Commercial Aeronautical Experience Question on 61.129

[robertb]

Hello all,
I am working on a commercial and have a question about 61.129. I have plenty of hours and am making sure I have sufficient training to meet 61.129. Mainly, section (a)(3)(iii) and (iv).

I am digging through my old logbooks looking to see what legitimate hours can be used to satisfy 61.129.

Since item (v) states “with an authorized instructor”, does than mean that (iii) and (iv) do not need an “authorized instructor” on board? Does a review of the flight plan, a brief and de-brief count as “training” even if the CFI was not onboard for the flight?

I have posed this question to my CFI and am awaiting a response. Just want to get the collective wisdom of the group in case I don't get the answer I want.

Thanks in advance!

For reference -

§ 61.129 Aeronautical experience.

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

(irrelevant sections removed for brevity)

(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least -

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

 

[RussR]

(3) says 20 hours of "training". This means with a CFI. Yes, the flights to meet (iii) and (iv) need to be with a CFI.

 

[Brad W]

my "not a CFI and not a lawyer" read on that is
a) the intention is that it's training with a CFI on board
b) but based on their language it might maybe be arguable (even if illogical) that the instruction from the CFI could be ground school...like a student pilot solo where the instructor is does ground school instruction before/after these 2-hour flights
c) the maybe bigger point of this is that the 2-hour instruction cross country flights could have been 5 years ago, but the three hours training must be within 2 months of the ride.

 

[midlifeflyer]

(3) says 20 hours of "training". This means with a CFI. Yes, the flights to meet (iii) and (iv) need to be with a CFI.

Yep. "Flight training with an authorized instructor" is a redundancy repeated many times in Part 61. There are a few others like it. There's even a "training" which does not involve an authorized instructor being in the airplane. Just bad drafting.

 

[midlifeflyer]

my "not a CFI and not a lawyer" read on that is
a) the intention is that it's training with a CFI on board

61.1. "Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft."

 

[robertb]

Thank you all for your responses, especially #midlifeflyer for the reference to 61.1. While it was not the answer I wanted, I see that trying to negotiate this one with a DPE would end badly for me. Looks like I need to find someplace 2 hours away to stop and have dinner with my CFI before flying back home at night.

 

[RussR]

Thank you all for your responses, especially #midlifeflyer for the reference to 61.1. While it was not the answer I wanted, I see that trying to negotiate this one with a DPE would end badly for me. Looks like I need to find someplace 2 hours away to stop and have dinner with my CFI before flying back home at night.

Remember, if you have one in the past, for example a new aircraft checkout where you flew to lunch or something, it very well may already qualify. Many clients I work with DO have the day dual XC already done for some other purpose, it's the night one that we need to do. Others, yes, we just fly somewhere for dinner and fly back at night. I makes sure to do some diversions and emergency and other scenarios enroute.

 

[jsstevens]

(3) says 20 hours of "training". This means with a CFI. Yes, the flights to meet (iii) and (iv) need to be with a CFI.

And have to be logged as meeting those requirements.

 

[unsafervguy]

if one point of your cross country for the instrument cross country was more than 100 miles way straight line, and it took 2hrs or more, one of those cross countries should be covered.

 

[samiamPA]

if one point of your cross country for the instrument cross country was more than 100 miles way straight line, and it took 2hrs or more, one of those cross countries should be covered.

Is this true? I've read differing opinions on this so I was not planning on counting it.

 

[unsafervguy]

Is this true? I've read differing opinions on this so I was not planning on counting it.

i cant find an interpretation that directly address that. Theriault somewhat address it, but does not cover that part. it does say that §61.129(c)(3)(i) is not covered by the training for an instrument rating. however, the reasoning given does not apply to §61.129(c)(3)(iii) really. here is what they say about 61.129(c)(3)(i)

The reason for this is that the training required under §61.65(e)
is general, while the training under §61.129(c)(3)(i) lists very specific operations that must
be accomplished to satisfy the requirements.
but (iii) is a very general statement, so can that argument be applied? to make it muddier, theriault was rescinded in pratt.

now to muddy it up further sun does point to the fact that you can.

https://www.faa.gov/about/office_or...nterps/2011/Sun_2011_Legal_Interpretation.pdf

your guess is as good as mine, the best bet would be to run it by the DPE before counting on it.

 

[midlifeflyer]

Is this true? I've read differing opinions on this so I was not planning on counting it.

The FAA generally frowns on double-dipping. I think it's possible in this case if, as @jsstevens said earlier, it is logged as meeting the requirements of both. The Chief Counsel's office said this in a letter where someone asked about whether having an instrument rating satisfied the commercial instrument training requirement.

But, you may well find different views on this within the DPE corps, so you may wat to check in advance. Nothing worse than going to a checkride and having the DPE say, "sorry, you don't meet the requirements."

 

[jsstevens]

The FAA generally frowns on double-dipping. I think it's possible in this case if, as @jsstevens said earlier, it is logged as meeting the requirements of both. The Chief Counsel's office said this in a letter where someone asked about whether having an instrument rating satisfied the commercial instrument training requirement.

But, you may well find different views on this within the DPE corps, so you may wat to check in advance. Nothing worse than going to a checkride and having the DPE say, "sorry, you don't meet the requirements."

I do know that mine was logged to specifically call out 61.129. Is that required? I don’t know but calling it out removes any question.

 

[Bonchie]

The FAA generally frowns on double-dipping. I think it's possible in this case if, as @jsstevens said earlier, it is logged as meeting the requirements of both. The Chief Counsel's office said this in a letter where someone asked about whether having an instrument rating satisfied the commercial instrument training requirement.

But, you may well find different views on this within the DPE corps, so you may wat to check in advance. Nothing worse than going to a checkride and having the DPE say, "sorry, you don't meet the requirements."

Good advice. Asking the DPE is the right call. I know I double-dipped on the IFR time for the commercial and that seems to be the default now, though you may find a DPE that still argues it.

Another thing to think about with the CPL is whether he is gonna do his 10 hours solo or with an instructor. I’ve always been told it’s got to be all one or the other. I also double dipped there with a previous long cross country and some night flying.

All this stuff is very DPE dependent. The one we send students to is very lenient in that he just wants to see the requirements met. Others may not be so easy going.

 

[midlifeflyer]

Another thing to think about with the CPL is whether he is gonna do his 10 hours solo or with an instructor. I’ve always been told it’s got to be all one or the other. I also double dipped there with a previous long cross country and some night flying.

Unlike the situation we were talking about, the rules that

1. The 10 hours solo or substitute solo with an instructor (PDPIC) all need to be accomplished the same way; and
2. PDPIC time is not dual received training time

are documented and not DPE-dependent (unless you come across the DPE who likes to make up their own).

 

[midlifeflyer]

I do know that mine was logged to specifically call out 61.129. Is that required? I don’t know but calling it out removes any question.

In the case of the IR/Commercial interpretation, yes, specifically saying it met both requirements was mentioned.

From 2010 Hartzel, I think the third letter to discuss it...

We are merely clarifying the requirement that the applicant for a commercial pilot certificate provide evidence that they have met the requirements of §61.129.There is not an exact equivalence between the training required for an instrument rating under §61.65 and the aeronautical experience requirements under §61.129.​

There is certainly more than one way to do this, but the shorthand of referring to the sections is the simplest.

 

[Rgbeard]

Hello all,
I am working on a commercial and have a question about 61.129. I have plenty of hours and am making sure I have sufficient training to meet 61.129. Mainly, section (a)(3)(iii) and (iv).

I am digging through my old logbooks looking to see what legitimate hours can be used to satisfy 61.129.

You and I are in the same boat.

I finally threw in the towel after digging through logs, and just made an appt with a CFI to fly from GYR to Brown and back. We'll take it slow to assure the 2hr mark.

It's frustrating after all these hours, cross-continent, day/night/VMC/IMC, solo, not-so-solo, to hang up on this snag.

 

[robertb]

You and I are in the same boat.

I finally threw in the towel after digging through logs, and just made an appt with a CFI to fly from GYR to Brown and back. We'll take it slow to assure the 2hr mark.

It's frustrating after all these hours, cross-continent, day/night/VMC/IMC, solo, not-so-solo, to hang up on this snag.

Agreed. I did a pair of 2 hour cross country flights last week. I own the plane and the CFI can use the money.