Commercial Pilot requirements

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c310flyr

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c310flyr
I may be having a brain freeze, but I am unsure of the interpretation of the commercial pilots requirements.

See 61.129 https://www.govinfo.gov/content/pkg/CFR-2010-title14-vol2/pdf/CFR-2010-title14-vol2-sec61-129.pdf

It says that the applicant must have 20 hours of training in the areas of operation listed in 61.127(b) (1) https://www.gleim.com/aviation/faraim/?leafNum=61.127

In there it lists specifically that the applicant must have 10 hours of instrument training.

Most folks applying for the commercial have an instrument rating.

So, does that mean one needs 10 hours more, specifically done for the training for the commercial rating ?

I would not think so, but the rule specifically states 20 hours of training in the areas listed for 61.127b which is for the commercial.

Similarly, must the cross countries be done during training for the commercial, or does what one have in his log count ?

Again, I think older hours count, but the requirements for the cross country are specifically listed under the 20 hours of training for the commercial section.

It also references the areas where one must receive and log ground and flight training for the commercial, and one of those areas is high altitude operation.

I get the ground training, but the reg says ground and flight training.

I've never heard of someone having to go to high altitude for a commercial sign off and it would preclude the planes I know are used, but how does one get around the language of the rule that says ground and flight training ?

Wonder if someone can clear this up.

Thanks.
 
dont forget the phrase above “high altitude operations” that says, “that apply to the aircraft category and class rating sought.”

If you’re not doing your commercial in a pressurized airplane that flies above 25,000 ft, it probably doesn’t apply.

Much like you won’t log training in seaplane base operations with a land plane.
 
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MauleSkinner said:
Where is the high altitude requirement in 61.129?
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Non-existent. He's looking at 61.127 which mentions high altitude ops, which can be simulated by performing takeoffs at reduced power.
 
Thanks

Still unsure of the confusion of what people seem to do vs what the chief counsel opinion was
 
c310flyr said:
Thanks

Still unsure of the confusion of what people seem to do vs what the chief counsel opinion was
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Because as usually the case, the CC has their head up their ass.
 
c310flyr said:
Thanks

Still unsure of the confusion of what people seem to do vs what the chief counsel opinion was
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If your instrument instructor logged those specific training events, you’re fine. If not, take the 15 minutes to train and log them, and move on.
 
c310flyr said:
So, does that mean one needs 10 hours more, specifically done for the training for the commercial rating ?
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No. The instrument you hold counts for the 10 hours.
 
c310flyr said:
Similarly, must the cross countries be done during training for the commercial, or does what one have in his log count ?
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Both the day and night cross county’s are dual.
 
Initial Fix said:
No. The instrument you hold counts for the 10 hours.
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Accroding to the FAA, this is not correct unless it was specifically logged as covering the areas listed in 61.129.

How it gets applied in practice varies from examiner to examiner.
 
EdFred said:
Because as usually the case, the CC has their head up their ass.
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Although in this case, the anti double dip philosophy predates the legal interpretations. Just as likely the CC is finding an interpretation Which fits Flight Standards policy as making it up on their own. As the Hartz ell letter put it,

This response was prepared by Neal O'Hara, an Attorney in the Regulations Division of the Office of the Chief Counsel, and has been coordinated with the Certification and General Aviation Operations Branch of the Flight Standards Service.
 
midlifeflyer said:
Although in this case, the anti double dip philosophy predates the legal interpretations. Just as likely the CC is finding an interpretation Which fits Flight Standards policy as making it up on their own. As the Hartz ell letter put it,

This response was prepared by Neal O'Hara, an Attorney in the Regulations Division of the Office of the Chief Counsel, and has been coordinated with the Certification and General Aviation Operations Branch of the Flight Standards Service.
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I stand corrected, here we have the FAA equivalent of the Human Centipede (if you don't know, you don't want to know).
 
MauleSkinner said:
dont forget the phrase above “high altitude operations” that says, “that apply to the aircraft category and class rating sought.”

If you’re not doing your commercial in a pressurized airplane that flies above 25,000 ft, it probably doesn’t apply.
.
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Eh? Since when does pressurization or altitude limits have anything to do with "category and class?"
 
MauleSkinner said:
Since they wrote the ref without thinking about what they were writing.
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But the reg doesn't say that. The reg lists "high altitude" operations in the general aeronautical knowledge and specifically in the flight proficiency for the airplane category.
It doesn't say anything about skipping that training if your airplane can't do it. Even the ACS expects the applicant to have that knowledge.
 
flyingron said:
But the reg doesn't say that. The reg lists "high altitude" operations in the general aeronautical knowledge and specifically in the flight proficiency for the airplane category.
It doesn't say anything about skipping that training if your airplane can't do it. Even the ACS expects the applicant to have that knowledge.
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So a commercial pilot needs to find an airplane that meets the requirements of 61.31(g) in order to get the flight training required by 61.127?
 
MauleSkinner said:
dont forget the phrase above “high altitude operations” that says, “that apply to the aircraft category and class rating sought.”
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The reg tells you which areas of operation go with which category and class, you don't pick and choose them. Maybe it would be clearer if you didn't take phrases out of context.

(a) General. A person who applies for a commercial pilot certificate must receive and log ground and flight training from an authorized instructor on the areas of operation of this section that apply to the aircraft category and class rating sought.

(b) Areas of operation.
(1) For an airplane category rating with a single-engine class rating:
...
(x) High-altitude operations; and
​
 
MauleSkinner said:
So a commercial pilot needs to find an airplane that meets the requirements of 61.31(g) in order to get the flight training required by 61.127?
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Where does 61.127 require training on pressurization or flight above 25,000 feet?
 
Well since 1.1 doesn't define "high altitude", we can scroll through 61 to see what returns we get for that phrase (also "high-altitude"):

61.31(g) The pressurized aircraft signoff
61.93 - Student solo XC requirements for powered lift (but not others)
61.125 - Commercial knowledge
61.127 - Commercial proficiency
61.156 - ATP w/ type rating

So, an argument could be made that in order to get the commercial you need a 61.31(g) signoff. But few people get that prior to commercial. So the FAA obviously brain farted when writing this reg. Of course they use PIC in multiple ways, so there is that.
 
MauleSkinner said:
So a commercial pilot needs to find an airplane that meets the requirements of 61.31(g) in order to get the flight training required by 61.127?
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Nope, the rules don't say it has to be in that kind of plane. It just says you've got to receive ground and flight training pertinent to that subject area. 61.31 is an independent requirement.
 
flyingron said:
Nope, the rules don't say it has to be in that kind of plane. It just says you've got to receive ground and flight training pertinent to that subject area. 61.31 is an independent requirement.
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So what flight training is required for that subject area?
 
Well, if you live in a place like Denver, you pretty much discuss it on every trip. If you live elsewhere, you might talk about high density altitude days. You talk about oxygen requirements. The reg is vague, but it would behoove you to have it in the logbook somewhere.
 
flyingron said:
Well, if you live in a place like Denver, you pretty much discuss it on every trip. If you live elsewhere, you might talk about high density altitude days. You talk about oxygen requirements. The reg is vague, but it would behoove you to have it in the logbook somewhere.
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So how do you comply with the Flight Training requirement if you live elsewhere?
 
MauleSkinner said:
So how do you comply with the Flight Training requirement if you live elsewhere?
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You read the reg. It says ground and flight training in the listed areas. The listed items are not included in the aeronautical experience section.

I already had most of the areas logged so I spent a couple of hours explaining each of the items and logged it as ground satisfying 61.127. Chances are the examiner will ask about some of the items so it’s good to review them with a CFI who is familiar with the examiner.
 
JScarry said:
You read the reg. It says ground and flight training in the listed areas. The listed items are not included in the aeronautical experience section.
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From the Aeronautical Experience section:
(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
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Looks like it’s listed to me. Flight training required.
 
MauleSkinner said:
From the Aeronautical Experience section:


Looks like it’s listed to me. Flight training required.
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That’s not how my CFII or DPE interpreted it. In fact,
(i) Preflight preparation;
(ii) Preflight procedures;
(xi) Postflight procedures.
by definition are not done in flight but on the ground.
 
JScarry said:
That’s not how my CFII or DPE interpreted it. In fact,
(i) Preflight preparation;
(ii) Preflight procedures;
(xi) Postflight procedures.
by definition are not done in flight but on the ground.
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Well, I guess if you can justify the interpretation that high altitude operations are not flight operations, you’ll do fine when you get to the regulatory interpretations where flaps aren’t a flight control but radios are.
 
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If your interpretation is correct, please explain to me how thousands of pilots have gotten their commercial certificate using Arrows and C172-RGs that aren’t even capable of flying in the flight levels. They certainly haven’t logged any time flying in a pressurized airplane above 25,000'.
 
JScarry said:
If your interpretation is correct, please explain to me how thousands of pilots have gotten their commercial certificate using Arrows and C172-RGs that aren’t even capable of flying in the flight levels. They certainly haven’t logged any time flying in a pressurized airplane above 25,000'.
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My interpretation is that the FAA wants ground and flight training in some ill-defined “high altitude operations.”

If that interpretation is correct, those thousands of pilots, their instructors, and examiners have ignored that requirement, and gotten away with it because it is ill-defined.
 
Am I the only one that understands what MauleSkinner is getting at?
 
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