Interpretation 61.129

Vance Breese

Cleared for Takeoff
Joined
Oct 10, 2014
Messages
1,061
Location
Santa Maria, CA
Display Name

Display name:
Vance Breese
Another recent thread started me wondering about my designated examiners interpretation of the training requirements.
The training I took for my private pilot, rotorcraft-gyroplane rating included most of the training requirements for commercial rotorcraft gyroplane except for the instrument requirement.
I am blind in one eye and have had a TBI so my training was probably more extensive than most private pilot rotorcraft-gyroplane pilots.
I trained with a CFI for three hours in preparation for the practical and learned to fly a fixed wing for the 2.5 hours on the control and maneuvering of a gyroplane solely by reference to instruments using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems.
The way my DPE interpreted this section was that any training I received for my private pilot, rotorcraft-gyroplane rating did not count for my commercial training requirements. He felt only training I received after my private pilot rotorcraft/gyroplane rating would count toward the training requirements of the commercial gyroplane rating.
It appears to me it would work the same for commercial training for single engine but I included the rotorcraft- gyroplane training requirements just in case there is something different because I understand most of you are fixed wing pilots.
I am working to become a gyroplane CFI so it would be helpful if I had a better understanding of the FARs.
I am working a trade show this weekend so I may not get to see the opinions right away so thank you in advance

(d) For a gyroplane rating. A person who applies for a commercial pilot certificate with a rotorcraft category and gyroplane class rating must log at least 150 hours of flight time as a pilot (of which 5 hours may have been accomplished in a flight simulator or flight training device that is representative of a gyroplane) that consists of at least:
(1) 100 hours in powered aircraft, of which 25 hours must be in gyroplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least—
(i) 10 hours in gyroplanes; and
(ii) 3 hours in cross-country flight in gyroplanes.
(3) 20 hours of training on the areas of operation listed in § 61.127(b)(4) of this part that includes at least—
(i) 2.5 hours on the control and maneuvering of a gyroplane solely by reference to instruments using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device;
(ii) One 2-hour cross country flight in a gyroplane in daytime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure;
(iii) Two hours of flight training during nighttime conditions in a gyroplane at an airport, that includes 10 takeoffs and 10 landings to a full stop (with each landing involving a flight in the traffic pattern); and
(iv) Three hours in a gyroplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.
 
I believe your DPE is confusing the requirements for airplanes with the requirements for gyroplanes. Unlike airplanes, there is no requirement for any instrument work for the PP-RG rating. The first time any instrument work is required for a gyroplane rating is for CP. Therefore, any prior flight training you got in the control and maneuvering of a gyroplane solely by reference to instruments was required only by 61.127/129, not 61.107/109, and so should count towards the CP-RG requirement. I suggest you and the DPE contact the FSDO to obtain clarification, which may have to come from AFS-810 at FAA HQ.

The situation is completely different for airplanes because PP-Airplane requires "3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight", which may be given by a CFI-Airplane who is not an instrument instructor, while CP-Airplane requires "Ten hours of instrument training", which is something else entirely and must be given by a CFI with both Airplane and Instrument-Airplane ratings (i.e., an "instrument instructor"). As such, the 3 hours for PP-A does not count towards the 10 hours for CP-Airplane. One could obtain instrument training from a CFI-IA beyond the 3 hours required for PP-Airplane, and that would count for the CP-Airplane requirement no matter when it was logged. But that's a totally different situation.
 
Thank you Ron; I took the instrument training after I received my private pilot rotorcraft certificate so that was not a problem.
The challenge came with the night training. I had to do it once for private and once for commercial.
It was the same thing with the cross country.
I have my commercial now so it is no longer a challenge.
The interpretation just caused some extra time with a CFI and I always learn something.
I have some potential students and I want to be certain I give them the right answers.
Thank you very much for you help.
 
Vance, in some of my early Part 61 airplane instruction my CFI actually noted "to commercial standards" in my log for tasks like maintaining altitude and airspeed, and I wondered why at the time, since I was training for the Private certificate.

Now, it makes sense.
 
The challenge came with the night training.I had to do it once for private and once for commercial.
It was the same thing with the cross country.
Because PP-RG and PP-Airplane both have night training requirements, the situation with night training is the same in both Airplanes and Gyroplanes -- you can't count the training you did to meet the PP training requirements towards the CP training requirements, and any additional night training you got beyond the PP requirements before you got the CP would have to be signed as being to meet the CP requirements or it won't count to meet those CP requirements.
 
Vance, in some of my early Part 61 airplane instruction my CFI actually noted "to commercial standards" in my log for tasks like maintaining altitude and airspeed, and I wondered why at the time, since I was training for the Private certificate.

Now, it makes sense.

Thank you for your input Paul.
When I took my private pilot practical the DPE said I was flying to commercial standards.
I don’t know why I can’t just read the FARs and understand them.
Maybe some day?
 
Because PP-RG and PP-Airplane both have night training requirements, the situation with night training is the same in both Airplanes and Gyroplanes -- you can't count the training you did to meet the PP training requirements towards the CP training requirements, and any additional night training you got beyond the PP requirements before you got the CP would have to be signed as being to meet the CP requirements or it won't count to meet those CP requirements.

Thank you Ron.
I am grateful for your help.
I suspect I have a mental block because I keep trying to imagine there is some logical safety reason for the FARs.
Some of them do make sense to me, some not so much.
I don’t know how I am going to manage that when I am a CFI.
I suppose I could ask the student; How do you interpret that?
I have a friend at the local FSDO that helps me sometimes but even he is not always correct.
I have ended up writing a letter to legal twice.
I am amazed how black and white the FARs are to some on this message board.
I have learned a lot here; thank you all.
 
Back
Top