61.129 Commercial instrument time

Walboy said:
You and I must come from different worlds.

I guess it's personal integrity for me.
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What does integrity have to do with making corrections to your own logbook? Wouldn't corrections give it more integrity (not less)?
 
I’ll correct my own mistakes. But adding something to a CFII note with a signature, without his or her approval or additional signature, doesn’t seem right.
 
dmspilot said:
What does integrity have to do with making corrections to your own logbook? Wouldn't corrections give it more integrity (not less)?
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I guess this is our disconnect, I thought the logbook belonged to an applicant (not me) for a commercial checkride and I'm the recommending instructor and another CFII's entry is being changed.

That said, I still wouldn't change training entries in my own logbook without consent from the CFI whose signature appears.

What's the reason the FAA requires signatures when training is given? What's to stop an applicant from embellishing actual training when there's a deficiency at checkride time?

Integrity.
 
Matthew said:
I’ll correct my own mistakes. But adding something to a CFII note with a signature, without his or her approval or additional signature, doesn’t seem right.
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DPEs making up ridiculous requirements for logging time doesn't seem right either. Why stop with one requirement? Why doesn't every training flight need to cite a regulation by section and subparagraph?
 
Walboy said:
I guess this is our disconnect, I thought the logbook belonged to an applicant (not me) for a commercial checkride and I'm the recommending instructor and another CFII's entry is being changed.

That said, I still wouldn't change training entries in my own logbook without consent from the CFI whose signature appears.

What's the reason the FAA requires signatures when training is given? What's to stop an applicant from embellishing actual training when there's a deficiency at checkride time?

Integrity.
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I wasn't aware that corrections and embellishment were ethically equivalent.
 
dmspilot said:
I wasn't aware that corrections and embellishment were ethically equivalent.
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I'm wondering what an examiner's reaction would be as he watches you "correct" the record in person upon discovery of a deficiency.

Our sense of right and wrong are different. Nothing more I can add.
 
Walboy said:
Our sense of right and wrong are different.
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How did you conclude that? I asked a question. When did I do something you consider to be "wrong"?
 
As with most things, whether a change/modification/embellishment/addendum is ethical or not is really dependent on the specifics. Case by case basis.

If I write in the logbook that we did 3 approaches, and the student later changes it to an 8, yes, that's a problem.

But if he adds a comment "first actual IMC, got the leans real bad", then I don't think there's any ethical problem at all. It's his logbook, his entry.

Of course, most things are somewhere in the middle.

As @midlifeflyer points out, this is one of the areas where "proper" electronic logbooks and signatures are more secure, nothing can be changed without the CFI's approval.
 
dmspilot said:
How did you conclude that? I asked a question. When did I do something you consider to be "wrong"?
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I think he's just thinking that making changes to a document after it is signed by someone else for verification purposes fits most criminal forgery statutes definition.

Except... the alteration needs to be false/fraudulent to fit within most statutes (and FAR 61.59).

So, it would not be "wrong" to clarify an entry with a correction (I actually did that by adding PIC time to my complex and high performance trainings). Changing the 61.51(h) descriptions of training received which has been previously endorsed may or may not be "fraudulent", but I would not blame a DPE who was able to detect that an unendorsed change was made, reject it without some verification from the instructor.

People talk all the time that "it's my logbook." Yeah, but it's also your official record of qualification and currency, including that "description of the training given" endorsed "by the authorized instructor" with "the authorized instructor’s signature, certificate number, and certificate expiration date."
 
RussR said:
??? I literally mentioned the military conversion scenario in the post you responded to, and quoted.



That's moving the goalposts (I think, I always get those sayings wrong). Your statement was that it's possible to get a Commercial without first having a Private, which is explicitly not true, except in military conversion (or foreign conversion) cases, which is not relevant to any of the preceding discussion about 61.129 requirements.
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I did say sort of. :)

Yes, you are correct that you cannot get a Commercial without any Private, except for Military. Happy???????
 
@midlifeflyer, how does the Gordon_2006_Legal_Interpretation.pdf fit in with the 2010 Theriault and Hartzell letters? Conceptually, I think the first answer re: one flight satisfying both requirements contributes to Hartzell, but is at odds with the 2010 Theriault. Am I missing something?
 
TCABM said:
@midlifeflyer, how does the Gordon_2006_Legal_Interpretation.pdf fit in with the 2010 Theriault and Hartzell letters? Conceptually, I think the first answer re: one flight satisfying both requirements contributes to Hartzell, but is at odds with the 2010 Theriault. Am I missing something?
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The aeronautical experience requirements for certificates and ratings come in two types. The distinction between them is the phrase "on the areas of operation." The regs use that phrase to denote that the experience is specific to the certificate or rating being sought and it's that phrase the Chief Counsel has repeatedly used as the basis of their "double dip" interpretations.

For example, "50 hours of cross country flight time as PIC" doesn't say "on the areas of operation" of a section, so it's generic flight time. It doesn't matter when or where you got so long as it meets the applicable cross country definition and you were entitled to log it as PIC. Even your student solo cross countries count.

OTOH, going back to Theriault and Hartzell, they deal with a 61.129 instrument training requirement that is part of "20 hours of training on the areas of operation listed in §61.127(b)(1)..." Thus, according to the interpretations, they are specific to the certificate or rating being sought in some way.

You can see that at work in Theriault although its application in that context is ridiculous. Don't look for too much logic in Hartzell. Arguably, it's really just a walk-back work around from the ridiculousness of Theriault (although the concept exists elsewhere).
 
midlifeflyer said:
The aeronautical experience requirements for certificates and ratings come in two types. The distinction between them is the phrase "on the areas of operation." The regs use that phrase to denote that the experience is specific to the certificate or rating being sought and it's that phrase the Chief Counsel has repeatedly used as the basis of their "double dip" interpretations.

For example, "50 hours of cross country flight time as PIC" doesn't say "on the areas of operation" of a section, so it's generic flight time. It doesn't matter when or where you got so long as it meets the applicable cross country definition and you were entitled to log it as PIC. Even your student solo cross countries count.

OTOH, going back to Theriault and Hartzell, they deal with a 61.129 instrument training requirement that is part of "20 hours of training on the areas of operation listed in §61.127(b)(1)..." Thus, according to the interpretations, they are specific to the certificate or rating being sought in some way.

You can see that at work in Theriault although its application in that context is ridiculous. Don't look for too much logic in Hartzell. Arguably, it's really just a walk-back work around from the ridiculousness of Theriault (although the concept exists elsewhere).
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Still trying to get my head around this: If training in “areas of operation” apply to 61.129, do they NOT apply to the instrument training? Or is it a one way street: hours that count towards commercial also count towards the instrument rating but not the other way around?

I guess I’m not alone in trying to understand the FAA requirements and explanations on this topic.
 
It would be simple for the FAA to fix this.

"Unless the applicatn already possesses an Instrument Rating Airplane, they must ........"

It makes no sense to have someone with an Instrument Rating do additional instrument training for the Commercial.
 
Matthew said:
Still trying to get my head around this: If training in “areas of operation” apply to 61.129, do they NOT apply to the instrument training? Or is it a one way street: hours that count towards commercial also count towards the instrument rating but not the other way around?

I guess I’m not alone in trying to understand the FAA requirements and explanations on this topic.
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Don't try too hard. You'll get a headache. It's a bit artificial.

I think the clearest explanation of the theory comes from the 2011 Murphy interpretation, which looks at 61.109 and 61.129.

The 61.129 commercial requirements includes a 2-hour dual cross country. 61.109 requires dual cross countries for the private certificate. So, why not kill two birds with one stone. Do a 2-hour dual cross country for the private certificate and be done with both requirements.

No, says the FAA. You can read their reasoning in Murphy but, to me it comes down to this. If you look at the areas of operation list, they look the same. But it's not about the list of tasks; it's about the level of competence at which the tasks and training are supposed to be performed

Because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards, the type of training contemplated by § 61.129(a)(3)(iii) is not interchangeable with the kind required for a private pilot certificate. Accordingly, any cross-country training experienced by a student pilot would not be credited toward the requirements of § 61.129(a)(3)(iii). - Murphy.​

Basically, the regulatory concept is that a commercial pilot applicant (who already has their private) is expected to be performing at a higher standard of knowledge, skill, and competence than that expected of a student pilot working on the private. If you want to hire a master chef for your five star restaurant, you are looking for a higher standard of cooking compete than the guy or gal frying hamburgers at McDonalds.

That's really all it comes down to. And the FAA has been very consistent in applying it.

Does it make sense in reality? If I'm training a commercial pilot, is there anything (other than my own standards) that requires me to treat the cross country any different than I would with a student pilot? Not really. The theory is aspirational - I should be treating the 61.129 cross country differently; giving the commercial applicant a more complex in-flight scenario, but nothing forces me to. There's really no way for the FAA to police it.

And as a number have said, in the instrument->commercial context it makes almost no sense at all. The instrument rating is one of the most difficult FAA pilot ratings to acquire. The commercial ASEL is a piece of cake in comparison. 10 hours of instrument training given to a non-instrument-rated pilot that doesn't require any knowledge of basic instrument procedures a "higher standard" than that required for the instrument rating? Nonsense.

But that's the FAA's theory. And having come up with it, they have been applying it pretty consistently. We don't have to agree with it in order to understand and apply it.
 
midlifeflyer said:
Don't try too hard. You'll get a headache. It's a bit artificial.

I think the clearest explanation of the theory comes from the 2011 Murphy interpretation, which looks at 61.109 and 61.129.

The 61.129 commercial requirements includes a 2-hour dual cross country. 61.109 requires dual cross countries for the private certificate. So, why not kill two birds with one stone. Do a 2-hour dual cross country for the private certificate and be done with both requirements.

No, says the FAA. You can read their reasoning in Murphy but, to me it comes down to this. If you look at the areas of operation list, they look the same. But it's not about the list of tasks; it's about the level of competence at which the tasks and training are supposed to be performed

Because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards, the type of training contemplated by § 61.129(a)(3)(iii) is not interchangeable with the kind required for a private pilot certificate. Accordingly, any cross-country training experienced by a student pilot would not be credited toward the requirements of § 61.129(a)(3)(iii). - Murphy.​

Basically, the regulatory concept is that a commercial pilot applicant (who already has their private) is expected to be performing at a higher standard of knowledge, skill, and competence than that expected of a student pilot working on the private. If you want to hire a master chef for your five star restaurant, you are looking for a higher standard of cooking compete than the guy or gal frying hamburgers at McDonalds.

That's really all it comes down to. And the FAA has been very consistent in applying it.

Does it make sense in reality? If I'm training a commercial pilot, is there anything (other than my own standards) that requires me to treat the cross country any different than I would with a student pilot? Not really. The theory is aspirational - I should be treating the 61.129 cross country differently; giving the commercial applicant a more complex in-flight scenario, but nothing forces me to. There's really no way for the FAA to police it.

And as a number have said, in the instrument->commercial context it makes almost no sense at all. The instrument rating is one of the most difficult FAA pilot ratings to acquire. The commercial ASEL is a piece of cake in comparison. 10 hours of instrument training given to a non-instrument-rated pilot that doesn't require any knowledge of basic instrument procedures a "higher standard" than that required for the instrument rating? Nonsense.

But that's the FAA's theory. And having come up with it, they have been applying it pretty consistently. We don't have to agree with it in order to understand and apply it.
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You're right, my head hurts.

How about the 61.65 IR cross country? That seems to meet the 61.129 requirements of "... instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems."

Except for the partial panel and unusual attitudes, I didn't do those on my IR XC. I can't remember how many hours my IR XC took, but that flight alone would make a big dent in that 10 for commercial.
 
Matthew said:
You're right, my head hurts.

How about the 61.65 IR cross country? That seems to meet the 61.129 requirements of "... instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems."

Except for the partial panel and unusual attitudes, I didn't do those on my IR XC. I can't remember how many hours my IR XC took, but that flight alone would make a big dent in that 10 for commercial.
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Hartzell says the CFII can indicate it meets the commercial requirement as well as the instrument rating one. Same for the unusual attitudes.
 
So to ask a slightly lower level question than the majority of this thread has dealt with, those 10 hours using a “view limiting device” have to include the prescribed tasks. So in theory, you could do all the tasks in, say, 2 hours, and just fly a straight line under the hood for the other eight, right?

And secondarily, why does the reg specify the VLD? Why can’t these tasks be accomplished in actual? I had multiple 2+ hour flights in the soup during training. Is that somehow LESS efficacious than with foggles on?
 
flyingpreacher said:
why does the reg specify the VLD? Why can’t these tasks be accomplished in actual?
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That is incredibly funny. I never noticed it before. So I guess 20 hours in actual during IR training doesn't automatically satisfy the "higher requirements" of 10 hours in VFR conditions! :D

WAG: It was supposed to say "in actual weather conditions, or under simulated conditions using a view-limiting device" but someone screwed up.
 
[QUOTE="flyingpreacher, post: 3456495, member: 49200"….
And secondarily, why does the reg specify the VLD? Why can’t these tasks be accomplished in actual? [/QUOTE]

Just put on a VLD in actual and be done with it.
 
midlifeflyer said:
That is incredibly funny. I never noticed it before. So I guess 20 hours in actual during IR training doesn't automatically satisfy the "higher requirements" of 10 hours in VFR conditions! :D

WAG: It was supposed to say "in actual weather conditions, or under simulated conditions using a view-limiting device" but someone screwed up.
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I think that clouds are certainly a "view limiting device", for certain liberal interpretations of the word "device".
 
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