Commercial requirements

[stevensun]

I am getting my first commercial training. I got 250 hours + from flying everywhere ( I fly for fun, not just for commercial.) and at same time, I almost fulfill all the requirements.
I had to check out on a complex. Which I spent 10 hours dual at least. ( does that count towards commercial? If my intention was to get complex endorsement. Or no matter what the intention was, as long as I have the hours)

I also had IFR training. I haven’t finished it yet, got 20+ hours for IFR training. Can that count towards 61.129 a. 3.ii? Or does the training must log and comment with “For commercial training”?

Also for the XC. I flew the legs but because of my log book only has departure and arrival, I couldn’t really fit 4 airports. So I put them 3 separate lines. It’s same day. Does that count?

My current instructor told me the PDE at their location won’t just take any IFR training and count that in as 10 hours of instrument training.

 

[DGlaeser]

The regs don't specify 'why' you are training, the hours are all that matters. The complex hours are good, and as long as the IFR training was with a CFII, it counts.
(Don't let the DPE tell you otherwise - have him show you the reg that says training has to be notated 'for commercial training')
If you don't have an instrument rating before getting your commercial, you will get a 'limited' commercial. (lots of crop dusters have these)
How you log the flights does not matter - as long as the date and departure/destination are there, all is good No reg says the long XC has to be completed in one day!

 

[stevensun]

The regs don't specify 'why' you are training, the hours are all that matters. The complex hours are good, and as long as the IFR training was with a CFII, it counts.
(Don't let the DPE tell you otherwise - have him show you the reg that says training has to be notated 'for commercial training')
If you don't have an instrument rating before getting your commercial, you will get a 'limited' commercial. (lots of crop dusters have these)
How you log the flights does not matter - as long as the date and departure/destination are there, all is good No reg says the long XC has to be completed in one day!

Any reg says the XC can not have long stop in the middle? ( grab a burger, fill gas)?

 

[stevensun]

https://www.faa.gov/about/office_or...0/theriault - (2010) legal interpretation.pdf
there is this. So IFR training hour can’t count towards commercial ? ( at least some of them?)

 

[stevensun]

Does PPL’s simulate instrument time count towards the commercial 10 hour requirements? Does it count towards IFR hours?

if I fly a 250NM IFR 3 leg night XC with CFII. That fulfills the CPL dual night 100NM and 2 hours, and the IFR long XC. Can this be used for CPL AND IFR?

 

[flyingron]

If you don't have an instrument rating before getting your commercial, you will get a 'limited' commercial. (lots of crop dusters have these)

No, you get the same commercial certificate that everybody else gets. It's only limited in what you're allowed to do with it until you add an instrument rating.

 

[MauleSkinner]

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2010/theriault - (2010) legal interpretation.pdf
there is this. So IFR training hour can’t count towards commercial ? ( at least some of them?)

Depends how it was logged. There are specific things that are required by 91.129 for a commercial applicant. If those things are not specifically noted in your logbook, it won’t work. It should take about an hour to get them done and logged if you’re reasonably proficient, however. The reg says ten hours of attitude instrument flying “including” these things, not “consisting of” these things.

 

[midlifeflyer]

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2010/theriault - (2010) legal interpretation.pdf
there is this. So IFR training hour can’t count towards commercial ? ( at least some of them?)

You need to read the follow-up to the Theriault letter also: https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps//2010/hartzell - (2010) legal interpretation.pdf It just needs to be properly documented. In theory, one can point out specific logged tasks and show they fit both, but the simplest is something like the usual statement of maneuvers and procedures followed by "per FAR 61.65 and 61.129(a)" (assuming it's thought of at the time)

 

[midlifeflyer]

Any reg says the XC can not have long stop in the middle? ( grab a burger, fill gas)?

No. Mine was a multi-day trip.

The FAA is on record saying what one considers a single flight is pretty much up to the pilots. I guess unless one is being ridiculous - I remember someone joking that he considers his entire flying career a single cross country flight .

The old, orphaned Part 61 FAQ was very explicit saying, ""The 'original point of departure' for the purpose of a cross country does not change with a new day or delay."

More recently, in the 2009 Glenn interpretation, which mostly deals with safety pilots not being permitted to log cross country time, it also talks a bit about this:

“There is nothing in § 61.1(b)(3)(ii) or previous FAA interpretations dictating how separate flights must be logged. Accordingly, the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted. Section 61.1(b)(3)(ii) requires that the flight include a landing at a point other than the point of departure.”
[2009 Glenn Interpretation](https://is.gd/pHRXUh)​

 

[flyingron]

The John Lynch "FAQ" never had any official status. The FAA officially (and rightfully so) disavowed any authority for it.

 

[stevensun]

What about:
Does PPL’s simulate instrument time (3 hours) count towards the commercial 10 hour requirements? Does it count towards IFR hours(40hours of actual or simulated)?
if I fly a 250NM IFR 3 leg night XC with CFII. That fulfills the CPL dual night 100NM and 2 hours, and the IFR long XC. Can this be used for CPL AND IFR?

 

[MauleSkinner]

What about:
Does PPL’s simulate instrument time (3 hours) count towards the commercial 10 hour requirements? Does it count towards IFR hours(40hours of actual or simulated)?
if I fly a 250NM IFR 3 leg night XC with CFII. That fulfills the CPL dual night 100NM and 2 hours, and the IFR long XC. Can this be used for CPL AND IFR?

Depends...does it meet the requirements of those regs?

 

[stevensun]

Depends...does it meet the requirements of those regs?

Not sure. But from I read from FAR61, it really doesn’t say it doesn’t count.

 

[MauleSkinner]

Not sure. But from I read from FAR61, it really doesn’t say it doesn’t count.

Read the regs that you’re wanting the flights to comply with. Do they meet the requirements of the reg?

for example, does your private pilot instrument instruction meet the requirements for the commercial training? did it include (and did your instructor log)

(i)...attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems.

And was it “instrument training” from a CFII, or “flight by reference to instruments”?

 

[stevensun]

Read the regs that you’re wanting the flights to comply with. Do they meet the requirements of the reg?

So.

Does PPL’s simulate instrument time (3 hours) count towards the commercial 10 hour requirements? Does it count towards IFR hours(40hours of actual or simulated)?

REGS:
(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) 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 single engine airplane;

Instrument training using view-limit, check.
Include attitude instrument flying blablabla, check. It doesn't say all 10 hours need to be those. Just need to include those. So I can literally do it once and call it good.
5 hours must be in a in single engine airplane. (the PPL 3hours was in a SEA)

if I fly a 250NM IFR 3 leg night XC with CFII. That fulfills the CPL dual night 100NM and 2 hours, and the IFR long XC. Can this be used for CPL AND IFR?
REG:
(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
Again.
61.129.3.i. Check. ( If I am using view limit? Can I use view limit when I am flying actual IMC with my CFII?)
IFR part:
(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves -

(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.

250NM, check.
Instrument approach, check
3 different approaches, check.

 

[MauleSkinner]

Instrument training using view-limit, check.
Include attitude instrument flying blablabla, check. It doesn't say all 10 hours need to be those. Just need to include those. So I can literally do it once and call it good.
5 hours must be in a in single engine airplane. (the PPL 3hours was in a SEA)

And “attitude instrument flying blablabla” is what your instructor wrote in your logbook?

 

[stevensun]

And “attitude instrument flying blablabla” is what your instructor wrote in your logbook?

I can take 1 hour of IFR flight and do all of those. No? And just have 9 hours of instrument dual with CFII and do altitude flying, or not even, I can just fly under the hood and do basically nothing.

You said

Depends how it was logged. There are specific things that are required by 91.129 for a commercial applicant. If those things are not specifically noted in your logbook, it won’t work. It should take about an hour to get them done and logged if you’re reasonably proficient, however. The reg says ten hours of attitude instrument flying “including” these things, not “consisting of” these things.

 

[midlifeflyer]

What about:
Does PPL’s simulate instrument time (3 hours) count towards the commercial 10 hour requirements?

No. There are two reasons. One is a long-standing FAA policy against using private pilot "training" requirements toward any advanced certificate or rating. Quite a few interpretations on this one. But the key to understanding it (assuming that's your goal) is the phrase in the regulations for this is "on the areas of operation." The FAA treats that as meaning different in kind, not just in wording. So, for example even if the words are the same, "slow flight and stalls" in 61.127 is different than "slow fight and stalls" in 61.107.

Does it count towards IFR hours (40hours of actual or simulated)?

Yes. In this case, it's not a "training" requirement, it is a general flight time requirement so everything counts.

if I fly a 250NM IFR 3 leg night XC with CFII. That fulfills the CPL dual night 100NM and 2 hours, and the IFR long XC. Can this be used for CPL AND IFR?

That was already answered. It's a tougher call for the CFI to say that both 61.65 and 61.129 requirements were met, but I guess it's possible.

 

[stevensun]

No. There are two reasons. One is a long-standing FAA policy against using private pilot "training" requirements toward any advanced certificate or rating. Quite a few interpretations on this one. But the key to understanding it (assuming that's your goal) is the phrase in the regulations for this is "on the areas of operation." The FAA treats that as meaning different in kind, not just in wording. So, for example even if the words are the same, "slow flight and stalls" in 61.127 is different than "slow fight and stalls" in 61.107.


Yes. In this case, it's not a "training" requirement, it is a general flight time requirement so everything counts.


That was already answered. It's a tougher call for the CFI to say that both 61.65 and 61.129 requirements were met, but I guess it's possible.

Isn’t what DPE says matters? DPE is the person who can let you take the test or not. If I switch an instructor, how does he know if it’s under 61.65 or 61.129?

 

[MauleSkinner]

Isn’t what DPE says matters? DPE is the person who can let you take the test or not. If I switch an instructor, how does he know if it’s under 61.65 or 61.129?

You appear to be looking for a specific answer (do my logbooks meet this criteria) to a general question (can a pilot count this time towards that). I suggest getting together with your instructor to have him evaluate your logbooks and training plan.

 

[midlifeflyer]

Isn’t what DPE says matters? DPE is the person who can let you take the test or not. If I switch an instructor, how does he know if it’s under 61.65 or 61.129?

That's true, but DPEs are supposed to know and follow FAA rules. They don't know unless it's logged properly.

 

[stevensun]

You appear to be looking for a specific answer (do my logbooks meet this criteria) to a general question (can a pilot count this time towards that). I suggest getting together with your instructor to have him evaluate your logbooks and training plan.

Well, I am asking the question here because the instructor I have and the DPE he usually uses don’t like the hours i have logged. Doesn’t always mean they are right, correct?

 

[MauleSkinner]

Well, I am asking the question here because the instructor I have and the DPE he usually uses don’t like the hours i have logged. Doesn’t always mean they are right, correct?

No, it doesn’t. But you don’t seem to be accepting the answers you’re getting here, either, and short of uploading copies of your logbooks, we can’t give you the answers you’re looking for.

 

[stevensun]

No, it doesn’t. But you don’t seem to be accepting the answers you’re getting here, either, and short of uploading copies of your logbooks, we can’t give you the answers you’re looking for.

Well just trying to understand. The answers given here aren’t that clear either. So

 

[MauleSkinner]

Well just trying to understand. The answers given here aren’t that clear either. So

They’re very clear answers to the questions you’re asking. They’re just not the answers you’re looking for, apparently.

 

[stevensun]

They’re very clear answers to the questions you’re asking. They’re just not the answers you’re looking for, apparently.

I am sorry, but it seems like all you said is, refer to the regs ( I guess that's real clear answers ). Other than the first one.

Depends how it was logged. There are specific things that are required by 91.129 for a commercial applicant. If those things are not specifically noted in your logbook, it won’t work. It should take about an hour to get them done and logged if you’re reasonably proficient, however. The reg says ten hours of attitude instrument flying “including” these things, not “consisting of” these things.

And that's what I used into example to try to understand if what you said is being correctly understand by me.

 

[MauleSkinner]

And that's what I used into example to try to understand if what you said is being correctly understand by me.

I’m willing to bet that “blablabla” wasn’t part of the logbook entry.

The answers you seem to want involve an assessment of your logs that we cannot provide here.

 

[stevensun]

I’m willing to bet that “blablabla” wasn’t part of the logbook entry.

The answers you seem to want involve an assessment of your logs that we cannot provide here.

It is part of the logbook.
Sorry I notice sometimes I like to hide information for others because I thought I only need the information I need from other people.

Just asked my previous CFI. He said the IFR training can be used for commercial IFR hours.
Each procedure is logged (ILS, RNV VOR). Partial panels, unusual attitude, Instrument flying.