Comm Rating

[iamtheari]

Considering that an instrument rating is category specific, I highly doubt that an ATP in an airplane implies that you’d have instrument privileges in a helicopter that you only have commercial privileges for.

That would also be my assumption. But it’s not everyday you run into someone with an ATP eggbeater license who can tell you for sure.

 

[mondtster]

That would also be my assumption. But it’s not everyday you run into someone with an ATP eggbeater license who can tell you for sure.

Perhaps I misunderstood what you were asking.

 

[iamtheari]

Perhaps I misunderstood what you were asking.

I believe you understood. It seems obvious, but sometimes what’s obvious isn’t necessarily correct, especially when the FAA gets involved. It’s really two questions:

1. Does an ATP certificate with one category rating imply commercial and/or instrument privileges in the categories you haven’t upgraded to ATP yet? (E.g., if you have an ATP in AMEL with lower level privileges in helicopters, do you have instrument and/or commercial privileges in helicopters? See 61.167(a)(1) for the privileges an ATP certificate confers.)

2. Can an ATP with one category rating add non-ATP ratings in other categories? (E.g., if you have an ATP in AMEL with lower level privileges in helicopters, can you add an instrument-helicopter rating to your lower privileges and/or upgrade from private to commercial in helicopters without going all the way up to ATP in them? See 61.165 for the requirements to add a rating to an ATP certificate.)

 

[Palmpilot]

In the case you cite, the FAA is not confused. You hold a commercial pilot certificate. The reason it says “Commercial Pilot” on the back under ratings is because that is a header. Everything under that header are the ratings you hold at the commercial level. There will be a “Private pilot” header under the ratings as well, and the ratings you hold at the private level, if you do not hold all ratings at the commercial level.

An ATP certificate with ratings at the commercial level would be far more common.

I think you're right.

 

[Pinecone]

Same thing as on my pilot certificate:

View attachment 112665

The reason it is listed that way is you could have some Ratings are the Commercial Pilot Certificate level and other Ratings at other levels.

So an aATP could be ATP for AMEL, but Commercial for ASEL, ASES, RH. And maybe even some at the Private level.

I hold Commercial Pilot Certificate with Commercial ASMEL, IA, RH, G, and Private level for ASES

 

[Pinecone]

If the FAA just called them licenses instead of certificates like common sense would dictate, then there would probably be much less confusion about ratings vs certificates/licenses...

There is a reason for the term.

In gov speak, a certificate has no expiration. A license does.

So if they called them licenses, you would have renewal requirements.

 

[sarangan]

Where are you getting that? According to 14 CFR 1.1, if it sets forth privileges on your pilot certificate, it's a rating.

"Rating means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations."​

On my pilot certificate, "Commercial Pilot" is listed under the heading, "Ratings."

This may seem pedantic, but if you are aspiring to be a CFI, you really need to pay attention to these subtle differences. You also need to be able to point to the relevant FARs instead of repeating what you have heard from others. For example, can you show that a CFI can instruct with BasicMed? This is not mentioned in plain words, but you should be able to find it. Another example, can you show that a safety pilot needs at least a 3rd class medical (that got changed a few weeks ago, but prior to that).

 

[DenverJayhawk]

For the OP, I used Shepard Air for the commercial written exam prep. Then get the ASA Commercial Oral Checkride book and read it end to end.

You will need to know a lot more than just O2 requirements. The commercial ticket is all VFR and the examiner will be evaluating your ability to safely plan and execute a flight. This makes sense after all, since they are giving you the privs for someone to pay you to fly for them. After some basic Commercial Priv questions from the FAR, my DPE mostly focused on the flight plan he had me prepare ahead of time. Then it was scenario based questions and what i would do when certain situations arose (altitudes, vfr rules, weather briefing, icing, sick passenger, etc.)

 

[midlifeflyer]

Another example, can you show that a safety pilot needs at least a 3rd class medical (that got changed a few weeks ago, but prior to that).

Well, partially changed anyway,

 

[mondtster]

I believe you understood. It seems obvious, but sometimes what’s obvious isn’t necessarily correct, especially when the FAA gets involved. It’s really two questions:

1. Does an ATP certificate with one category rating imply commercial and/or instrument privileges in the categories you haven’t upgraded to ATP yet? (E.g., if you have an ATP in AMEL with lower level privileges in helicopters, do you have instrument and/or commercial privileges in helicopters? See 91.167(a)(1) for the privileges an ATP certificate confers.)

2. Can an ATP with one category rating add non-ATP ratings in other categories? (E.g., if you have an ATP in AMEL with lower level privileges in helicopters, can you add an instrument-helicopter rating to your lower privileges and/or upgrade from private to commercial in helicopters without going all the way up to ATP in them? See 91.165 for the requirements to add a rating to an ATP certificate.)

I didn’t misunderstand, but that is probably the biggest stretch of the regulations I’ve seen in a while. Seems clear to me.

 

[Palmpilot]

The reason it is listed that way is you could have some Ratings are the Commercial Pilot Certificate level and other Ratings at other levels.

So an aATP could be ATP for AMEL, but Commercial for ASEL, ASES, RH. And maybe even some at the Private level.

I hold Commercial Pilot Certificate with Commercial ASMEL, IA, RH, G, and Private level for ASES

Understood.

 

[Palmpilot]

This may seem pedantic, but if you are aspiring to be a CFI, you really need to pay attention to these subtle differences. You also need to be able to point to the relevant FARs instead of repeating what you have heard from others. For example, can you show that a CFI can instruct with BasicMed? This is not mentioned in plain words, but you should be able to find it. Another example, can you show that a safety pilot needs at least a 3rd class medical (that got changed a few weeks ago, but prior to that).

Yes, I can show those things, but I have no plans to become a CFI. I couldn't force myself to read all the way through the FAA's Fundamentals of Instructing!

 

[DenverJayhawk]

Yes, I can show those things, but I have no plans to become a CFI. I couldn't force myself to read all the way through the FAA's Fundamentals of Instructing!

that one is brutal. I think the FAA makes it a weed out course. Shepard air is your savior for that exam.

 

[Palmpilot]

Well, partially changed anyway,

Can you elaborate?

 

[midlifeflyer]

Can you elaborate?

Safety pilots who were also acting as PIC could rely on BasicMed from the beginning. The recent change was to allow safety pilots who were not also acting as PIC to rely on BasicMed.

 

[IK04]

That would also be my assumption. But it’s not everyday you run into someone with an ATP eggbeater license who can tell you for sure.

Yeah, that's me: Mr. Example.

My ATP in both categories means that I am instrument rated in both Airplanes and Helicopters. Here's a twist: You can have a Commercial Certificate, Rotorcraft-Helicopter without an instrument rating. That would put a limitation on the card under the "Commercial Pilot" section...

 

[MauleSkinner]

You should know some general 135 aspects. Oxygen and duty hours for example. These were explored during my CPL Oral Exam.

135 Single engine VFR ops

If the examiner gets beyond “how do you identify a Part 135 operation so that you don’t do it,” he’s going off the reservation IMO.

 

[mondtster]

Yeah, that's me: Mr. Example.

My ATP in both categories means that I am instrument rated in both Airplanes and Helicopters. Here's a twist: You can have a Commercial Certificate, Rotorcraft-Helicopter without an instrument rating. That would put a limitation on the card under the "Commercial Pilot" section...

Personally, I think he was asking the wrong person. Holding an ATP in category/class already implies instrument privileges. So why would he ask someone who clearly has it a question about if someone without an ATP in helicopters has the ability to fly instruments in one just because they have instrument privileges in something else? That’s the part I don’t understand about the inquiry.

Out of curiosity, how often do you actually fly instruments in a helicopter anyway? I could see doing it in one that is reasonably stable but I’d rather see where I’m going.

 

[Palmpilot]

Safety pilots who were also acting as PIC could rely on BasicMed from the beginning. The recent change was to allow safety pilots who were not also acting as PIC to rely on BasicMed.

Agreed.

 

[sarangan]

Safety pilots who were also acting as PIC could rely on BasicMed from the beginning. The recent change was to allow safety pilots who were not also acting as PIC to rely on BasicMed.

I think the way that worked out was an oversight when basicmed was first introduced.

 

[IK04]

Out of curiosity, how often do you actually fly instruments in a helicopter anyway? I could see doing it in one that is reasonably stable but I’d rather see where I’m going.

Offshore Oil and Gas support with a two-pilot IFR helicopter is done every day, every flight. The weather does not care if you can see or not.

 

[iamtheari]

Yeah, that's me: Mr. Example.

My ATP in both categories means that I am instrument rated in both Airplanes and Helicopters. Here's a twist: You can have a Commercial Certificate, Rotorcraft-Helicopter without an instrument rating. That would put a limitation on the card under the "Commercial Pilot" section...

Better than Mr. Bad Example, stealing from the children's fund cash box and whatnot. (Just checked, and we don't have a POA smiley for rock and roll piano.)

Thank you. This mostly answers my question. They put a limitation on your ATP to deny you IFR privileges in the category you aren't rated to fly IFR. Does that mean that, absent such a limitation, an ATP in airplanes with commercial privileges in helicopters (like @RussR posted about in #30 above) carries IFR privileges in helicopters?

 

[mondtster]

Thank you. This mostly answers my question. They put a limitation on your ATP to deny you IFR privileges in the category you aren't rated to fly IFR. Does that mean that, absent such a limitation, an ATP in airplanes with commercial privileges in helicopters (like @RussR posted about in #30 above) carries IFR privileges in helicopters?

It does not appear that Russ has an instrument rating in a helicopter so why would he be able to exercise something he doesn’t have?

 

[Palmpilot]

I think the way that worked out was an oversight when basicmed was first introduced.

Yes, it was worded that way in the statute, and in order for the FAA to meet the implementation deadline, they had to copy the wording exactly. Now that there has been time to go through a notice-and-comment period, they have done so.

 

[dmspilot]

There is a reason for the term.

In gov speak, a certificate has no expiration. A license does.

So if they called them licenses, you would have renewal requirements.

Constantly amazed by all the dumb folk etymologies people are constantly coming up with, which are easily disproven with 60 seconds of research.

 

[Kritchlow]

Personally, I think he was asking the wrong person. Holding an ATP in category/class already implies instrument privileges. So why would he ask someone who clearly has it a question about if someone without an ATP in helicopters has the ability to fly instruments in one just because they have instrument privileges in something else? That’s the part I don’t understand about the inquiry.

Out of curiosity, how often do you actually fly instruments in a helicopter anyway? I could see doing it in one that is reasonably stable but I’d rather see where I’m going.

At one point in history you could get a rotorcraft ATP without instrument privileges. I assume those folks are grandfathered into the ATP somehow. Perhaps in the limitations it says rotorcraft VFR only??

 

[Eric Brunelle]

It all makes sense now.

 

[mondtster]

Thank you. This mostly answers my question. They put a limitation on your ATP to deny you IFR privileges in the category you aren't rated to fly IFR. Does that mean that, absent such a limitation, an ATP in airplanes with commercial privileges in helicopters (like @RussR posted about in #30 above) carries IFR privileges in helicopters?

Here’s what you’re after.

 

[midlifeflyer]

I think the way that worked out was an oversight when basicmed was first introduced.

The FAA agrees with you. That's why it was fixed.

I did an article for IFR Magazine a few years ago on safety pilot rules (no paywall). There's an update on the change scheduled for the February issue.

 

[RussR]

It does not appear that Russ has an instrument rating in a helicopter so why would he be able to exercise something he doesn’t have?

Russ definitely does not have an instrument-helicopter rating!

 

[RussR]

There is a reason for the term.

In gov speak, a certificate has no expiration. A license does.

So if they called them licenses, you would have renewal requirements.

My CFI Certificate definitely has an expiration date.

 

[WDD]

My CFI Certificate definitely has an expiration date.

Expiration of certificate? Or expiration of currency? (Such as with IFR rating, need for biannual for PPL, etc.)

If the CFI certificate expires, do you then need to take another check ride to get a new one?

 

[mondtster]

Expiration of certificate? Or expiration of currency? (Such as with IFR rating, need for biannual for PPL, etc.)

If the CFI certificate expires, do you then need to take another check ride to get a new one?

Yes they expire. And yes, taking a checkride is one way of renewing a flight instructor certificate.

 

[DenverJayhawk]

there is also a class you can take to renew your CFI cert.

 

[midlifeflyer]

Expiration of certificate? Or expiration of currency? (Such as with IFR rating, need for biannual for PPL, etc.)

If the CFI certificate expires, do you then need to take another check ride to get a new one?

Expiration of certificate. There are several renewal options, but in each case you get a brand new certificate with a new expiration date. There's periodically discussions to change that - renew the privileges rather than the certificate itself. You know how when you get dual the CFI signs with an expiration date? It's printed on the back of the certificate.

 

[midlifeflyer]

View attachment 112701

Constantly amazed by all the dumb folk etymologies people are constantly coming up with, which are easily disproven with 60 seconds of research.

It's not really dumb. Just the usual reality vs belief.

 

[WDD]

Yes they expire. And yes, taking a checkride is one way of renewing a flight instructor certificate.

Another belief I had that "certificates never expire" is busted. Turns out some don't, some do. I learn something new every day here. So I am justified in spending all these hours hanging out here on this forum.........

 

[DesertNomad]

Expiration of certificate? Or expiration of currency? (Such as with IFR rating, need for biannual for PPL, etc.)

If the CFI certificate expires, do you then need to take another check ride to get a new one?

if you let it expire, then you do need another checkride. If you renew before expiration, there are several different ways to renew such as a FIRC.

 

[Kritchlow]

Now I’m confused. My CFI “expired” in 1996, but according to several sources I still have a CFI certificate, but it’s not current (expired I guess).

The FAA registry still shows I hold the certificate. Some say it just needs to be renewed. I guess it’s all a play on words. Really doesn’t matter to me, as I never want to exercise CFI privileges again.

 

[sarangan]

The FAA agrees with you. That's why it was fixed.

I did an article for IFR Magazine a few years ago on safety pilot rules (no paywall). There's an update on the change scheduled for the February issue.

I am curious what your take on this is. Before the new proposed rule, a safety pilot with Basicmed also had to be PIC. By the same argument, I would have assumed that the a CFI with a Basicmed giving instrument instruction would also have to designated as PIC. But the language in 61.23 is a bit confusing. It says except when operating under Basicmed, a flight instructor needs a 3rd class medical when acting as PIC or as a required crewmember. That seems to suggest that the CFI is allowed to serve as required crewmember (not PIC) with Basicmed.