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Commercial aeronautical experience (spec 61.129(a)(3)(i) and 61.129(a)(4)(ii))

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General Aviation

Hi, I was wondering about two issues with respect to Aeronautical Experience for commercial pilot:

  1. Re the Aeronautical Experience described in 61.129(a)(4)(ii) (i.e., the solo "5h in night VFR conditions" and "10 take-off and landings [...]"): does it need to be accomplished in the same flight or can it be accumulated across different flights (e.g., today I'll do 10 t/offs and landings in night VFR with control tower, next week I'll get up in the air and do 5hrs of night VFR)? I read a prior answer explaining that since it is experience I could achieve it in different flights, but then why aren't these two separate requirements (e.g., 4(ii) and 4(iii)...)?
  2. Re the Aeronautical Experience described in 61.129(a)(3)(i), I have read prior answers to say/imply that my non-specifically 61.129 hours of instrument training (I am IFR rated) do not count. Yet, I cannot quite find where that is in the regs? My (perhaps naive) reading of that 61.129(a)(3)(i) is that I need to have logged at least 250 hrs, of which 10 must be instrument training -- that's it. Wouldn't it also say "excluding training counting towards 61.65(d)" or something like that?

Thanks for any clarifications -- happy flying

Martin

8 Answers



  1. KDS on Nov 26, 2020

    Regarding your first question, why did they do it the way they did it, I can only guess. But, I believe your interpretation is correct.

    For your second question, Google “FAA Legal Interpretation Daniel Murphy 2011”.

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  2. MCube78 on Nov 28, 2020

    Hi KDS,

    thank you for the answers. So I read up on Murphy 2011 and also Theriault 2010 (referenced in Murphy 2011). It seems to me that both of those are about using training for a Private Pilot Certificate (so while someone was a student pilot) as a substitute for Commercial, not training for IFR.

    Reading the two letters, the FAA says “the applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see§61.127), not while training for a different certificate” which is then further clarified in Murphy 2011 by stating that “Because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards,the type of training contemplated by§ 61. 129(a)(3)(iii) is not interchangeable with the kind required for a private pilot certificate.”

    Given the above, I would argue that (1) IFR is an endorsement, not a certificate, so since I was doing my IFR training after having completed my PPL, I was not training for another certificate at the time; and (2) I don’t think there are different IFR standards/maneuvers for commercial versus private (are there?), so that the point in Theriault 2010 also does not apply.

    What do you think?

    Cheers — and thank you for the input

    martin

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  3. MCube78 on Nov 28, 2020

    KDS, I take my above answer back (sorry, cannot seem to be able to delete it?).

    Whether my two points above have legal standing or not, there is an additional point in the Theriault 2010 letter that I think answers my request (in the negative).

    Essentially it says that (for helicopter) you cannot use 61.55(e) in substitution of 61.129(c) because the latter lists specific maneuvers (i.e., (3)(i) Five hours on the control and maneuvering of a helicopter 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.) whereas 61.65 is “general”.

    Given this, it seems to me to be an obvious extension that, for airplane, 61.65(d) CANNOT be used as a substitute for 61.129(a)(3)(i) since the latter also specifies “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.”

    sorry for the confusion — but thank you for making me read these letters!

    cheers

    Martin

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  4. KDS on Nov 29, 2020

    I definitely agree with you that reading the legal interpretations is not fun. They do seem to go the long way around to answer a question.

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  5. Mark Kolber on Nov 29, 2020

    Your question has been answered but just a note about being careful about technical language when reading the FAR.

    For example, “Given the above, I would argue that (1) IFR is an endorsement, not a certificate,” No, the IR is neither a certificate nor an endorsement. It is a rating.

    There are two others here. The use of the word “instrument training” in 61.65 and 61.129, but not in 61.55. And when you read that series of interpretations, they are really less about certificate vs certificate and rating vs rating than about the meaning of “on the areas of operation.”

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  6. Mark Kolber on Nov 29, 2020

    BTW on the first question, “5 hours in night VFR conditions with 10 takeoffs and 10 landings” just means a minimum of 5 hours of night VFR which includes 10 takeoffs and landings.

    You said, “today I’ll do 10 t/offs and landings in night VFR with control tower, next week I’ll get up in the air and do 5hrs of night VFR.”

    Why? Lets suppose you are based at a towered airport so you don’t have to go anywhere else. You decide for some reason to do all the 10 takeoffs and landings in the pattern inone session. That’s takes, say .1 hour for each landing, so call it an hour. You only have another 4 hours to go.

    And that all assuming you have never flow solo at night into a towered airport before. All that stuff can be combined. I had a friend who visited us for dinner one evening in the middle of his log solo cross country, knocking out a lot of his remaining night requirements along with his cross country.

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  7. MCube78 on Nov 29, 2020

    Mark, thank you, that’s what I meant — wasn’t until I read your comment that i realized I said endorsement!

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  8. Paul H. on Dec 08, 2020

    I went to my commercial practical test as an instrument rated private pilot. I did not get 10 additional hours of instrument training between receiving my instrument rating and going to my commercial check ride.

    This was blatantly obvious, as the logbooks I used to show my instrument training experience were from a part 141 school where different log books are used for each semester, and the logbooks for my instrument rating (2 semester courses for the rating) were clearly labeled as such. The training I got for my commercial rating was Part 61 and recorded in a more normal log book.

    The examiner accepted them without comment.

    My commercial check ride was Part 61 and not associated with the Part 141 school where I got my PPL and Instrument Rating.

    I also got my commercial certificate with almost exactly 250 flight hours, but only if I included the simulator time. A significant percentage of those hours were flown while I was still a student pilot, yet they counted toward my aeronautical experience requirements for the commercial certificate. The Murphy letter deals specifically with XC requirements, but the logic used seems to imply that the vast majority of my 250 hours flight experience shouldn’t have counted either, since they weren’t flown “to commercial standards.”

    For that matter, I also flew the equivalent of the “long commercial XC” while I was an instrument student, and the examiner counted that one as well.

    I’m just one, random, low-time CFI on the internet, but my experience was that my instrument training experience was my experience, no matter when I got it, and it met the requirements for 61.129 even though it was obtained during an instrument rating course.

    I suggest that you speak to your dpe ahead of time and get his or her opinion. That’s the person who will be making the decision on the day of your check ride.

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