FAR 61.129 Instrument Training...

[randalrowles]

Hello All,

 

I'm looking for your professional opinions regarding the current instrument training requirement in accordance with FAR 61.129. As it stands, an applicant for the FAA CPL only needs to accomplish the required 10 hours of instrument training in an aircraft. This would allow a helicopter pilot to fly the 10 hours in an airplane even though they may not hold an airplane rating.

 

Question: Do you feel that the 10 hours of instrument training for the FAA CPL Helicopter I/A/W FAR 61.129 should be required to be conducted in a helicopter?

 

In addition, the maneuvers and standards for the 10 hours were loosely outlined by John Lynch in the FAQs sometime ago. The direction from Mr. Lynch was the standard was the Instrument PTS. This made no sense to me. If the FAA truely expects the applicant to meet the Instrument PTS, why do they require 40 hours for the Instrument rating? Anyway, a simple text change would fix this issue if they just used the same guidance given in the PPL Airplane requirements.

 

FAR 61.109 PPL Airplane states: 3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight".

 

This guidance is clear and concise to the training to be conducted.

 

Question: Do you feel that the instrument training requirement I/A/W FAR 61.129 CPL Helicopter should change its requirement text to a similar requirement text of FAR 61.109 PPL Airplane?

 

Lastly, the FAA has decided that the instrument training required I/A/W FAR 61.129 CPL Helicopter must be conducted by a CFII. This is contrary to the privileges and limitations of a CFI because the CPL Helicopter is limited to VFR.

 

Now, don't misunderstand my intent. I would love to see ALL helicopter pilots receive their instrument training from a CFII if for no other reason that they can use the time toward their instrument rating dual requirement. My intent is to fix regulatory issues that either do not make sense, provide no safety benefit to the industry, or are contrary to the regulations.

 

Question: Do you feel that a CFII must conduct the instrument training I/A/W FAR 61.129 CPL Helicopter requirements as they are currently written?

 

If you wish to participate, please email your response to the above questions to rrowles@bellhelicopter.textron.com with your name, certificates held, and how long you have been a flight instructor.

 

Your responses will be utilized as data to be presented to the FAA at Heliexpo 2007 in Orlando. More information is available to those that respond.

 

Thanks in advance!

 

Randy Rowles

[jet trash]

Randy,

 

Question for you. In this FAR, it states "(i) 10 hours of instrument training in an aircraft; ".

 

My question for you is, can this be accomplished in a FTD or Simulator, such as the Flyit?

 

Also do you have the link for The FAR interpretation by Mr. Lynch?

 

Thanks

[Jeff]

Randy,

 

I sent you a response.

 

Jeff

[joker]

Oh well. Such good questions and no one is responding openly!

 

So here is my take on it all! Not necessarily what people may want to hear, so hopefully some good fuel for discussion.

 

Joker

 

Summary of what I put to Mr. Rowles

 

Question: Do you feel that the 10 hours of instrument training for the FAA CPL Helicopter I/A/W FAR 61.129 should be required to be conducted in a helicopter?

 

Yes and no! Some of it should be conducted in the same category of aircraft. However, not all of it needs to be in the same category of aircraft. Maybe 5 hours only needs to be done in a helicopter for a CPL(H).

 

Question: Do you feel that the instrument training requirement I/A/W FAR 61.129 CPL Helicopter should change its requirement text to a similar requirement text of FAR 61.109 PPL Airplane?

 

No! I think this wording is deliberate and differentiates the different level of knowledge and understanding and the different areas of focus at those two different levels. The PPL requirement focuses on aircraft handling and control with reference to instruments and some of the navigation equipment and facilities available to pilots in / or not in IMC. These are mainly there as a ‘self-rescue’ skills.

 

The CPL requires a more detailed understanding of the equipment and procedures available for navigation and the IFR system in general. This ‘higher’ level of knowledge and understanding builds on the ‘introduction’ given to the PPL(A) pilot as a natural and necessary progression.

 

Question: Do you feel that a CFII must conduct the instrument training I/A/W FAR 61.129 CPL Helicopter requirements as they are currently written?

 

No! The regulations do not require any of the training to be covered in IMC or on an IFR flight plan. There is no reason why a CFI cannot therefore master the skills and understanding to a level appropriate for the CPL pilot thus relinquishing the need for a CFII to instruct that portion of the CPL course.

Edited January 3, 2007 by joker

[randalrowles]

I cannot give you a link for John Lynch and the FAQ's as the FAA no longer recognizes Mr. Lynch's responses as FAA guidance. The FAA has removed Mr. Lynch's site from public domain and issued a statement that directs all interpretations of regulation either to your FSDO or AGC-1 (Office of General Cousel).

 

I can provide an answer though to your question. FAR Part 1 defines aircraft as "a device that is used or intended to be used for flight in the air". The position of the FAA has been when the term aircraft is used, it must be in-flight. So the answer would be "no, you cannot use an FTD or Simulator to conduct the 10 hours of Instrument Training I/A/W FAR 61.129 toward the CPL Helicopter certificate". This is also our guidance when reviewing a application for said examination as a DPE.

 

I hope this helps.

 

Randy Rowles

 

Randy,

 

Question for you. In this FAR, it states "(i) 10 hours of instrument training in an aircraft; ".

 

My question for you is, can this be accomplished in a FTD or Simulator, such as the Flyit?

 

Also do you have the link for The FAR interpretation by Mr. Lynch?

 

Thanks

[jet trash]

I cannot give you a link for John Lynch and the FAQ's as the FAA no longer recognizes Mr. Lynch's responses as FAA guidance. The FAA has removed Mr. Lynch's site from public domain and issued a statement that directs all interpretations of regulation either to your FSDO or AGC-1 (Office of General Cousel).

 

I can provide an answer though to your question. FAR Part 1 defines aircraft as "a device that is used or intended to be used for flight in the air". The position of the FAA has been when the term aircraft is used, it must be in-flight. So the answer would be "no, you cannot use an FTD or Simulator to conduct the 10 hours of Instrument Training I/A/W FAR 61.129 toward the CPL Helicopter certificate". This is also our guidance when reviewing a application for said examination as a DPE.

 

I hope this helps.

 

Randy Rowles

 

thanks randy, i really appreciate it.