Part 61 and 141 Transfer credit

[Joshua Mamajek]

I got my PP at a part 61 flight school about 2 years ago. Soon after i heard about a local college opening up a 141 flight school in a years time. Obviously through the 141 i had to get my instrument rating with the university so in the meantime i flew random XC's to stay current and slowly gain hours. I ended up going into the first semester with about 115 total hours and about 40 XC time. Thinking that all of those hours would help in the long term for my commercial license, A fellow student told me only 25% of the hours will now transfer. So does that mean next semester when i start my commercial, instead of starting with maybe ~150 total hours that id have to take 25% of 115 and add whatever time it took to get my instrument at the university? Trying to confirm because its a little confusing.

 

[Clip4]

Many University 141 Schools are professional pilot training programs. If you opt for a 141 program, you are required to complete the training and solo time contained in that schools syllabus. The syllabus must meet the FAA minimum requirements and may exceed those requirements.

The regulatory instruction requirement is 55 hours and solo requirement is only 10 hours. Solo flying at a 141 school has a training purpose.

“Ten hours of solo flight time in a single engine airplane, or 10 hours of flight time while performing the duties of pilot in command in a single engine airplane with an authorized instructor on board. The training must consist of the approved areas of operation under paragraph (d)(1) of section 4 of this appendix, and include -

One cross-country flight, if the training is being performed in a State other than Hawaii, with landings at a minimum of three points, and one segment of the flight consisting of a straight-line distance of at least 250 nautical miles; and

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.

 

[Wheels]

FAR 141.77 gives the conditions under which a 141 school may decide to give you credit for prior training.

 

[Clip4]

FAR 141.77 gives the conditions under which a 141 school may decide to give you credit for prior training.

A student who enrolls in a course of training may receive credit for not more than 25 percent of the curriculum requirement for knowledge and experience received from other than a part 141 pilot school or 14 CFR part 142 approved aeronautical or flight training course.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_141-1B.pdf

 

[dmspilot]

I got my PP at a part 61 flight school about 2 years ago. Soon after i heard about a local college opening up a 141 flight school in a years time. Obviously through the 141 i had to get my instrument rating with the university so in the meantime i flew random XC's to stay current and slowly gain hours. I ended up going into the first semester with about 115 total hours and about 40 XC time. Thinking that all of those hours would help in the long term for my commercial license, A fellow student told me only 25% of the hours will now transfer. So does that mean next semester when i start my commercial, instead of starting with maybe ~150 total hours that id have to take 25% of 115 and add whatever time it took to get my instrument at the university? Trying to confirm because its a little confusing.

No, the transfer limit isn't 25% of your flight time, it's 25% of the course requirements. If the course requires 40 hours (for example) you may transfer 25%*40 hours = 10 hours. So you will need to know the hour requirements of the individual course(s) you wish to transfer hours to.

 

[Clip4]

No, the transfer limit isn't 25% of your flight time, it's 25% of the course requirements. If the course requires 40 hours (for example) you may transfer 25%*40 hours = 10 hours. So you will need to know the hour requirements of the individual course(s) you wish to transfer hours to.

He can’t transfer training hours because he was “time building” and has no training hours to transfer.

 

[dmspilot]

He can’t transfer training hours because he was “time building” and has no training hours to transfer.

Sounds like another example of you making up your own FAR interpretation and posting it as fact.

 

[Clip4]

Sounds like another example of you making up your own FAR interpretation and posting it as fact.

The regulation allows for the transfer of training. OP is transferring Zero hours of training because he is not in training.

 

[dmspilot]

The regulation allows for the transfer of training. OP is transferring Zero hours of training because he is not in training.

Why? You can't build time and train at the same time? What a stupid statement.

 

[Clip4]

Why? You can't build time and train at the same time? What a stupid statement.

Sure you can, all you need is a CFI signature associated with each flight.


§ 61.189 Flight instructor records.
(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.


And the 141 school may accept a 25% transfer of that time toward the training requirements.

 

[kath]

I would assume that when the regs use the word "training" they mean "dual instruction".
The OP has been building time (and XC hours, etc.) on his own for a while, as PIC time, without a CFI.
So would those hours still count towards a 141 commercial program? Towards the "total hours" requirement, or "solo" or "solo XC" or those sorts of things?

 

[Clip4]

I would assume that when the regs use the word "training" they mean "dual instruction".
The OP has been building time (and XC hours, etc.) on his own for a while, as PIC time, without a CFI.
So would those hours still count towards a 141 commercial program? Towards the "total hours" requirement, or "solo" or "solo XC" or those sorts of things?

Probably <60 hours depending on the schools syllabus for an IR + Comm. program. Some schools will make the student take a transition course with the hours counting toward the commercial. Embury Riddle as an example. It’s polite way of saying we aren’t accepting your private certificate without more training. It’s not a bad idea if transitioning from Part 61 to a professional pilot program.

Part 141 Programs assume you go from zero to hero at one school. The problem is some want to go to the 141 School because there is a 60 hour training savings thru IR commercial, but the FAA is stingy with counting any other training time you bring with you from a different school.

 

[dmspilot]

I would assume that when the regs use the word "training" they mean "dual instruction".

Your assumption is incorrect.

 

[dmspilot]

Sure you can, all you need is a CFI signature associated with each flight.
§ 61.189 Flight instructor records.
(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.

Wrong again. Solo flight training is flight training. Additionally, your earlier statement combined with this one requires you to assume OP has never flown with a CFI ever. Again, you are full of ridiculous statements and absurd assumptions.

 

[kath]

Your assumption is incorrect.

Wrong again. Solo flight training is flight training.

Mmmmm, whaaaaaaaat? ...the FAA actually defines that phrase:
From the "definitions" bit of Part 61:
--------
Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft.
Ground training means that training, other than flight training, received from an authorized instructor.
...
Training time means training received -
(i) In flight from an authorized instructor;
(ii) On the ground from an authorized instructor; or
(iii) In a flight simulator or flight training device from an authorized instructor.

-------... and then there's this bit:
Logging training time.
(1) A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.
(2) The training time must be logged in a logbook and must:
(i) Be endorsed in a legible manner by the authorized instructor; and
(ii) Include a description of the training given, the length of the training lesson, and the authorized instructor's signature, certificate number, and certificate expiration date.
-------

...now, part 61 does phrase things sometimes confusingly like: "(for PPL) 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation listed...", ...so is it these particular phrasings that you're talking about? In which case, this would seem a highly unusual interpretation of the FAR's. Outside of a few odd (and perhaps poorly-chosen) phrases here and there in the Private/Sport Pilot section, when the FAR's talk about "flight training" they're talking about the CFI-y type defined in 61.1, for which 500 hours of burger-runs (no CFI, no logbook-signing) does not count.

...At least in Part 61. Maybe there is some weird corner of Part 141 that I'm not versed in...? In which case, feel free to school me, as I don't really know Part 141 at all.

I don't think the OP's question or @Clip4's take is stupid or absurd at all. "Flight experience" and "Flight training" are two different things to the FAA. So the OP needs to know if the "25% transfer thing" applies to one, or the other, or both.

 

[dmspilot]

...At least in Part 61. Maybe there is some weird corner of Part 141 that I'm not versed in...? In which case, feel free to school me, as I don't really know Part 141 at all.

There is no weird corner. In Part 141, every hour is "training" because it is part of an approved training course, including solo and what in Part 61 would be considered "time-building".

 

[Albany Tom]

So....141 transfers are degraded. That makes sense, in that the FAA doesn't look at 141 as a bunch of hours, but rather some sort of magical program, where people learn more efficiently than part 61. That's why it takes fewer hours. Going between different schools, they have different magic, so you have to take steps back, closer to starting from scratch.

Back to OP, why not just do the rest of everything part 61? Then you'll need a reasonable number of hours to get things done, but every hour of dual or solo counts. Because it's not magical.

 

[Clip4]

There is no weird corner. In Part 141, every hour is "training" because it is part of an approved training course, including solo and what in Part 61 would be considered "time-building".

The stuff you read on beer night. Solo under Part 141 is not logged as training although solo is part of the training course. No different than 61 - it is an experience requirement.

 

[dmspilot]

The stuff you read on beer night. Solo under Part 141 is not logged as training although solo is part of the training course. No different than 61.

Your first sentence is not a complete sentence. The rest of your post is incorrect. Part 61 makes numerous references to "solo flight training." Your argument, that solo is not training even when it is part of a training course, is garbage. And self-contradictory.

 

[kath]

OK, so I'm having a look at Part 141 (for the first time ever, actually...!), specifically the Commercial Pilot section.

First of all, it also says that for CP, "Each approved course must include at least the following flight training,.....120 hours of training if the course is for an airplane or powered-lift rating". Now that *must* include solo time, because otherwise, BOY HOWDY is that a lot of hours! Is that really right?? For *just* the commercial, not total? I'll have to look up how many hours I spent training for my CP under Part 61, but there's no way it was that much. You can only practice chandelles and lazy-8's for so long. How is this saving time?

Then, each approved course must include "55 hours of flight training from a certificated flight instructor..." and this includes things like the complex/TAA, the night XC, the day XC, and the 90-days-before-checkride. Again, this is for *just* a commercial course, and not total, right? Seems like an awful lot!

Then, there's a whole section about "solo training", which includes things like the long solo commercial XC.

This sure is illuminating. I can totally understand how it can be confusing. I have more questions now than I did going in. No idea where to look for this "25% transfer" business.

 

[Clip4]

The 120 includes the training time for the private and instrument. 141.77 (c) (4) and (5) for transfer of training from 61.

 

[Clip4]

Also don’t get too wrapped up on the hours. Most 141 schools have inexperienced instructors who do not teach very efficiently and the hours exceed 141 minimums. 190 total time 141 vs 250 part 61 are needed for the comm.

 

[dmspilot]

OK, so I'm having a look at Part 141 (for the first time ever, actually...!), specifically the Commercial Pilot section.

First of all, it also says that for CP, "Each approved course must include at least the following flight training,.....120 hours of training if the course is for an airplane or powered-lift rating". Now that *must* include solo time, because otherwise, BOY HOWDY is that a lot of hours! Is that really right?? For *just* the commercial, not total? I'll have to look up how many hours I spent training for my CP under Part 61, but there's no way it was that much. You can only practice chandelles and lazy-8's for so long. How is this saving time?

Then, each approved course must include "55 hours of flight training from a certificated flight instructor..." and this includes things like the complex/TAA, the night XC, the day XC, and the 90-days-before-checkride. Again, this is for *just* a commercial course, and not total, right? Seems like an awful lot!

Then, there's a whole section about "solo training", which includes things like the long solo commercial XC.

This sure is illuminating. I can totally understand how it can be confusing. I have more questions now than I did going in. No idea where to look for this "25% transfer" business.

You are confused because you thought Clip knew what he was talking about and then you read Part 141 yourself. Now you have cognitive dissonance.

 

[dmspilot]

The 120 includes the training time for the private and instrument. 141.77 (c) (4) and (5) for transfer of training from 61.

Lol you are funny. Show me one example of a person obtaining a commercial pilot certificate with 120 hours total time. You fell off your rocker into another spacetime continuum.

 

[Clip4]

Lol you are funny. Show me one example of a person obtaining a commercial pilot certificate with 120 hours total time. You fell off your rocker into another spacetime continuum.

Show me where I said 120 total time?

 

[dmspilot]

Show me where I said 120 total time?

I was using your premises to draw a conclusion which is demonstrably false to show that your premises are incorrect. Since you don't follow, I'll put it more simply: the 120 hour Part 141 commercial course requirement does not include credits from private or instrument training. The minimum to obtain a commercial airplane certificate under Part 141 is 190 hours: 35 + 35 + 120 (private + instrument + commercial).

Furthermore, to reiterate from earlier, I will point out that the phrase "solo flight training" occurs in Part 141 twelve times, and in Part 61 thirteen times, and "solo training" appears once in each of Parts 61 and 141. (Of course this excludes similar phrases with a different meaning such as "pre-solo flight training".) But you said there is no such thing as solo training, and that solo flight time does not count as training time under either part.

 

[Clip4]

I was using your premises to draw a conclusion which is demonstrably false to show that your premises are incorrect. Since you don't follow, I'll put it more simply: the 120 hour Part 141 commercial course requirement does not include credits from private or instrument training. The minimum to obtain a commercial airplane certificate under Part 141 is 190 hours: 35 + 35 + 120 (private + instrument + commercial).

Furthermore, to reiterate from earlier, I will point out that the phrase "solo flight training" occurs in Part 141 twelve times, and in Part 61 thirteen times, and "solo training" appears once in each of Parts 61 and 141. (Of course this excludes similar phrases with a different meaning such as "pre-solo flight training".) But you said there is no such thing as solo training, and that solo flight time does not count as training time under either part.

There is no such thing as solo flight training other than the training required before a CFI can endorse a student for solo. Training requires a CFI onboard and the CFI to endorse the logbook.

Solo training as you refer to it is experience and the FAA regulatory definitions clearly state that. The Sections you reference are titled Experience. The definition of solo does not require any Instructor participation or even to be under the supervision of an instructor. An ATP can log solo time.

 

[dmspilot]

There is no such thing as solo flight training other than the training required before a CFI can endorse a student for solo. Training requires a CFI onboard and the CFI to endorse the logbook.

The point isn't moot, your claim is that OP can transfer a maximum of zero hours since solo time is not training time.

I understand you are in the habit of doubling down on being wrong, despite the clear and simple evidence staring you in the face. The following are two examples, but it only takes one to disprove your thesis.

§ 61.109 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (k) of this section, a person who applies for a private pilot certificate with an airplane category and single-engine class rating must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training

---------------------

Appendix B to Part 141 - Private Pilot Certification Course
...
Solo flight training. Each approved course must include at least the following solo flight training:
(a) For an airplane single-engine course: 5 hours of solo flight training in a single-engine airplane on the approved areas of operation in paragraph (d)(1) of section No. 4 of this appendix that includes at least -​

 

[Clip4]

I think you should ask the lawyers at the FAA Chief Council’s office for an opinion. I believe the commanding sections are below.


Training time means training received -

(i) In flight from an authorized instructor;

(ii) On the ground from an authorized instructor; or

(iii) In a flight simulator or flight training device from an authorized instructor.




(h) Logging training time.

(1) A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.

(2) The training time must be logged in a logbook and must:

(i) Be endorsed in a legible manner by the authorized instructor; and

(ii) Include a description of the training given, the length of the training lesson, and the authorized instructor's signature, certificate number, and certificate expiration date.

If the time does not meet those requirements, it isn’t training time.

 

[Kritchlow]

I am very happy that my instructor days are long behind me.

 

[dmspilot]

I think you should ask the lawyers at the FAA Chief Coumcils office for an opinion because
61.51 Pilot logbooks clearly states

(h) Logging training time.

(1) A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.

I think you should, since according to you, it is impossible to comply with 61.109(a) (among other regs) which requires 10 hours of solo flight training. Since you say there is no such thing, every private pilot certificate issued since the regulation was written is invalid. Nevermind the 24 other times the phrase "solo flight training" is used in 14 CFR Parts 61 and 141.

 

[Clip4]

And let me add this from 141.77 for you.
5) Completion of previous training must be certified in the student's training record by the training provider or a management official within the training provider's organization, and must contain -

(i) The kind and amount of training provided; and

(ii) The result of each stage check and end-of-course test, if appropriate.

 

[dmspilot]

And let me add this from 141.77 for you.
5) Completion of previous training must be certified in the student's training record by the training provider or a management official within the training provider's organization, and must contain -

(i) The kind and amount of training provided; and

(ii) The result of each stage check and end-of-course test, if appropriate.

Completely irrelevant. The paperwork process to transfer time has zero impact on the ability to do so.

 

[Clip4]

61.87. The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft or that flight time during which the student performs the duties of a pilot in command of a gas balloon or an airship requiring more than one pilot flight crewmember.



Flight time means:
(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing; or
(2) For a glider without self-launch capability, pilot time that commences when the glider is towed for the purpose of flight and ends when the glider comes to rest after landing.

It does not mean training time.

End of the debate on my end.

 

[dmspilot]

The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft or that flight time during which the student performs the duties of a pilot in command of a gas balloon or an airship requiring more than one pilot flight crewmember.

It does not mean training time.

End of the debate on my end.

You posted the definition of solo flight, good for you. Does not support your claim in the slightest.

You have yet to explain why, if there is no such thing as "solo flight training" time, or "solo training", why do those terms appear in the FARs 27 times?

You think a person cannot transfer Part 61 "solo flight training" (for example, the "10 hours of solo flight training" required by 61.109(a)) to meet the Part 141, Appendix B item 5 requirement of "5 hours solo flight training" because there's no such thing as solo training. Huh.