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Can i go directly to a commercial ticket and skip ppl if i am a ppl rated fixed wing?


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Hello all again, i have my fixed wing ppl, and i was under the impression that i can go directly for my commercial rotocraft license and skip the rotocraft ppl, because the commercial will trumph the ppl. so again as a rated fixed wing private pilot do i have to get a private helicopter add on before moving to commercial. Thanks everyone

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As 67N said, go through part 61. In a nutshell, yes you can go straight to commercial, the big kicker is the 50 hours of PIC RC time. Basically you spend about 50 hours flying around learning bad habits solo instead of training with an instructor. However, it may save you money in the long run. Our school offers a Commercial add on course with just this route.

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Actually, it's 35 hours PIC in helicopters (which would all have to be solo).

 

Then you have to add the dual to get you to solo, then commercial standards.

 

May or may not save you money in the long run. If you're damn good, it would. If you're average, you're not going to lose money, just PIC time. If you need the PIC time, you'd be better off getting the private first, then be able to log all that commercial prep as PIC.

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that goes into the forum down a bit on the page about logging time as a rated pilot between PIC and dual recieved or a combination of both. I am in that boat figuring out what to log as what because i am a rated pilot and have heard both that i can go straight to commercial and handle the requirements and others say a ppl in helicopters is a pre requisit to the commercial. I understand what you are saying delorean, but these things have sop many grey areas that it can drive you mad and you still have no clear cut answer and it all up to interpretation and what the examiner thinks when he sees your logbook.

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We have found out that each FSDO reads the regs differently. I know, some are going to say that regs are regs and they are what thry are. This is not true. The FAA has developed things called policy letters. The public may or may not be privy to these policies. They can bite you. Our FSDO says you canNOT log PIC toward a commercial rating until you are rated in the aircraft. The only time you can log PIC and not be rated is when you are a student pilot. We incountered this doing add ons to fixed wing. The fixed wing pilot is not considered a student pilot because he already has a rating. The helicopter is an addition to his rating. We sent a fixed wing ATP for the commercial ride. The examiner gave him the commercial ride and passed him. When the paperwork was submitted to the FSDO they kicked it back to a PPL and informed him he would have to take another commercial ride after he logged the additional PIC time. Needless to say, we kicked it up to Washington for an opinion. They said the FSDO was correct. Some FSDOs, we hear, have allowed the one ride. So, the long and short of it is, ask the FSDO directly.

bossman

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WARNING: As you see from Bossman's post below, he is sure that most of this post is not supported by both FSDO and Washington policy notice. Until we get to the bottom of this, consider those authorities (or your OWN FSDO) as more accurate!

In short, there are two ways you can add PIC time for your commercial add-on.

 

• Already hold a helicopter rating at the private pilot level. Then PIC flight time can be logged while flying solo and / or while manipulating the control as per § 61.51(e)(1)(i) when the flight instructor is on board; or

 

• Be the sole occupant of the aircraft and have a current solo endorsement in accordance with § 61.31(d)(3).

 

As someone mentioned, this kicks back to the issue of whether you can log all your dual time in persuit of your commercial as PIC. No you can't. You must meet one of the two scenarios above.

 

Here are the two arguments: Additional Helicopter Rating (Assuming many hrs of PIC in airplanes.) Remember, these are minimums.

 

A. Private then Commercial

 

Private = 20hrs Dual and 20 hrs Solo (PIC)

+Commercial still needed = 20hrs Dual and 15 hrs solo (PIC).

 

How to log PIC time during commercial Dual Lessons:

 

The solo time may be reduced as you can log the time in the commercial dual lessons which you were manipulating the controls as PIC. Let's say after your private, your instructor is on the controls for only 15 minutes an hour. That's 300 minutes (of the 20 hrs dual) you cannot log as PIC. The rest of your commercial dual time can be logged as PIC. Doing it this way, your commercial numbers are = 20hrs Dual (which include the 15hrs PIC). Hey presto! Your PIC requirements are covered. Add on the private requirements and your totals are: 60hrs, that's all.

 

B. Straight to Commercial Add-on

 

20hrs Dual and 35 hrs solo (PIC). = 55 hrs Total

 

(Note: As you are not yet rated, you CANNOT log any of your dual time as PIC like the example A above - You must do 35 hrs ON YOUR OWN). Bossman is this what your ATPL guy forgot?

 

You can go straight to commercial add-on checkride in 55hrs. However the chances of you being ready with just 20hrs of dual is rare. It is totally likely you'll need more dual time anyway.

So you are comparing a minimum of 60hrs (private then commercial) to a minimum of 55hrs (straight to commercial add-on) The first way gets you the rating with lots of dual. This is probably what most people need.

 

Thinking Reality!

 

There is a real possiblity that you will need say, 40hrs of dual to be ready for your commercial checkride.

 

Option A gets you your rating in the 60hrs listed above. Option B would require 75hrs. (40hrs Dual + 35hrs Solo PIC)

 

Lastly, if you have your private, about 75% of any additional hours you need (very likely) can be logged as PIC!

 

The bottom line: Get rated in the aircraft (private) as early as possible! (unless you are sh*t hot!)

Or you can do what my friend CofG suggests. Find a 141 Add-on course.

 

Someone check my numbers please...its ages since I've done this. Ready for flaming!

 

Your FSDO sound like a bunch of wierdos Bossman. (Or they are not telling you the whole story!)

 

Our FSDO says you canNOT log PIC toward a commercial rating until you are rated in the aircraft.

 

Unless you are solo surely? See option B above. Once you have been signed off with a 61.31(d) endorsement, you may fly solo and log PIC, although you are still not rated in the aircraft. In other words, you have been given the privilages required by, and may log as per 61.51(e)(1)(i)

 

The only time you can log PIC and not be rated is when you are a student pilot.

 

Not true. See above.

 

The fixed wing pilot is not considered a student pilot because he already has a rating.

 

Strictly speaking he is not considered a student pilot because he does not have a current solo flight endorsement as required under Sec. 61.87.

 

The helicopter is an addition to his rating.

 

I disagree. According to the list in 61.5(B) 'helicopter' is a separate category rating to 'airplane'. The helicopter is an addition to his certificate, not rating. (Did you mean this?)

 

Joker

Edited by joker
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Joker,

Yes addition to certificate. Washington says you are wrong on almost all your points. You cannot log time as PIC (toward your commercial) until you have the private license. Even if you are signed off for solo, you are still NOT RATED. I understand where you are coming from, your version was the way we initially read it, but Washington and the FSDO shot us down. The ATP fixed wing we sent for the ride had logged about 45 hours by himself. He had a total of about 65 hours dual and solo when he took the ride. He had to pay for another ride and log another 35 hours PIC after he received his PPL helicopter. We argued and protested everywhere we could think of, but to no avail. We even did the "well, other places are doing it", their response was that if it was brought to their attention they (Washington) would pull the certificates. You know after it was all said and done, when the guy got his license the second time they made him an ATP Helicopter. We shut up after that.

bossman

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Joker,

Yes addition to certificate. Washington says you are wrong on almost all your points. You cannot log time as PIC (toward your commercial) until you have the private license. Even if you are signed off for solo, you are still NOT RATED. I understand where you are coming from, your version was the way we initially read it, but Washington and the FSDO shot us down. The ATP fixed wing we sent for the ride had logged about 45 hours by himself. He had a total of about 65 hours dual and solo when he took the ride. He had to pay for another ride and log another 35 hours PIC after he received his PPL helicopter. We argued and protested everywhere we could think of, but to no avail. We even did the "well, other places are doing it", their response was that if it was brought to their attention they (Washington) would pull the certificates. You know after it was all said and done, when the guy got his license the second time they made him an ATP Helicopter. We shut up after that.

bossman

 

Man, that is messed up!!! Even John Lynch's Pt. 61 FAQs said that you could go straight to commercial. I guess that's why they pulled his FAQs off FAA.gov

 

Now, I've heard that they would not let you "kill two birds with one stone" by taking a 50+ mile solo x/c for your Private, then using it again for your commercial pre-reqs. You had to have two seperate x/c's--one for private, one for commercial.

 

We've had people in the past on this board who claimed they could log PIC time in ANY category (solo or dual) as long as they held ANY pilot certificate that was Private, commercial, or ATP. That's was obviously completely wrong, but plenty of people out there still do it.

 

Has anyone looked in the examiners handbook?? I just took the DPE written test and I swear it had a question about it on there.

 

One of the other things that FSDO specific, logging your first 10 hrs of R22 or R44 time for already rated helicopter pilots. SFAR 73 says you have to have 10 hrs of dual in R22/R44s before you can act as PIC. Our FSDO says you can't *act* as PIC, but you can *log* PIC since you are rated in category & class and you are the sole manipulator of the controls while undergoing dual instruction.

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Bossman,

 

As you will see, I have put a warning up on my previous post. Of course, FSDO and Washington take more precedence than my measly opinion. Nor do I distrust you.

 

Still, I can't help feeling that something is wrong! Either with the exact circumstances in which you ATPL guy was put forward (i.e. his particular case), or with their replies, or with how you have understood their replies or/and reported this case on the VR forum.

 

I have been through all the appropriate FAR carefully, particularly 61.51, 61.129, 61.63, 61.31, and can find nothing which is supportive of the notion that you cannot log time as PIC (toward your commercial) until you have the private license.

 

Joker

 

Delorean!

 

I am as confused as you are on the Add-on question.

 

As to your R22/44 question...thanks - Just when I thought I could go for lunch! Can you start a new thread for this? I'll then move my answer too.

 

Our FSDO says you can't *act* as PIC, but you can *log* PIC since you are rated in category & class and you are the sole manipulator of the controls while undergoing dual instruction.

 

Just because you are rated in category and class, does that make you rated in the aircraft? 61.51(e)(1)(i) asks for the pilot to be 'rated' in the aircraft. There is no mention of category or class in when logging PIC.

 

What about type ratings? You can hold the category and class, but still not be rated for say, multi-engine or an aircraft requiring additional type-specific training. (Correct me if I'm wrong.) Does the SFAR constitute a type rating? Indeed, 61.31 specifies the type rating requirements and additional training in order to 'serve/act' as PIC.

 

As I can find no definition of being 'rated for an aircraft', the authorisation to act as a crewmember is what I agree to constitute being 'rated' in an aircraft. For single pilot aircraft, that would mean a PIC endorsement and hold category and class ratings on your certificate. In otherwords, comply with 61.31(d), 61.31(h) and SFAR73-1 (2)(B)(1)(ii)

 

Until you have done 10hrs in the Robinson, you are not authorised to act as PIC. I would say thus, you are not rated in that aircraft (as required by 61.51(e)).

 

Thus I would say your FSDOs interpretation is dubious at best!

 

(Unless of course, your Awareness Training sign-off infers 'privilages'!!!)

 

Joker

Edited by joker
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Joker,

The instance I make reference to was in 2004. Send a question in to the FAA and see what the response will be. I'm going to do the same.

bossman

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Bossman,

 

 

This is because the crux of our question here is whether the 61.31(d)(3) 'Solo' endorsement constitutes the 'privilages' as required by 61.51(e)(1)(i)?

(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;]

 

 

When it says, "or has privileges," that is a reference to Sport Pilots only. You have to look at the intent of the rule when it was drafted. I think that is stated in the Federal Register, but I'm not sure. I saw it once but cannot remember where. Anyways, PIC time logged toward a PPL (in the case of the original poster) can be logged toward the PIC requirement for the CPL. And that is provided the PIC time is logged properly. If you have PIC (solo) privileges in a helicopter, but your certificate does NOT read "ROTORCRAFT-HELICOPTER" anywhere on it, you can only log PIC time for that time you are flying solo in the helicopter. The only time you can log PIC while receiving instruction in a helicopter is if you are rated (on your pilot certificate) in a helicopter and you are the sole manipulator of the controls.

 

To the original poster:

 

I recommend that you get your private helicopter add-on first, instead of going directly for a commercial add-on. The reason is that you have to build a lot of PIC time, so it's better to have your PPL so you can take friends with you. It's not quite as boring that way (assuming you might do a lot of cross-countries to build the PIC time).

 

Jeff

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Thanks Jeff,

 

When it says, "or has privileges," that is a reference to Sport Pilots only.

 

That would make sense.

 

Ok - Now I'm confusing myself....(as well as everyone).

 

What you have just said, is the same as what I put in post number 9! I think we are agreed on those points.

 

I confused matters in Post 12 regarding Bossman's assertion by asking it about the wrong FAR. In effect, I barked up the wrong tree whilst trying to parse Bossman's point.

 

OK

 

61.51(e)(1)(i) is agreed. If you go straight to commercial, you cannot log any dual time as PIC - you are not rated. However, by getting a PPL first, you can.

 

Bossman is saying that you cannot log any PIC towards your commercial add-on before you have a PPL in same category or class.

 

This would question 61.51(e)(1)(ii) instead.

 

(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--

(ii) Is the sole occupant of the aircraft;

 

This is where Bossman's statement seems to conflict. His statement implies that the above FAR is inapplicable if you are on a 'solo' endorsement and not rated in category and class. This is what sounds odd to me.

 

I am saying if you go solo then you must be able to log PIC and credit this towards the commercial add-on requirements (as per the above FAR). That's of course the point of the whole add-on thing!

 

My numbers and information in post 9 still stand (I think).

 

Sorry to confuse you all there. Previous post has been edited. Thanks for straightening me out on that...it is obviously WAAY to late to think about this kind of thing.

 

Joker

Edited by joker
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Seems crazy to disagree with a FSDO but I have to side with Joker and Delorean. How else do you explain Appendix 1 of AC 61-65E, Instructor Endorsements (Additional Endorsements)? #62. on pg 16 specifically details how to endorse a pilot "To act as PIC of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: section 61.31(d)(3)."

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Blave,

 

It all does sound a little odd. Just to clarify (and play devil's advocate ):

Remember we are talking about 'logging' the PIC time.

 

I think even Bossman, the goons in the FSDO and the monkeys in Washington agree that the 61.31(d)(3) 'solo' endorsement allows someone to act as PIC.

 

The question is whether it can be logged towards the commercial.

 

As mentioned relates to (and I think this must be allowed by) 61.51(e)(1)(ii).

 

I am ready too learn otherwise though.

 

Joker

Edited by joker
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Blave,

It is NOT crazy to disagree with a FSDO. We do it all the time.

Joker,

We got out the 2008 FARs today and the wording they kicked us on, we cannot find. So there may have been a change since 2004. I still submitted a formal question to the FAA web site. I'll let you know when they respond.

bossman

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  • 3 weeks later...

Just to make things more interesting and maybe cause more debate, go to page 6 of FAA-S-8081-16A, the Commercial Helicopter PTS.

Where it reads as a prerequisite:

"possess a private pilot certificate or meets the flight experience required for a private pilot certificate and pass the private helicopter or gyroplane knowledge and practical test;"

How does one read this?

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Anyone end up resolving this?

Got an answer from FAA Washington yesterday. They said ask your FSDO. It seems that it is up to each FSDO to do what they want in regards to this question. I have come to agree that you CAN go from private fixed wing to Commercial Helicopter, after taking and passing the commercial written. The wording that they kicked our student on has been dropped from the FARs. Taking the PPL Helicopter makes it easier to log the required PIC time with no questions asked.

Mike

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Where it reads as a prerequisite:

"possess a private pilot certificate or meets the flight experience required for a private pilot certificate and pass the private helicopter or gyroplane knowledge and practical test;"

How does one read this?

 

Nbit,

 

Can you provide the FAR reference for your quote above? I couldn't find it, and can't remember off-hand, and can't be bothered to trawl through. Nevertheless, it looks like an allowance for competent and proven AND acceptable pilots who do not have a FAA private certificate, to jump straight to the Commercial course. Examples of these would be, pilots trained in the millitary, pilots who's certificates have been revoked (if there are any) and foriegn trained pilots.

 

Still a FAR reference would have been nice.

 

 

Bossman,

 

Thanks for the information. That alludes to what we all have been saying all along. Check with your FSDO! I still think this is a cop-out by the FAA rep.

 

Joker

 

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Nbit,

 

Can you provide the FAR reference for your quote above? I couldn't find it, and can't remember off-hand, and can't be bothered to trawl through. Nevertheless, it looks like an allowance for competent and proven AND acceptable pilots who do not have a FAA private certificate, to jump straight to the Commercial course. Examples of these would be, pilots trained in the millitary, pilots who's certificates have been revoked (if there are any) and foriegn trained pilots.

 

Still a FAR reference would have been nice.

 

I *did* provide the reference - the quote did *not* come from an FAR, but from "page 6 of FAA-S-8081-16A, the Commercial Helicopter PTS", where the FAA seems to be interpreting the FARs for us.

Edited by nbit
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Nbit,

 

My apologies then. I see it now! In that case it makes sense then. (I was sure I hadn't seen this wording in the FAR, so was a bit confused.)

 

That paragraph is part of a section titled: Commercial Pilot Rotorcraft Practical Test Prerequisites found as you say in the PTS.

 

There is nothing really mysterious about this.

 

All it is saying is you must meet either of those requirements to take a commercial practical test.

 

Of course the most common method is for a pilot to have a private certificate, before doing a commercial checkride.

 

The second requirement -meets the flight experience required for a private pilot certificate- is included to accomodate military trained pilots. There may be other examples...too.

 

Hope that helps!

 

Joker

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