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4 Answers

Commercial Pilot Aeronautical Experience

Asked by: 4627 views Commercial Pilot

I have a student with the following ratings: PRIVATE PILOT ASEL and INSTRUMENT AIRPLANE. All of his experience is in single engine airplanes, with the exception of some FTD time aqcuired during his instrument training. He wants to get his commercial pilot certificate in a multiengine airplane under part 61. I plan to have my MEI by the time he is ready begin his training.

Looking at 61.129(b)(4), it states that the applicant must have "10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in 61.127(b)(2) of this part that includes at least..."

Looking accordingly at 61.129(b)(2), it states that an applicant needs "100 hours of pilot in command flight time which includes at least [50 hours in airplanes] and [50 hours in cross-country flight of which at least 10 hours must be in airplanes]"

My question:

If my student is not rated to act as PIC of a multiengine airplane, then why do the FAR's tell me that I can credit this time (dual given instead of solo) towards the 100 hours of pilot in command flight time required under 61.129(b)(2)? Last time I checked, this cannot be logged as PIC under 61.51(e)(iv). I guess I'm just wondering if there is a legitimate way, aside from the 61.31(d)(2) PIC endorsement (which is not cited as necessary for the 61.129(b)(2) solo credit), that a student who holds a pilot certificate that is not yet rated to fly a particular aircraft but who has flown that aircraft with an appropriately rated flight instructor can log PIC time. With the way it's written, 61.129(b)(2), and even part 141 APP. D section 5 seem to equate this dual time with solo time, which through 61.51(e) is considered as PIC...

...Is this a legitimate way to log PIC or is this an arbitrary exception to aeronautical experience requirements?

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4 Answers

  1. Nathan Parker on Feb 29, 2012

    “Is this a legitimate way to log PIC”
    “is this an arbitrary exception to aeronautical experience requirements?”
    Yes, although “arbitrary” is not completely true.  The exception is allowed because the FAA acknowledged the reality that no insurance company is going to allow a non-rated pilot to solo a multi-engine aircraft.  It was a terrible solution to the problem, in my view.

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  2. Bill Trussell on Feb 29, 2012

    I believe the intent of this section is to mandate that there be at least 10 hours of expereince in the class of aircraft (MEL) before taking the checkride.  That said there is an out in that there is an allowance for 10 hours of dual while “performing the duties of PIC.  Note that it does not say “acting as PIC”
    In this case I believe that your student should meet all the requirements should he/she get 10 hours of dual instruction from you in a MEL aircraft, assuming they meet all the other requirements for the Commercial Pilot rating.  The time should not be logged as PIC.
    Keep in mind also that you as the instructor should have 5 hours of PIC in the type of aircaft to be used for this instruction in order to comply with your obilgations under the rules as well.

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  3. Matthew Waugh on Mar 12, 2012

    You’ve stumbled into the reason why everybody gets their SINGLE engine commercial first – and then the multi is just a “train to proficiency”.
    If your student has a pile of money then you can wade through the owning or renting a multi-engine plane to get a commericial initial – then go for it – great for you, a new ly minted MEI, although you may find it hard to find a plane you can train in (for insurance, not FAA reasons).

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  4. Nicholas Terleckyj on Mar 12, 2012

    My student was in the marines and the government is going to pay for his training while he goes to school. He wants to get twin time as he is working towards his commercial. I’ve spoken with an inspector from the DuPage FSDO and he suggested that the instructor logs nothing at all for this “supervised solo” flight while the student logs solo, but no PIC or dual received. According to the FAR’s, this supervised solo time can be credited towards the PIC time required to get your commercial AMEL. Interestingly, 61.129(b)(4) states that an authorized instructor needs to be on board, and in the definitions section, part 61 defines an authorized instructor as “A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with §61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate”.
    An authorized instructor is, therefore, an authorized instructor when conducting ground or flight training. The student must be in the cockpit with an authorized instructor for insurance purposes. So therefore, the student, who is endorsed under 61.31 to act as PIC of the aircraft, must receive ground or flight training? Further, 61.51 states: “A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.” Why can’t the instructor log PIC time?
    Here is something else that is kind of weird. Perhaps I haven’t thought about it fully enough, but here it goes: Let’s say a Commercial pilot with a rotorcraft helicopter rating desires a commercial pilot certificate in a multiengine airplane. Commercial pilot eligibility minimums only state that the applicant must hold at least a Private pilot certificate. Technically, the commercial RH pilot has at least a Private pilot certificate. Do we assume that this applicant has to get his private pilot AMEL before he gets his commercial pilot AMEL?

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