Commercial multi w/o single requirements?

[alfadog]

Please side-check me on this. Last winter, I was thinking of doing the commercial multi deal with Captain Apache out of Delray. My boss's son is going to skip straight to the commercial multi in his Dad's DA-42. That might also be an option for me as he lets employees use his 172 for primary training. I have not broached the subject with him; he is getting an instructor checked out now in the DA-42 for his son who finished his IR right after me.

Here is what I come up with as the minimum requirements for multi time assuming that I have enough single time in all categories per 61.129:

• Dual
  • 10 hours of training in complex multi.
    • 5 hours of instrument instruction (can be included in 10 hrs. above).
    • 2 hour day VFR flight (can be included in 10 hrs. above).
    • 2 hour night VFR flight (can be included in 10 hrs. above).
    • 3 hours dual within 60 days of checkride (can be included in 10 hrs. above).
• Solo
  • 10 hours of solo flight (assuming that the student does not have the multi rating and cannot act as PIC with instructor on-board).
    • Long XC (can be included in 10 hrs. above).
    • 5 hours night VFR (can be included in 10 hrs. above).

This is basically the deal that the Delray fellow does. It runs about $6k with him in an Apache. So you start as a PPL ASEL and end up as commercial multi. If you already have the IR then you shoot an approach on the checkride and get that also for the multi commercial.

Do I have it right? Can you theoretically go from PPL ASEL to commercial multi in 20 hours of multi time and one checkride?

 

[ja_user]

Yes, in theory you could do anything in the minimal amount of time. At some point you have to learn all the MEL maneuvers/procedures. I assume he plans on teaching those during the VFR XC flights? I'm not sure.

If you aren't already proficient in IFR/Complex Aircraft you are going to be behind the ball and it may take a lot longer.

 

[alfadog]

Thanks. I am basically interested if I have the numbers right, not if this is particularly realistic. I think more like 25 - 30 hours if one wanted to go this route.

Yes, in theory you could do anything in the minimal amount of time. At some point you have to learn all the MEL maneuvers/procedures. I assume he plans on teaching those during the VFR XC flights? I'm not sure.

If you aren't already proficient in IFR/Complex Aircraft you are going to be behind the ball and it may take a lot longer.

 

[ja_user]

You understand that most places won't let you Solo the MEL right?

So you'll have to fall under the exception that allows a CFI to sit there in the right seat and not do anything, while you "perform the duties of PIC" (including they can't really give logable instruction).. My assumption is that your CFI would like to be compensated for this 10hrs, figure that into it as well.

 

[alfadog]

You understand that most places won't let you Solo the MEL right?

So you'll have to fall under the exception that allows a CFI to sit there in the right seat and not do anything, while you "perform the duties of PIC" (including they can't really give logable instruction).. My assumption is that your CFI would like to be compensated for this 10hrs, figure that into it as well.

Thank you for that. Can you point me at that exception. I was trying to figure that one out because I know it is done that way.

 

[TCABM]

He might be referring to this:

§ 61.129 Aeronautical experience.

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

(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in § 61.127(b)(2) of this part that includes at least....

As I understand it, the PIC requirement carves out the ability of the CFI to give instruction.

I might be wrong, though.

 

[alfadog]

I saw that but I guess that I misinterpreted it and did not think that "performing the duties of pilot in command" was a special thing separate from being the legal PIC.

...

(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in § 61.127(b)(2) of this part that includes at least....

As I understand it, the PIC requirement carves out the ability of the CFI to give instruction.

I might be wrong, though.

 

[alfadog]

Answering my own question. Here is an FAA counsel letter stating that this type of flight IS a substitute for required solo flight and no flight instruction is given. The student pilot may NOT log PIC time if not rated nor dual received, simply under total flight time. This letter is for the single-engine commercial but the language in 61.129 is identical for the multi so it should apply.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2014/kuhn - (2014) legal interpretation.pdf

 

[alfadog]

Something from the Federal Register that touches on this

In addition, the FAA has revised § 61.129(b)(4) to permit an applicant for a commercial pilot certificate with a multiengine rating to credit the 10 hours of flight time performing the duties of PIC in a multiengine airplane required by that paragraph toward the 100 hours of PIC flight time required under § 61.129(b)(2). This revision is consistent with the provisions of § 61.129(b) as proposed in Notice No. 95-11. As previously noted, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. The solo flight time would have constituted PIC flight time; therefore, the applicant would have been able to credit that flight time toward the requirements of § 61.129(b)(2). However, under § 61.129(b)(4) as adopted in the final rule, an applicant would be performing the duties of PIC rather than acting as PIC. Consequently, that flight time does not constitute PIC flight time. Therefore, the FAA has revised § 61.129(b)(4) to permit the crediting of flight time accomplished under that paragraph toward the requirements of § 61.129(b)(2). However, this revision does not permit an applicant to log the flight time required under § 61.129(b)(4) as PIC flight time under § 61.51(e) unless the applicant holds a private pilot certificate with a multiengine rating and chooses to accomplish the requirements with an authorized instructor.

 

[ja_user]

You got it.
My point was, plan on paying the CFI for that time in addition to the plane if you are putting these numbers together for budget purposes. That solo exception is also handy if someone needs the solo night requirements, but is restricted from night flying based on their medical. The exception also exists for SEL now, although that is a fairly recent change.

Keep in mind that 61.129 outlines what is required for your initial commercial airplane rating.
None of that experience has to be met when you add on a rating (MEL Commercial pilot adds on SEL, or more commonly SEL Commercial pilot adds on MEL). Or said another way, you already are a commercial pilot, so you already met the requirements. Either way, you can ignore it once you get your first commercial airplane rating.

 

[James331]

Is he doing this just to do it, or is he actually looking to become a professional pilot?

If it’s the later he’s going to need a CPL single engine, heck he’s going to need the single engine more than the multi for those first few jobs.

 

[ja_user]

Is he doing this just to do it, or is he actually looking to become a professional pilot?

If it’s the later he’s going to need a CPL single engine, heck he’s going to need the single engine more than the multi for those first few jobs.

Might need a CFI for some of those jobs too, but I think we are just discussing theory here?

 

[alfadog]

Is he doing this just to do it, or is he actually looking to become a professional pilot?

If it’s the later he’s going to need a CPL single engine, heck he’s going to need the single engine more than the multi for those first few jobs.

Maybe he thinks he is going to fly his Dad's Beech 18's ;-)

 

[RussR]

That solo exception is also handy if someone needs the solo night requirements, but is restricted from night flying based on their medical.

That poses a bit of an unfortunate scenario. The 10 hours of solo or "supervised solo" cannot be mixed and matched. It has to be 10 of one, or 10 of the other. For most situations, this makes sense if you think about it - the reason for the "supervised solo" exception is for insurance purposes. If you CAN fly some of it actually solo, then the insurance reasons obviously aren't a factor and there's no reason then to allow the exception for part of the time.

See the 2016 Grannis interpretation:
https://www.faa.gov/about/office_or...016/grannis - (2016) legal interpretation.pdf

But for the case you describe with a night restriction, unfortunately this means that the applicant would have to do all 10, including the "long XC" with a CFI as "supervised solo".

 

[dmspilot]

The 10 hours of solo or "supervised solo" cannot be mixed and matched. It has to be 10 of one, or 10 of the other. For most situations, this makes sense if you think about it - the reason for the "supervised solo" exception is for insurance purposes.

It's also the way the reg is written: "10 hours of A or 10 hours of B" not "10 hours of A or B".

 

[ja_user]

It's also the way the reg is written: "10 hours of A or 10 hours of B" not "10 hours of A or B".

I can see how you would interpret it this way. Thanks for the reference to the FAA letter.

If someone wanted to press it, it would be worth having the reg updated. There are more reasons than just insurance that a person would want to do a combination. Such as night restrictions, changing planes and ins requirements.. But I can also see why it is limited with the CFI reg.

I was actually quite suprised when they switched it from MEL only, and included that language in that SEL section. I'm guessing it was a copy/paste job and not as much thought as you would hope was put into it.

I've also never heard of a DPE denying a combination, it likely just doesn't come up that often.

 

[MauleSkinner]

That poses a bit of an unfortunate scenario. The 10 hours of solo or "supervised solo" cannot be mixed and matched. It has to be 10 of one, or 10 of the other. For most situations, this makes sense if you think about it - the reason for the "supervised solo" exception is for insurance purposes. If you CAN fly some of it actually solo, then the insurance reasons obviously aren't a factor and there's no reason then to allow the exception for part of the time.

But that also assumes that all flying and/or training for the commercial certificate is done at one place/time. What if I were to look back in my logbook and realize I could count the time my mom gave me a credit card & I flew my dad’s Lance down to Iowa for combine parts, but that was the only previous solo complex time I had (less than 10 hours), and that airplane is no longer available? I’d now have to get an ADDITIONAL 10 hours of complex time because the new stuff all has to be supervised.

 

[RussR]

But that also assumes that all flying and/or training for the commercial certificate is done at one place/time. What if I were to look back in my logbook and realize I could count the time my mom gave me a credit card & I flew my dad’s Lance down to Iowa for combine parts, but that was the only previous solo complex time I had (less than 10 hours), and that airplane is no longer available? I’d now have to get an ADDITIONAL 10 hours of complex time because the new stuff all has to be supervised.

But the solo time does NOT have to be in a complex airplane, it can be in a 172. That's not a change, it's been that way a long time. And your "new stuff" does not have to be supervised, so I do not understand your question. Are you saying that the single-engine aircraft available near you for rent (in this hypothetical) do not allow solo flight? Has the industry turned that way? If so, I'm unaware.

You would still need the long solo XC as well as the 5 hours night solo, which will quite possibly add up to right about 10 hours.

 

[dmspilot]

But that also assumes that all flying and/or training for the commercial certificate is done at one place/time. What if I were to look back in my logbook and realize I could count the time my mom gave me a credit card & I flew my dad’s Lance down to Iowa for combine parts, but that was the only previous solo complex time I had (less than 10 hours), and that airplane is no longer available? I’d now have to get an ADDITIONAL 10 hours of complex time because the new stuff all has to be supervised.

What do you mean "has to be"?

 

[MauleSkinner]

But the solo time does NOT have to be in a complex airplane, it can be in a 172. That's not a change, it's been that way a long time. And your "new stuff" does not have to be supervised, so I do not understand your question. Are you saying that the single-engine aircraft available near you for rent (in this hypothetical) do not allow solo flight? Has the industry turned that way? If so, I'm unaware.

You would still need the long solo XC as well as the 5 hours night solo, which will quite possibly add up to right about 10 hours.

So what is it about the 10-hour solo requirement that may not be insurable without an instructor on board?

 

[RussR]

So what is it about the 10-hour solo requirement that may not be insurable without an instructor on board?

For single-engine, there is no reason for the rule as far as I can tell. But the rule is identical to the multi-engine one, which has some valid insurance reasons.

 

[ja_user]

So what is it about the 10-hour solo requirement that may not be insurable without an instructor on board?

Maybe you own a Malibu and insurance said "CFI onboard until you get your commercial rating"?

Or you are low time, own a BO, and insurance wants you to get 25hours or something with a CFI onboard, so you decide to knock out a rating.

 

[Glenn C]

Make sure of which flying goes into which category. I was the CFI for my son who did just this, an initial commercial multi engine without a single engine commercial. There was a rush to become qualified for a possible job and dad has a 310 soooo.... Anyway, be sure which flying goes into which category. The long cross country has to be logged as performing the duties of pilot and command under FAR 61.129.xxx as well as the ten night takeoff and landings at a tower airport. They come under section 4, items i and ii.

The dpe was grateful that I wrote a letter clearly explaining which flights counted for which, some logged specifically as training under the FAR and some specifically as performing the duties of the PIC. Read the reg carefully! Training has to include two separate x country flights with an instructor.

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

(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.

(2) 100 hours of pilot-in-command flight time, which includes at least -

(i) 50 hours in airplanes; and

(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.

(3) 20 hours of training on the areas of operation listed in § 61.127(b)(2) of this part that includes at least -

(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 multiengine airplane;

(ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine-powered, or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine seaplane that has flaps and a controllable pitch propeller;

(iii) One 2-hour cross country flight in a multiengine 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 multiengine 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 multiengine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in § 61.127(b)(2) of this part that includes at least -

(i) One cross-country flight of not less than 300 nautical miles total distance with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight with a traffic pattern) at an airport with an operating control tower.

 

[Glenn C]

So now that we have cleared that up, I have a similar question but in reverse.

My son called a different DPE to make an appointment for a single engine add on to his commercial. The guy asked him to send pictures of his log books to make sure he had his requirements. He said to the examiner, "just to be clear, I already have a commercial" and the guy said, "yes, in a twin, but the FAR's are quite specific that they have to be met in a single". Looking at the FAR's I'm with him to a point, but I want an opinion. The training flights clearly have to be done in a single. Does the long requirement have to be met in a single even if it was already done in a twin? At the school he went to people doing an add on multi did not have to do a long xc in the twin because the single engine counted. Why would it be different doing it in reverse?

 

[dmspilot]

My son called a different DPE to make an appointment for a single engine add on to his commercial. The guy asked him to send pictures of his log books to make sure he had his requirements. He said to the examiner, "just to be clear, I already have a commercial" and the guy said, "yes, in a twin, but the FAR's are quite specific that they have to be met in a single". Looking at the FAR's I'm with him to a point, but I want an opinion. The training flights clearly have to be done in a single. Does the long requirement have to be met in a single even if it was already done in a twin? At the school he went to people doing an add on multi did not have to do a long xc in the twin because the single engine counted. Why would it be different doing it in reverse?

Suggest you give your money to a DPE who knows what he's talking about instead.

§61.63 Additional aircraft ratings (other than for ratings at the airline transport pilot certification level).

(a) General. For an additional aircraft rating on a pilot certificate, other than for an airline transport pilot certificate, a person must meet the requirements of this section appropriate to the additional aircraft rating sought.
(b) Additional aircraft category rating [...SNIP]
(c) Additional aircraft class rating. A person who applies for an additional class rating on a pilot certificate:

(1) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.
(2) Must pass the practical test.
(3) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought; unless, the person only holds a lighter-than-air category rating with a balloon class rating and is seeking an airship class rating, then that person must receive the specified training time requirements and possess the appropriate aeronautical experience.
(4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.​

 

[ja_user]

Yeah, no reason to use a DPE that rolls his own regs.

 

[Glenn C]

I like this answer!