How to Meet Part 141 Flight Training Requirements for Commercial

[RingLaserGyroSandwich]

I've found conflicting information online, but I find even CFIs are sometimes confused about this issue. I'm specifically discussing qualifying for the ASEL commercial checkride, but the principles likely apply to Instruments when Part 141 and other 141 courses. The flight training requirements for Commercial ASEL when already holding an instrument rating are (Part 141 Appendix D, italics are my words):

• Each approved course must include at least the following flight training, as provided in this section (Aeronautical knowledge training, section No. 3) and section No. 5 (solo training) of this appendix, on the approved areas of operation listed in paragraph (d) (preflight, takeoffs, navigation, etc.) of this section that are appropriate to the aircraft category and class rating for which the course applies:

1. 120 hours of training if the course is for an airplane...
2. 55 hours of flight training from a certificated flight instructor on the approved areas of operation listed in paragraph (d)(1) of this section that includes at least—
3. 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;
4. Ten hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane that meets the requirements of §61.129(j) of this chapter, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;
5. Cross Country Flights: 2hr/100nm day, 2hr/100nm night
6. 3 hours in a single-engine airplane in preparation for the practical test within 60 days preceding the date of the test.
7. Ten hours of solo flight time in a single engine airplane...The training must consist of the approved areas of operation under paragraph (d)(1) of section 4 of this appendix, and include—
8. Cross Country Flights: Big flight with 250 nm leg
9. 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.

The approved Part 141 curriculum for the commercial course will likely assume 120 hours of flight training, including at least 55 hours of dual, 10 hours of under-the-hood training, 10 hours in a complex plane (or the other permissible options), and 5 hours of night VFR. Assume the student got their private and instrument ratings under a mixture of part 61 and part 141, prior to January 1, 2020. Assume the student started the commercial curriculum on January 1, 2020 as well. Can some flight training performed prior to January 1, 2020 count towards any of the requirements above while under Part 141? The confusion is surrounding this exact question and I'd like to source/cite the answer so I can refer other people in the future.

The magenta text above regarding instrument training implies it's possible, at some level, to count flying that was not specifically performed on/after January 1, 2020. Under what scenarios would a commercial learner ( ) only need five instead of ten hours of instrument training in a single-engine airplane? Why would the commercial curriculum include 5 hours of training under-the-hood in a single engine airplane, and 5 hours of training under-the-hood in a multi-engine airplane or perhaps helicopter? How about instrument training performed while working on the instrument rating? As long as it was logged in accordance with the words above, can it count towards the ten hours, even though it was performed prior to January 1, 2020? How do you know?

As a related question, does the learner need to complete 120 hours of flight training on/after January 1, 2020? If some of the under-the-hood time from 2019 counts towards the 10 hour requirement, doesn't it also count towards the 120 hours requirement? What other training from 2019 and earlier would count towards the 120 hour requirement?

Training under Part 61 is a fair bit simpler in this regard! Thanks in advance for the help.

 

[Brad Z]

I've found conflicting information online, but I find even CFIs are sometimes confused about this issue. I'm specifically discussing qualifying for the ASEL commercial checkride, but the principles likely apply to Instruments when Part 141 and other 141 courses. The flight training requirements for Commercial ASEL when already holding an instrument rating are (Part 141 Appendix D, italics are my words):

• Each approved course must include at least the following flight training, as provided in this section (Aeronautical knowledge training, section No. 3) and section No. 5 (solo training) of this appendix, on the approved areas of operation listed in paragraph (d) (preflight, takeoffs, navigation, etc.) of this section that are appropriate to the aircraft category and class rating for which the course applies:

1. 120 hours of training if the course is for an airplane...
2. 55 hours of flight training from a certificated flight instructor on the approved areas of operation listed in paragraph (d)(1) of this section that includes at least—
3. 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;
4. Ten hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane that meets the requirements of §61.129(j) of this chapter, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;
5. Cross Country Flights: 2hr/100nm day, 2hr/100nm night
6. 3 hours in a single-engine airplane in preparation for the practical test within 60 days preceding the date of the test.
7. Ten hours of solo flight time in a single engine airplane...The training must consist of the approved areas of operation under paragraph (d)(1) of section 4 of this appendix, and include—
8. Cross Country Flights: Big flight with 250 nm leg
9. 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.

The approved Part 141 curriculum for the commercial course will likely assume 120 hours of flight training, including at least 55 hours of dual, 10 hours of under-the-hood training, 10 hours in a complex plane (or the other permissible options), and 5 hours of night VFR. Assume the student got their private and instrument ratings under a mixture of part 61 and part 141, prior to January 1, 2020. Assume the student started the commercial curriculum on January 1, 2020 as well. Can some flight training performed prior to January 1, 2020 count towards any of the requirements above while under Part 141? The confusion is surrounding this exact question and I'd like to source/cite the answer so I can refer other people in the future.

The magenta text above regarding instrument training implies it's possible, at some level, to count flying that was not specifically performed on/after January 1, 2020. Under what scenarios would a commercial learner ( ) only need five instead of ten hours of instrument training in a single-engine airplane? Why would the commercial curriculum include 5 hours of training under-the-hood in a single engine airplane, and 5 hours of training under-the-hood in a multi-engine airplane or perhaps helicopter? How about instrument training performed while working on the instrument rating? As long as it was logged in accordance with the words above, can it count towards the ten hours, even though it was performed prior to January 1, 2020? How do you know?

As a related question, does the learner need to complete 120 hours of flight training on/after January 1, 2020? If some of the under-the-hood time from 2019 counts towards the 10 hour requirement, doesn't it also count towards the 120 hours requirement? What other training from 2019 and earlier would count towards the 120 hour requirement?

Training under Part 61 is a fair bit simpler in this regard! Thanks in advance for the help.

Don't confuse the 61.129 aeronautical experience requirements for the 141 Appendix D course requirements. The requirements you quoted above are the requirements for the course. You don't get credit for flight training received outside of the enrolled 141 course to count towards the 120 hour minimum requirement.

 

[MauleSkinner]

Whatever the course requirements are, they have to be completed as part of the course.

If you’ve already completed something that’s part of a 141 course into which you’re considering enrolling, you’ll have to do it again as part of the course.

 

[RingLaserGyroSandwich]

What you both said is what I was expecting from the beginning when I first read the requirements. However, that does not seem to explain the magenta text above. If you have to complete ten hours of hood time, why does it say that only five of them must be in a single engine airplane? What can the other five be? Why would they let the course include five hours of instrument training in another category or class?

 

[Brad Z]

What you both said is what I was expecting from the beginning when I first read the requirements. However, that does not seem to explain the magenta text above. If you have to complete ten hours of hood time, why does it say that only five of them must be in a single engine airplane? What can the other five be? Why would they let the course include five hours of instrument training in another category or class?

It gives the flight school the flexibility to combine things like single and multi-engine operations into the curriculum. This is mostly to meet the desire to maximize the amount of multi-engine flight time in a curriculum.

 

[dmspilot]

The flight training requirements for Commercial ASEL when already holding an instrument rating are (Part 141 Appendix D, italics are my words):

Those aren't flight training requirements. Those are minimum requirements to get a course approved. You must meet the requirements specified by the course you are enrolled in, regardless of what they are.

 

[RingLaserGyroSandwich]

Ahh this is making more sense now. I think I also understand why a CFI was telling me I don't need to get 10 full additional hours of hood time post instruments checkride. I believe my flight school's approved 141 program is to strictly follow the Jeppesen Instrument+Commercial curriculum. The single curriculum calls for 35 hours of flight training for stages 1-3 (instrument rating) and 120 hours of flight training for stages 4-6 (commercial). Since the curriculum is combined, hood time from stages 1-3 (pre January 1, 2020) can also count for stages 4-6 if logged properly, but 120 hours of flight training are still needed after January 1, 2020. Does that sound right?

 

[WDD]

So, for Part 61:
If you are a PPL with an instrument rating and are instrument current, and you've flown 250 hours as a PPL in a single engine airplane, don't you have just about everything already in the log book? You might still need a 250 X country with no one else in the cockpit, and make sure you have up to 10 hours of training in complex and/or TAA. But shouldn't you at this point pretty much be able to take the written, do practice prep hours with a CFI, and take the practical?

To obtain a commercial certificate in an airplane under FAR Part 61 rules a pilot must have:

• 250 hours of flight time, 100 hours of which must be in powered aircraft, and 50 must be in airplanes.
• 100 hours of pilot-in-command time, 50 of which must be in airplanes.
• 50 hours of cross-country time, 10 of which must be in an airplane.
• 20 hours of training, including 10 of instrument, 10 of complex or TAA, and a smattering of cross-country and practical test preparation.

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;

(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

(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.

• 10 hours of solo training, including a smattering of cross-country and night.