercial add on rating is added to an FW ATP can the requirements of FAR 61.127 be met by previous training conducted for the fixed wing ATP/IFR rating and recurrent training?

Sec. 61.127((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;

[kona4breakfast]

You're trying to get a commercial helicopter added to an airplane ATP?

[PitchLink]

Because the regulation specifically states 5 hours on the control and maneuvering of a helicopter, it must be conducted as such. In a helicopter, a helicopter FTD, SIM, or ATD. Simply put, your previous FW time will not count towards that requirement.

[DizzyD]

Thank you for the comments. This concerns a colleague and there is apparently some disagreement on this issue among the CFIs where he is training. It is noteworthy that the FAR states "This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device."

So if a desktop Elite ATD could suffice, why wouldn't the full motion G550 sim he just finished flying for recurrent training fulfill the requirement?

 

DD

[PitchLink]

Any time the regulation specifically states that a requirement must be accomplished in a helicopter, that's what it means. The regulation specifically says 5 hours on the control and maneuvering of a HELICOPTER. This requirement can be accomplished in a helicopter, helicopter SIM, helicopter FTD, or helicopter ATD. Each one of which will be issued a LOA by the Administrator stating what the device is approved for. They must be a representative of the equipment, panel, controls etc. of the appropriate category/class. A G550 is an airplane SIM, not a helicopter SIM and therefore would not be useful to fulfill that requirement.

[DizzyD]

Makes complete sense now, thanks for clarifying.

[rick1128]

That questions has been a sticker since it was issued. There were some FAA inspectors that said that the helicopter instrument rating does not count toward that requirement, even though the requirement items are all part of the instrument rating. Plus this regulation states 'aircraft' not 'helicopter' so it could be done in an airplane or blimp or simulation there of as long as the focus of the training is the operation of a helicopter for these items.

 

Clear as mud isn't it?