Question about night flight landing requirements for Private and Commercial licences.

7 Answers

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   Mark Kolber on Aug 19, 2013

   I’ve never seen a formal definition or interpretation of “flight in the traffic pattern” but can’t help but think that, the FAA envision someone finding a very long runway and doing 3 takeoffs and landings on each pass. Hence the “traffic pattern” requirement.

   With that said, the purpose of the pattern requirement is to ensure you can mix with other traffic and, at a towered airport, follow ATC instructions. My take is that it does not require full circuits but only the joining of a normal traffic pattern. Yes, your joining the downwind (or base or extended runway centerline) is a flight in the traffic pattern.

   But no, the landings you did for your PPL don’t count. For the commercial in a single-engine airplane (the others are similar), the 10 night landing requirement is in 61.129(a)(4) which has the the magic words (my emphasis):

   ==============================
   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 (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under § 61.127(b)(1) that include–
   ==============================

   The magic words “on the areas of operation” is the FAA’s way of saying that, even though the task sounds exactly the same as one you did for a lower grade certificate or rating, it’s really not, and you can’t use the earlier one. The phase is used all the time, always with the same purpose.

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   Mark Butros on Aug 19, 2013

   Thanks Mark. My old instructor was an idiot. It looks like I need 10 hours of training with 5 in the sim and 5 under the hood too…. what an idiot my instructor is. I’m almost done with my training, and used up a lot of my pre paid hours.. I looked at 61.127(b)(1), and it does look like the exact things that were covered in IFR though. Is your interpretation commonly held? If so, I now need to rent an airplane for a solo flight to bang out these landings, plus do possibly 10 hours of instruction…..

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   Mark Kolber on Aug 19, 2013

   Don’t know how “commonly held” it is. People believe all sorts of things. But here are two FAA Chief Counsel opinion letters applying it:
   • 2010 Theriault opinion (http://goo.gl/dKYTI7) – commercial pilot applicant may not use student pilot dual night cross country to meet commercial requirements.
   • 2010 Murphy opinion (http://goo.gl/GFvPVy) – the second half of the letter discussed that student pilot may not complete the commercial dual cross countries.

   and the proverbial exception that proves the rule, the 2011 Hartzell opinion (http://goo.gl/bcSPXR) – instrument training for the instrument rating may be used to satisfy commercial instrument training requirements, but only if properly documented by the instructor.

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   Mark Kolber on Aug 19, 2013

   and it does look like the exact things that were covered in IFR though.

   I just noticed this part – the instrument work done for the instrument rating is covered by the Hartzell “exception.” As you’ll read in the letter, the FAA recognizes that the instrument tasks you performed to get the instrument rating are probably good enough (pretty obvious, isn’t it, since 99% of the commercial tasks are visual tasks?) to meet the commercial’s instrument training tasks.

   All that’s needed is for it to be documented properly as meeting both requirements. That may mean asking your instrument CFII to go back and modify the entry to reflect this (assuming, of course, your CFII agrees it does which is likely)

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   Mark Butros on Aug 19, 2013

   Thanks again. Perhaps I don’t have to waste more money thanks to the Hartzell exception. I’m going to see my old CFI tonight to give me some endorsements he never signed. How exactly does he need to document this? As a written endorsement in the back of my logbook referencing the Hartzell letter, or as some additional scribbles on the actual flights where 61.127 was satisfied?

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   Mark Butros on Aug 19, 2013

   I might add that, though I’m doing commercial as part 61, I did IFR part 141.

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   Mark Kolber on Aug 19, 2013

   There’s a good chance he knows; some 141 schools combine the instrument and commercial so they’ve been doing it for a while. Just in case, though, you may want to print a copy of the Hartzell letter to show to him.

   There’s unfortunately no post-Hartzell guidance from the FAA to tell us how to do it. So anything I say is nothing more than a WAG from SGOTI. But understanding this isn’t advice that can be relied on, personally, I’d either

   • simply include a reference in the comments for the individual lessons. For example, “Timed Turns, non-precision approaches” would become “”Timed Turns, non-precision approaches. Ref. 61.65(c); 61.129 (a)”

   • create a blanket endorsement certifying that the instrument training I provided between stated dates met the instrument training requirements of 61.129(a) as well as those of 61.65(c).

   It’s an easy call to use the line-item method when making the original entry but a tougher call when going back to correct entries; sometimes revising an entry raises more questions than it answers. Unfortunately, unless the 141 school has some internal guidelines on it, you and your CFII are on your own.

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