Thoroughly Confused by the FAR's

[aerospacepilot]

61.129

Aeronautical experience for commercial pilots. I cannot figure it out. I am a private/instrument pilot with about 165hrs. I am going to build some time (say 50 hours) of Cessna-172 time to set myself up for getting my commercial single/multi engine rating this summer when school gets out.

I am trying to decide how much time I should build before I start commercial SEL training. According to the FAR's, for commercial SEL, I need:
- 250hrs of flight time, 100 PIC, 50 xc. Ok, that is easy.
Parts 3 and 4 confuse me.
(3)20hrs of training in 61.127 that includes atleast:
- 10hrs of instrument training, atleast 5hrs must be in single engine airplanes.
- 10hrs of training in an airplane with RG, flaps, and controllable pitch propeller.
- One cross country flight of atleast 2hrs in a single engine airplane in day VFR conditions, straight line distance of more than 100nm.
- One cross country flight of atleast 2hrs in a single engine airplane in night VFR conditions, straight line distance of more than 100nm.
- 3hrs in a single engine airplane in preparation for the checkride.
(4)10hrs of solo flight in single engine airplanes that includes atleast:
- One cross country flight of more than 300nm, atleast 250nm straight line distance
- 5hrs in night VFR conditions with 10 takeoffs/landings at airport with tower.


Ok, first the solo requirements (part 4). Lets say I have already met all three of these requirements (10hrs solo, 300nm flight, and 5hrs in night VFR conditions). Am I good to go, or do I have to "practice the areas of operation listed in 61.127?? In other words, do I have to wait until I start commercial training, then do this stuff, or is it ok as long as I have done it at some point in my flying life?

Now back to part 3. Say I already have 10hrs of instrument training from my instrument rating. Do I need to do this again, or am I good to go? Next question, how long does it usually take to learn to fly a RG and controllable pitch airplane? I plan to do my commercial SEL in a C-172RG. Would it be feasable to do those two 2hr cross countries and the 3 hours of checkride prep in the complex airplane while building up to 10hrs?
How many hours does it take a typical student to get a commercial single engine rating? Is 10hrs feasable, or is it usually much more (assuming you have the solo requirements out of the way before you start training)?

And I am even more confused about the commercial multi engine FAR's, but I will save that until after I find out about the single engine questions. Thanks in advance. I am going to go back to reading my Space Mission Analysis and Design book, it is less confusing than reading the FAR's!

 

[kfour]

Ok, first the solo requirements (part 4). Lets say I have already met all three of these requirements (10hrs solo, 300nm flight, and 5hrs in night VFR conditions). Am I good to go, or do I have to "practice the areas of operation listed in 61.127?? In other words, do I have to wait until I start commercial training, then do this stuff, or is it ok as long as I have done it at some point in my flying life?

It's possible to do this flight while still a student pilot and have it meet the commercial criteria later. As far as the 2nd question...I'm not 100% on that...someone else will get it.

 

[tgrayson]

It's possible to do this flight while still a student pilot and have it meet the commercial criteria later.

No, according to the old FAA FAQs:

{Q&A-234}
QUESTION: Apart from § 61.129(a)(3)(v), is there anything in § 61.129 that implies that I cannot count any “aeronautical experience” obtained during my pre-Private training? I believe the old regulations stated this, but it has been removed from the new regulations.

Simple question: If I flew a student solo cross country (pre-Private) from Seattle to LAX and back in a C172, could I count that towards my Commercial requirements?

ANSWER: Ref. § 61.129(a)(2)(ii); Yes. The pre-Private solo cross-country does “count” toward the § 61.129(a)(2)(ii) [i.e., the requirement for 50 hours of PIC cross-country time].

However, the answer is no if your question is asking: “Can this be used to meet the § 61.129(a)(4) “long crosscountry solo flight” commercial preparation?” § 61.129(a)(4) specifies that the reason for such flight (commercial preparation) must relate to § 61.127(b)(1). This was not the training (certificate preparation) requirement being
met for the “pre-Private solo cross-country.”

 

[mhcasey]

What TGrayson said. I also tried to use my instrument xc as the day 100nm and the SAT FSDO came back with "it's supposed to be in day VFR conditions. The idea is to navigate the VFR way, which you could not do under the hood." You'd probably get different responses from different FSDO's or even different people at the same FDSO, but whatever...

Make sure you get the 10 takeoffs and landings (solo) at a control tower airport at night. What's the deal with this requirement anyway? Seems like it's tougher to get in there during the day when there's a lot of traffic. Austin has cleared me to land from 50 miles out at night before...

Make sure your 300nm XC is solo (as in no other pilots, but you can take your girlfriend or whoever along).

You don't need 10 extra hours of instrument training, but I think you are still supposed to have 20 hours of training...which is extremely stupid. Why the heck would someone with an instrument rating require more training than someone without? Can anyone else clear this one up?

I felt comfortable with the maneuvers/landings in the 172RG after 7 or 8 hours. Then I took a few extra checkride prep lessons to get up to 10. I would not plan on using the duel xc's just to build the required complex time.

 

[wrxpilot]

Make sure your 300nm XC is solo (as in no other pilots, but you can take your girlfriend or whoever along).

Agreed... But don't write down in your logbook that you went flying with your g/f or whoever on that flight. Write it out such that there is no info regarding any person being on the plane during that flight. It's kind of ridiculous, but technically there should be NO HUMAN BEING on the plane during that flight.

 

[MidlifeFlyer]

Make sure your 300nm XC is solo (as in no other pilots, but you can take your girlfriend or whoever along).

No you cannot. Look at when you can log time as "solo" under FAR 61.51.

==============================
Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.
==============================

wrxpilot, I'm not sure that bringing your girlfriend but not mentioning it and then falsifying the logbook entry is worth the penalty if discovered, but to each his own.

 

[dc3flyer]

Make sure your 300nm XC is solo (as in no other pilots, but you can take your girlfriend or whoever along).

What the ???? Is that legal??? Far Part 61.51 says SOLO: a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft. And I know no one on JC would break any reg.



I would say you will need more than the 10 hrs in a complex. It will take you 5 or so to get used to the plane, and then you have to learn the maneuvers in that plane and be comfortable with them for a checkride.

 

[wrxpilot]

wrxpilot, I'm not sure that bringing your girlfriend but not mentioning it and then falsifying the logbook entry is worth the penalty if discovered, but to each his own.

Just don't bring anybody on the flight period and avoid the whole mess. Solo is solo.

 

[wrxpilot]

wrxpilot, I'm not sure that bringing your girlfriend but not mentioning it and then falsifying the logbook entry is worth the penalty if discovered, but to each his own.

As far as the false entries go, I disagree Mark. This issue is actually not as clear as some people think... I've personally seen the intrepretation change dramatically depending upon the FSDO. If I had one of these flights, I wouldn't write "solo" and I wouldn't write "too Aunt Bea flying" either. I don't see that as falsifying a logbook.

Like I said in my above post, I agree with your intrepretation, but not everybody (whose opinion matters) does. If it were me, I'd just fly the x/c solo (nobody in the plane at all). That way there are not questions at all.

 

[CoffeeIcePapers]

As far as the false entries go, I disagree Mark. This issue is actually not as clear as some people think... I've personally seen the intrepretation change dramatically depending upon the FSDO. /quote]

This is one of the instances when the FARs are pretty black and white. No interpretation is needed. If someone else is in the airplane, you are not solo.

 

[wrxpilot]

This is one of the instances when the FARs are pretty black and white. No interpretation is needed. If someone else is in the airplane, you are not solo.

Like I said, I agree completely - no argument from me. However, I have personally heard from at least one FSDO and several examiners that the requirement only pertains to having pilots/CFIs in the airplane - not pax. Regardless, a smart person would be flying/logging this as a flight without passengers of any kind. Not worth having to redo it.

 

[mhcasey]

Like I said, I agree completely - no argument from me. However, I have personally heard from at least one FSDO and several examiners that the requirement only pertains to having pilots/CFIs in the airplane - not pax. Regardless, a smart person would be flying/logging this as a flight without passengers of any kind. Not worth having to redo it.

Likewise on the interpretations I've heard from the higher ups, but again, you'd probably get different interpretations on different days from different people at the same FSDO...

Anyone want to post a defense of the "sole occupant" thing just for kicks? Seems like another stupid one to me. "Wait a minute, your mother with no ability to fly an airplane whatsoever was sitting right seat? No. Her presence must have made the flight much easier as she could probably hold a chart for you, so this cannot be logged as solo time." ???

Coincidentally, will anyone at any time during my career progression care how much "solo" time I have? Seems like of the magic numbers out there, "solo" is not too often included...

 

[tgrayson]

Likewise on the interpretations I've heard from the higher ups, but again, you'd probably get different interpretations on different days from different people at the same FSDO...

FSDOs and Examiners are extremely unreliable sources for interpretations. They are, however, experts in what they themselves would try to enforce. The Part 61 FAQs were useful in that they provided some standardization, regardless of whether they followed the letter or intent of the regulations as written. That said, the Part 61 FAQs do emphasize that solo is solo, no passengers of any kind. That does suggest what the highest levels of the FAA Management think the law supports and is still probably more reliable than any random Inspector or Examiner.

 

[nosehair]

Anyone want to post a defense of the "sole occupant" thing just for kicks? Seems like another stupid one to me. "Wait a minute, your mother with no ability to fly an airplane whatsoever was sitting right seat? No. Her presence must have made the flight much easier as she could probably hold a chart for you, so this cannot be logged as solo time." ???

Yep, I'll try to clear this up so it doesn't sound so "stupid" for you.

First, and foremost, the concept of "solo" in the beginning of flight training is to prove, beyond a shadow of doubt, that you can fly the airplane, all by your self, with no help from anyone. Normally, that would be your instructor, and most everyone agrees that having to have some solo time is a good way of preventing a pilot getting certificated and never having to make solo decisions on his own.

Yes? You agree?...

OK, now carry that concept on into commercial training.

OK, maybe you wouldn't do it, but there would be some people who would carry a pax who could help with some stuff, like folding maps, or watching out on their side for landmarks, looking up frequencys,etc.,etc.,...and so on. Get the picture?

We all got to our various certificates and ratings by actually flying SOLO for some certain time to prove that we could do it all on our little lonesome.

 

[MidlifeFlyer]

FSDOs and Examiners are extremely unreliable sources for interpretations. They are, however, experts in what they themselves would try to enforce. The Part 61 FAQs were useful in that they provided some standardization, regardless of whether they followed the letter or intent of the regulations as written. That said, the Part 61 FAQs do emphasize that solo is solo, no passengers of any kind. That does suggest what the highest levels of the FAA Management think the law supports and is still probably more reliable than any random Inspector or Examiner.

You know how incorrect information gets handed down as though it were accurate? There may be a historical basis for the belief that "solo" means something other than what 61.51 says (I have a funny feeling that if they meant sole pilot, they would have said it instead of "sole occupant").

I can picture some ancient pilot passing it on to a youngster who passes it on to... and both the earlier and current meanings get messed up.

 

[aerospacepilot]

Here is what I understand.

I don't need to redo the 10hrs of instrument training if I already have done it.
I don't have to redo the 10hrs solo, 300nm xc, or 5hrs in night VFR with 10 takeoffs/landings at an airport with an operating control tower if I already have done it.

All I have to do is get the 10hrs of complex time, and 3hrs of checkride preparation, which can be combined.

Two things that still are not settled:
1.
One cross country flight 2+ hours in a SE airplane in day VFR of atleast 100nm
One cross country flight 2+ hours in a SE airplane in night VFR of atleast 100nm
Do these need to be with an instructor? If so, can I count my long IFR cross country (in day VFR) for the top requirement, even though I was under the hood.

2.
What is solo? I asked an FAA inspector today and he said as long as you are the sole qualified pilot on board, you are technically solo. I can also see the argument that solo means sole occupant of the aircraft. Either way, I don't think it is that much of a big deal. I am more concerned with the answer to number 1.

One last thing. About how many hours do you think it takes to learn to fly a complex airplane and learn to do the commercial maneuvers? If I want to get a commercial multi engine add on with 0 multi time, about how many hours do you think that will take?

Thank you all so much for your help. You rock!!! :nana2:
Ross

 

[tgrayson]

"sole occupant"

Although this requirement is 99.9% silly, I have known Commercial candidates who apparently were uncomfortable flying by themselves.

 

[Fly_Unity]

1.
One cross country flight 2+ hours in a SE airplane in day VFR of atleast 100nm
One cross country flight 2+ hours in a SE airplane in night VFR of atleast 100nm
Do these need to be with an instructor? If so, can I count my long IFR cross country (in day VFR) for the top requirement, even though I was under the hood.

Ross

At my school I did my commercial IFR long cross country and 2 hour cross country VFR all in one flight, my commercial examiner was ok with it, then when I went in for my MEI, my Examiner (June Bonesteel) refused to take my ride because of that, Chief pilot called the PHX FSDO, and FSDO said it was ok, but they also said they couldn't force an examiner to take a check ride.

so although technically you can count your IFR cross country as your VFR flight (as long as your instructor does "VFR" training as well) I would do the extra flight so you dont have problems down the road.

 

[wrxpilot]

Yep, I'll try to clear this up so it doesn't sound so "stupid" for you.

I didn't write this. Please correct your post so it doesn't look like I wrote it.

 

[mhcasey]

I knew my commercial examiner would be fine with me combining the IFR XC with the 100nm dual vfr commercial requirement, but I called the FSDO ahead of time since I didn't want any trouble during my CFI checkride. They told me to redo it using pilotage and dead reckoning.

As far as "solo" goes, I still think the idea is a bit silly/stupid/whatever, though I understand obviously why it is important for a student pilot. My thoughts were simply that by 250 hours, surely the guy has plenty of solo time, but I guess I could be wrong.

Aerospace, the regs say something to the effect of "20 hour of training in the following areas of operation..." Training = duel = with an instructor, so your XC's have to be with an instructor.

I think by now it should be clear to play it safe and:

1) Fly the long XC as sole occupant of the aircraft.
2) Don't double count your IFR XC or any other XC for the two duel XC's required for the commercial license.
3) You will more than likely need at least 10 hour in the RG to be proficient.

Not too sure about the multi stuff. Still hoping Uncle Sam will cover that part of my training...