Commercial Certificate experience requirements- gotchas?

[Rgbeard]

I have had my PPL for more than 30 years, am Instrument rated, have over a thousand hours of experience, just under 20% is night time. Over 80% of my flight time is XC.

I have flown many times, cross-most-of-the-continent, and into Canada and Mexico, mostly with my wife, but more than a few times solo, with night and IMC in the mix. My 4-ish-hour range on the Lance is commonly around 700 to 800 nm Eastbound. (Just to be clear my wife is not an instructor nor a pilot, but I understand that solo means solo, except maybe for the dogs. Am I correct?)

I have seldom considered the Commercial certificate but it appears to me that I already have “the boxes checked” and simply need to pass the written and do the maneuvers. My doc said nothing would prevent me from having a second-class physical.

My motivation mostly stems from my exposure to some friends that buy/sell planes and sometimes need a pilot to relocate a plane. It seems that helping them, even if for zero dollars, skirts the commercial rules a little too closely for comfort.

So, why not go for it at some point? I have read 61.129 (a) and believe my experience is close to, if not already complete, but wonder, is there a common gotcha in there that I may have overlooked? Is there something I should do this year to be sure I don’t get caught short? Should I go back into my logs and write notes on some of my XC flights such as: “meets requirements of 61.129(a)(3)(iii)”?

May I ask the brain trust, what am I overlooking, missing or otherwise glossing over?

 

[RyanB]

You’ll most likely just need the 2-hr day and night dual cross country and the 10hrs of instrument training, assuming your instrument training wasn’t logged as meeting 61.129 (a)(3)(i).

Other than that, you should have everything else as far as requirements are concerned. Take written and do the maneuvers.

 

[Rgbeard]

You’ll most likely just need the 2-hr day and night dual cross country and the 10hrs of instrument training, assuming your instrument training wasn’t logged as meeting 61.129 (a)(3)(i).

Other than that, you should have everything else as far as requirements are concerned. Take written and do the maneuvers.

Being instrument rated would not, in and of itself, imply meeting the requirements of 61.129 a3i? Not trying to be argumentative, simply find it puzzling.

 

[tonycondon]

yes, solo is solo.

Dont mix/match PDPIC/Solo time. Watch the Takeoff AND Landing requirements at night. I've had a few come up short from flights where they took off during the day but landed at night.

2hr day & night XC's need to be post-Private Pilot training

Make sure you have some instrument training covering the areas listed in 61.129

 

[tonycondon]

Being instrument rated would not, in and of itself, imply meeting the requirements of 61.129 a3i? Not trying to be argumentative, simply find it puzzling.

Its a terminology thing. the areas of training required in 61.129 do not exactly match the training required in 61.65. In practice, they are done, but its not implicit because the regs don't match.

IMO you do not need 10 hours of training on 61.129 areas. you need 10 hours of instrument training and somewhere in that 10 hours you need to cover the 61.129 requirements. In reality its probably just a matter of making sure your logbook entries reflect the 61.129 wording

 

[Walboy]

I'd say you probably have an above average handle on requirements. Select which flight will count as your long solo X/C to show prospective CFI who will help you. Instrument instruction may be dicey depending how it was logged when you got your IR. There specific key words DPEs look for.

I'm sure some will disagree, but I would suggest getting a copy of Gleim's commercial flight maneuvers book and start thumbing through it. You'll likely spend most of your instruction time perfecting a couple of new maneuvers and tightening up your tolerances. All that is laid out pretty well in the Gleim book.

I did the King course for the knowledge test, just to get the admission ticket to take it. Virtually guarantees >90%.

 

[Clip4]

Being instrument rated would not, in and of itself, imply meeting the requirements of 61.129 a3i? Not trying to be argumentative, simply find it puzzling.

(i) Ten hours 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. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

I guess if you are applying for a single engine multi you have received all your IR training in actual and in a multi

 

[RyanB]

Being instrument rated would not, in and of itself, imply meeting the requirements of 61.129 a3i? Not trying to be argumentative, simply find it puzzling.

It should but it doesn’t necessarily meet the requirements for 61.129. The training that you’d receive for 61.129 is/are the same things you should’ve done for the instrument, it’s really just a matter of how it was logged. The DPE here says that it has to be logged as such in order to count for the commercial requirement being met.

Instrument instruction may be dicey depending how it was logged when you got your IR. There specific key words DPEs look for.

This.

 

[Rgbeard]

Oh and simply for clarification, I am not multi, nor ever intend to be unless buying a multi.

Thanks for the responses.

I’m still in touch with my IR instructor and may see if he’ll sign off our training as meeting the requirements.

 

[midlifeflyer]

yes, solo is solo.

...and be sure you identify qualifying solo flights a "solo" (aside form the PDPIC issue).

Many pilots don't use the "solo" column in their logbooks (and some might not even have one). As a student, you don't need to since PIC=Solo and if y=not considering the commercial certificate, don't really see the need to. The "gotcha" is, if it ain't logged it does not exist. A friend from years ago got bitten by that one when the Examiner rejected him at his checkride for not meeting the requirements.

 

[eman1200]

The first requirement of the commercial cert is shorter posts!

Oh and simply for clarification, I am not multi, nor ever intend to be unless buying a multi...

Hhhmmmmm, that comment sounds familiar. I think I said something similar after every rating/cert.

 

[455 Bravo Uniform]

You don’t need a 2nd Class medical to get the certificate, you only need it to exercise the privileges of the certificate (except CFI).

 

[eman1200]

You don’t need a 2nd Class medical to get the certificate, you only need it to exercise the privileges of the certificate (except CFI).

He hints at wanting to do ferry flights, but yeah.

 

[Wagondriver]

Its your log book. If you and your instrument instructor did course tracking, unusual attitudes and all that, it just has to be documented with those words. YOU can write that in the comments of the flight.
The DUAL cross country flights need to be documented as training for the commercial, use those and some maneuvers to get your 3 hours for sign off for the practical. I'm not so sure the long cross country has to be solo, just has to be PIC.

After 4 checkrides, I have found that just about every CFI, CFII, and DPE has a different view of how log books should be filled out. My instrument DPE chastised me profusely for recording ANY solo after I got my private. While not chastised, the latest DPE agreed that solo time in the log book is only for prior to having a PPL. The latest DPE told me that if I wanted to get a job with my log books, (commercial ride), that I needed to "clean up" my log books. So, today I went through them and got 5.5 years of flying up to date and correct with all categories. While doing the IACRA application there were categories for cross country instruction, ground instruction, total dual etc... I never thought to break out the cross country instruction and never bothered to add up the ground instruction.
But, now I have almost all categories that I think I need. SEL, SES, PIC, Ground instruction, Dual, night, day, actual IMC, simulated IMC, complex, tailwheel. It also turns out that I forgot to add up a few pages, turns out I have about 35 more hours than I thought.

 

[iamtheari]

The gotchas for me were:

• Solo cross country with 3 landings. I normally flew one or two legs at a time to go up to 1000 miles.
• Night cross country dual flight. I had met the day requirement somewhere along the way but not the night one.
• Night takeoffs and landings with flight in the traffic pattern at an airport with an operating control tower. I normally fly to a place with a tower and sometimes arrive at night, but rarely depart at night and never fly in the pattern much. So I made a trip to a towered airport one spring (before “night” turned into 11:30 pm as it does in the summer) and flew 10 stop-and-go laps around the pattern.
• Instructor availability.

 

[dmspilot]

Being instrument rated would not, in and of itself, imply meeting the requirements of 61.129 a3i? Not trying to be argumentative, simply find it puzzling.

We just had this discussion on this, though it was hidden in a thread about 8s on pylons so many might have missed it.

https://www.pilotsofamerica.com/com...ircraft-even-legal.136890/page-2#post-3223179

 

[dmspilot]

The gotchas for me were:

• Solo cross country with 3 landings. I normally flew one or two legs at a time to go up to 1000 miles.
• Night cross country dual flight. I had met the day requirement somewhere along the way but not the night one.
• Night takeoffs and landings with flight in the traffic pattern at an airport with an operating control tower. I normally fly to a place with a tower and sometimes arrive at night, but rarely depart at night and never fly in the pattern much. So I made a trip to a towered airport one spring (before “night” turned into 11:30 pm as it does in the summer) and flew 10 stop-and-go laps around the pattern.
• Instructor availability.

The night landings for 61.129(a)(4)(ii) don't have to be full stops.

 

[Lindberg]

2hr day & night XC's need to be post-Private Pilot training

Why?

 

[idahoflier]

My motivation mostly stems from my exposure to some friends that buy/sell planes and sometimes need a pilot to relocate a plane. It seems that helping them, even if for zero dollars, skirts the commercial rules a little too closely for comfort.

So, why not go for it at some point?

Well, since you asked... Years ago I had heard from others and then later actually heard it directly from an inspector that if you ever find yourself in a situation resulting in an enforcement action by the FAA, the penalty gets progressively worse based on the airman's certificate.

 

[Rgbeard]

Well, since you asked... Years ago I had heard from others and then later actually heard it directly from an inspector that if you ever find yourself in a situation resulting in an enforcement action by the FAA, the penalty gets progressively worse based on the airman's certificate.

So this is an argument to not go for the commercial certificate. Hmmm. Food for thought.

 

[iamtheari]

The night landings for 61.129(a)(4)(ii) don't have to be full stops.

I had a few externalities pushing me to do full-stop landings in that instance. One is that I don't like doing touch-and-goes at night all that much. Another is that I wanted to be night current for the rest of the spring while I was at it. But the biggest reason I only do full-stop landings at night is that MyFlightBook may have several properties/columns for various types of night landings, but the main night landing column is for full-stop and I already use too many properties.

 

[eman1200]

So this is an argument to not go for the commercial certificate. Hmmm. Food for thought.

maybe go for it because you love flying and enjoy the challenge of learning a few new maneuvers and will be able to relish* in the joy you get from putting in some hard work and passing a checkride?



*I hate relish.

 

[brcase]

So this is an argument to not go for the commercial certificate. Hmmm. Food for thought.

IMO, Only if you are a bit loose with the FAR's applying to you.

In reality I think there is a grain of true to the statement the FAA looks at you Certificate level in determining if and how much enforcement might be appropriate.

But the more accurate answer is I think they look at the whole picture. The higher the ratings the more they expect you to be an example of a professional pilot.
A DPE is a lot more likely to get an enforcement action for flying below safe altitudes than a Private pilot.
As a commercial pilot they would consider what kind of commercial work you are doing, how the infraction appears to other pilots (what kind of example are you setting) or the public, and how what risks/Dangers did it cause.
An Occasional Ferry pilot probably isn't likely to get as much of an enforcement issue as 135 pilot that is flying every day for the same event, but even then it would depend upon what kind of infraction. In reality an enforcement action would probably only occur if it was deliberate or negligent or re-occurring infraction.

Brian
CFIIG/ASEL

 

[Rgbeard]

IMP, Only if you are a bit loose with the FAR's applying to you.

In reality I think there is a grain of true to the statement the FAA looks at you Certificate level in determining if and how much enforcement might be appropriate.

But the more accurate answer is I think they look at the whole picture. The higher the ratings the more they expect you to be an example of a professional pilot.

Brian
CFIIG/ASEL

Thanks for the check back. I’ve never been the type of person that felt as if rules didn’t apply to me. I’ve always tried to conduct myself in the most safe and legal manner possible, after all it’s my life and the life of my family on the line every time we go.

what I have taken away from this is that I need to carefully go through my logbooks with my IR instructor to be sure that I can get my instrument training and instruction to count towards this, as I would just be miffed having to redo anything pointlessly. I’ll end up taking this year probably to put all that in place, and maybe make this a goal for the year 2023.

 

[tonycondon]

Why?

Because training towards a Private Certificate is not the same as training towards a Commercial Certificate. This was clarified in the Murphy Interpretation in 2011.

 

[Lindberg]

This was clarified in the Murphy Interpretation in 2011.

Yeah, it's wrong. And cites no support in the regulations.