PPL vs CPL Hours Regulation Wording

[myercod]

Reading regulation legalese is always fun.
In regards to the total hour requirements per 61.109(a) and 61.129(a): 109 states "at least 40 hours of flight time..." and 129 states "at least 250 hours of flight time as a pilot..." Now, logic tells me that the 40 and 250 are total time, period. It is the use of the wording "as a pilot" in 129 that caught my eye. Would that imply the 250 hours comes from PIC time, whereas the 40 doesn't (since you don't earn all those hours as PIC during training for PPL)? Or did that 250-hour clock for your CPL start the first lesson you took for your PPL? Another reason I'm curious is someone once pointed out the wording in 61.109(a)(3) "3 hours of flight training... solely by reference to instruments..." and 61.129(a)(3)(i) "Ten hours of instrument training..." The point was made that, given the wording, the training in 109 did not require a CFI-I (the CFI is more acting as an instructor/safety pilot during those 3 hours of training), but the training in 129 required a CFI-I because of the use of the words "instrument training".
Lastly, in 61.129(a)(4) it begins "Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board..." The "or" implying it isn't 10 hours total of solo or not solo but performing as PIC, but 10 hours of one or the other. Thoughts?
Nitpicking the wording, but every now and then in training someone drops a little gee wiz knowledge they've gained over the years, and I'm curious how you'd all interpret the wording above. Thanks!

 

[flyingron]

The phrase "as a pilot" is redundant because as far as these regs are concerned "flight time" includes "pilot time" in its definition.

No "as a pilot" doesn't mean PIC time or anything else you are imagining.

Yes, the FAA has affirmed that the ten hours of instrument training for the instrument and commercial must be done by an instructor with an instrument rating on his instructor certificate. The three hours stuck into the private training doesn't count for either the commercial or instrument rating instrument training requirements.

It's all or nothing on the solo/cfi-dummy rule. The original wording just said solo. Because it was harder to find places that would rent certain aircraft (notably complex and/or multiengine) to students to sola, the FAA relented and allowed you to fly around pretending you were solo with the cfi being a dummy in the right seat. But you have to choose one of the other.

 

[myercod]

Excellent. Appreciate it.

 

[midlifeflyer]

Yeah, probably just an accidental redundancy probably attributable in part to the ATP " least 1,500 hours of total time as a pilot," which includes simulator time as well as flight time.

 

[Mikey52]

Well back when they had flight engineers, they got to log the time as total time. So that "as a pilot" was included so that the flight engineers could not use the time as a flight engineer to qualify for a pilot certificate.

So no, it is not redundant.

 

[midlifeflyer]

Well back when they had flight engineers, they got to log the time as total time. So that "as a pilot" was included so that the flight engineers could not use the time as a flight engineer to qualify for a pilot certificate.

So no, it is not redundant.

I looked further and I can see that. It's even discussed later in 61.129.

 

[BillTIZ]

Well back when they had flight engineers, they got to log the time as total time. So that "as a pilot" was included so that the flight engineers could not use the time as a flight engineer to qualify for a pilot certificate.

So no, it is not redundant.

Agreed, no one in the civilian world would accept my 2500hrs as a USAF Master Navigator towards any civilian ratings or positions. But it is 2500hrs in the air, working the National Airspace System, dealing with Air Traffic Controllers, and monitoring instrument approaches. Even with a few Airborne Radar Directed Approaches in the mix.

 

[flyingron]

Well back when they had flight engineers, they got to log the time as total time. So that "as a pilot" was included so that the flight engineers could not use the time as a flight engineer to qualify for a pilot certificate.

So no, it is not redundant.

It is redundant. FAR 1 defines flight time:

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 is not possible to have flight time that isn't pilot time.

Time as a FLIGHT ENGINEER isn't flight time under the regs. The few places where you can count that time specifically mention "flight engineer time."

 

[midlifeflyer]

Time as a FLIGHT ENGINEER isn't flight time under the regs. The few places where you can count that time specifically mention "flight engineer time."

The half dozen times it mentioned in 14 C.F.R. it's called "flight engineer flight time."

 

[Mikey52]

The half dozen times it mentioned in 14 C.F.R. it's called "flight engineer flight time."

Which seems to me, and the way it was done, to be included in total time. It's just not pilot time.

 

[jbarrass]

The three hours stuck into the private training doesn't count for either the commercial or instrument rating instrument training requirements.

The 3 Private hours "might" count if signed off by a CFII and the notes include reference to Instrument training. (Most don't, mine did)