Ten Hours Is All That Is Req. For a Heli Private Add-On...

Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

nosehair said:
61.109(c) these are requirements for a helicopter: "...that includes 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation in 61.107(b)(3).

Note the bold 'and'
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"20 hours of flight training from an authorized instructor" is not specifically required to be from "an authorized instructor in a helicopter." After "and," only the 10 hours specifically relates to flight time that is required in a helicopter (as it is a reference directly to the areas of operation in 61.107(b)(3)); this is where we seem to disagree. But based on the opinion of three different Inspectors (from three different districts), they all explained it to me in this manner (and this was my original interpretation as well).

nosehair said:
The 20 hours from an authorized instructor is a helicopter instructor, and the areas of operation are helicopter operations listed in (b)(3), which are the list of TASKs on the PTS.

The above is fact, the following is my opinion.
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Again, where in the regulations does it specifically specify that the 20 hours must be from a "helicopter instructor?"

nosehair said:
The above is fact, the following is my opinion.
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It's your personal interpretation; but I can see how it can be misinterpreted. And if you are indeed correct, then the regulation is poorly written.

mojo6911 said:
The FAA has a legal department who are the only ones authorized to interpret the regulations. The only legal interpretations can be found here:

http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/interpretations/

The FSDO inspectors aren't authorized to interpret regs officially.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/
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Those links are useful; but none of those links verify your claim. You originally claimed that "the FSDO's opinion has no bearing in FAA legal proceedings. It is pretty worthless." Those links do not substantiate such claim. So again, what source indicates your claim that "...FSDO's opinion has no bearing in FAA legal proceedings?"

Note the following link: http://www.faa.gov/about/office_org/field_offices/fsdo/

According to the aforementioned link, the FAA seems to indicate that one's local FSDO is responsible for questions pertaining to "Airmen certification (licensing) for pilots, mechanics, repairmen, dispatchers, and parachute riggers." That is exactly what I did for the interpretation of this regulation. And the interpretation was corroborated by Inspectors from three different FSDOs.

Yes, I understand that the 10 hours of solo time -- in addition to the three hours of practical test preperation -- is not conducive to producing a proficient pilot; this is what you seem to allude to -- and it may not even be possible in almost all cases. However, law and regulations are not always written in the most pragmatic sense. But I suppose our disagreement can only be solved by a question to the FAA's Chief Counsel. ;)
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

Wm226 said:
Those links are useful; but none of those links verify your claim. You originally claimed that "the FSDO's opinion has no bearing in FAA legal proceedings. It is pretty worthless." Those links do not substantiate such claim. So again, what source indicates your claim that "...FSDO's opinion has no bearing in FAA legal proceedings?"
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Do you have anything in writing that says the sky isn't orange? You can prove a negative assertion. You can call FAA legal and ask them yourself, if you like. (202) 267-3222
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

mojo6911 said:
Do you have anything in writing that says the sky isn't orange? You can prove a negative assertion. You can call FAA legal and ask them yourself, if you like. (202) 267-3222
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The number is actually 202-267-3073 -- and I did speak with an FAA attorney with the Office of Chief Counsel. He was kind enough to spend a few minutes with me to discuss the issue of this thread. And though he couldn't provide a concrete opinion to 61.109(c), he referred me to an FAA ASI who might know its interpretation (waiting on his telephone call). Nonetheless, you are incorrect about "FSDO's opinion [having no] bearing in FAA legal proceedings." The attorney stated that FSDO's opinion may be entered into FAA legal proceedings; but its weight would depend on many factors -- including whether the evidence was entered orally or in writing.
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

Wm226 said:
The number is actually 202-267-3073 -- and I did speak with an FAA attorney with the Office of Chief Counsel. He was kind enough to spend a few minutes with me to discuss the issue of this thread. And though he couldn't provide a concrete opinion to 61.109(c), he referred me to an FAA ASI who might know its interpretation (waiting on his telephone call). Nonetheless, you are incorrect about "FSDO's opinion [having no] bearing in FAA legal proceedings." The attorney stated that FSDO's opinion may be entered into FAA legal proceedings; but its weight would depend on many factors -- including whether the evidence was entered orally or in writing.
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My question, respectfully, what exactly are you trying to prove/disprove? A lot of time invested in a matter that is nothing more than a gray legal interpretation from the FAA. You will not get a heli add-on in 10 hours flat. If you do, I will pay for the add-on.
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

Wm226 said:
Again, where in the regulations does it specifically specify that the 20 hours must be from a "helicopter instructor?"
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61.1 Definitions: (b)(2)Authorized Instructor (ii)"...holds a current flight instructor certificate when conducting flight training in accordance with the privileges and limitations.."
61.193 Flight Instructor Privileges:"...is authorized within the limitations of that flight instructor certificate and ratings.."
61.195 Flight Instructor limitations(b)"...may not conduct flight training in an aircraft for which the flight instructor does not hold:
A pilot and flight instructor certificate with appropriate category and class ratings.
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

nosehair said:
I can appreciate your standing, and understanding, on this matter. It would certainly seem that an FAA Inspector would have a concrete understanding of Part 61. But, some of them don't. It is a fact you will discover as you become more familiar with our government system of regulation.

The part of the regulation about basic requirements of private pilot applicants is divided into categories, as you can see.

61.109(c) these are requirements for a helicopter: "...that includes 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation in 61.107(b)(3).

Note the bold 'and'.

The 20 hours from an authorized instructor is a helicopter instructor, and the areas of operation are helicopter operations listed in (b)(3), which are the list of TASKs on the PTS.

This is the same format for all of the ratings. ASEL requires 20 dual in an ASEL from an ASEL CFI on ASEL maneuvers. Every category has that requirement. "...20 hours of flight training from an authorized instructor..." This is under the category for which the requirement is listed, referencing the maneuvers required for that category, not for some generic training.

The above is fact, the following is my opinion.

As a long-time experienced instructor in both ASEL and helicopters, myself, I will tell you that nothing in 61.107(b)(1)(ASEL maneuvers) that can be effectively substituted for 61.107(b)(3)(helicopter maneuvers).

Even radio tuning in a helicopter is more difficult and actually requires more training for an airplane pilot. The ASEL pilot has already established a habit of looking at the radio tuner knob longer than a helicopter pilot can afford to look away or not keep both hands on the flight controls. He has to relearn a new 'procedure' for simply changing radio frequencies.

He will need all of the 20 hours to become safe in a helicopter.
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nosehair said:
61.1 Definitions: (b)(2)Authorized Instructor (ii)"...holds a current flight instructor certificate when conducting flight training in accordance with the privileges and limitations.."
61.193 Flight Instructor Privileges:"...is authorized within the limitations of that flight instructor certificate and ratings.."
61.195 Flight Instructor limitations(b)"...may not conduct flight training in an aircraft for which the flight instructor does not hold:
A pilot and flight instructor certificate with appropriate category and class ratings.
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These 2 posts make it pretty cut and dry. "Authorized" is the key word! It is under helicopter, ASEL, etc. You can't be an "authorized instructor" for teaching in a helicopter without being a CFI-H. Its 30 hours min both ways, 20 dual and 10 solo whether you go from FW to H or H to FW.

Also as Lefty said why worry about whether its 10 hours or not? You will need a min of 30 eitherway. You will be lucky to hold a stable hover in 10 hours.
 
Re: Ten Hours Is All That Is Req. For a Heli Private Add-On.

I hate to piggyback on a thread, but this may come up also if you're doing an add on. The regs changed and now you can log PIC with an instructor on board.

c) For a helicopter rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with a rotorcraft category and helicopter class rating must log at least 150 hours of flight time as a pilot that consists of at least:

(1) 100 hours in powered aircraft, of which 50 hours must be in helicopters.

(2) 100 hours of pilot-in-command flight time, which includes at least—

(i) 35 hours in helicopters; and

(ii) 10 hours in cross-country flight in helicopters.

then a bit farther down...

(4) Ten hours of solo flight time in a helicopter or 10 hours of flight time performing the duties of pilot in command in a helicopter with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph ©(2) of this section), on the areas of operation listed under §61.127(
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(3) that includes—
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Now when do you make the determination to start logging PIC? After solo?

*Edit-This is for a commercial add-on, not private.
 
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