Need some FAR clarification...

danielhv

New Member
Looking at the Commercial requirements, one part says:

20 hours of training to include:
10 hours of instrument training, 5 in an airplane
10 hours training in retract gear, flaps, constant speed prop
1 x-country atleast 2 hours day vfr consisting of 100nm straight line distance from the departure airport
1 x-country atleast 2 hours night vfr consisting of 100nm straight line distance from the departure airport
3 hours in a single in prep for practical within 60 days of the test date

The question: I'm assuming since it says 20 hours of TRAINING, that everything below that must be dual with an instructor? The top two I have, its the two x-countries I'm unsure about... Also, is there ANY time limitation to meeting those requirements? For example, if I did a x-country dual 3 years ago as part of my private that was 100nm, 2 hours, day vfr... does it count here as well?
 
Looking at the Commercial requirements, one part says:

20 hours of training to include:
10 hours of instrument training, 5 in an airplane
10 hours training in retract gear, flaps, constant speed prop
1 x-country atleast 2 hours day vfr consisting of 100nm straight line distance from the departure airport
1 x-country atleast 2 hours night vfr consisting of 100nm straight line distance from the departure airport
3 hours in a single in prep for practical within 60 days of the test date

The question: I'm assuming since it says 20 hours of TRAINING, that everything below that must be dual with an instructor? The top two I have, its the two x-countries I'm unsure about... Also, is there ANY time limitation to meeting those requirements? For example, if I did a x-country dual 3 years ago as part of my private that was 100nm, 2 hours, day vfr... does it count here as well?


There shouldn't be a time limitation - when I went for my commercial single-engine, the examiner wanted me to show him where my long solo cross-country was. I showed him the logbook entry from 3 years ago (but post private checkride), and since it was in a different part of the country, I brought the sectionals that I used for the flight. He took it.

I don't know if you'll be able to use the cross-country dual that you did for your private though.
 
No, you may not "double dip" on your cross countries. If they were done for your PPL, they don't count. Otherwise, there is no "time limit", per se. And yes, it's "training", so you need a CFI-A.
 
No, you may not "double dip" on your cross countries. If they were done for your PPL, they don't count.

This part is debatable and depends on the DPE. If you did your instrument rating, can you count that as the 10 hours of instrument training? I believe most people would answer yes, so it is a little contradictory.
 
This part is debatable and depends on the DPE.

It shouldn't, but it probably does, particularly since the demise of the Part 61 FAQs. In general, the no "double counting" is the policy applied by the FAQs. The instrument training for the Commercial is kind of an exception; if it were a full exception, then that would remove 10 hours from Commercial training, but it doesn't.

The cross-countries need to be post-private. If this were not so, many of the training requirements for the Commercial would be pointless. Private instructors would just make sure some of their cross countries met the Commercial requirements and you could skip half of the Commercial training. Obviously, this is not what's intended.

From the FAQs:

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.”
{Q&A-207}
 
Taking down the FAQs is one of the dumbest things the FAA ever did. They were a common-sense explanation of ambiguous regs without the legalese. Looks like you have to get the general counsel to provide a legal interpretation every time.
 
Taking down the FAQs is one of the dumbest things the FAA ever did. They were a common-sense explanation of ambiguous regs without the legalese. Looks like you have to get the general counsel to provide a legal interpretation every time.
I think that what happened was that, for all its value in providing a public reference and enhancing consistency among FSDOs, there were answers that were incorrect and sometimes tended to reflect John Lynch's personal view of what the FAR should say rather than what it did say.

That's okay for an internal documents, but not that good for one for public consumption, especially one that was officially not official.
 
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