61.129 Commercial Requirement Questions

[Shane Kendry]

I have a few questions about the Commercial Single Engine Requirements.

First, here are the requirements as you all may know:

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 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 airplanes.

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

(i) 50 hours in airplanes; and

(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.

(3) 20 hours of training on the areas of operation listed in Sec. 61.127(b)(1) of this part that includes at least--

[(i) 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. Five hours of the 10 hours required on instrument training must be in a single engine airplane;]

(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;

[(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

(4) Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under Sec. 61.127(b)(1) that include--]

(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.


QUESTIONS:

1. If i have my instrument rating, do I still need to complete the 10 hours of instrument training?

2. For the Day and Night Dual cross country flights, can I combine them with the 10 hour complex training. (After 5 or so hours of initial complex training, take the instructor and the complex aircraft for the two dual flights while he/she teaches me complex stuff?) That way I can knock out the dual cross countries along with some of the complex training hours.

3. Can I combine the long solo cross country with some of the night solo requirements as long as it is all in VFR?

Thanks!

 

[nemich]

1. 99.9% of examiners will count your IR time towards it, but still worth to ask your DPE
2. Yes
3. I did mine - it was 7h flight total, 1h was at night

 

[MidlifeFlyer]

1. Maybe yes, maybe no. This one requires a bit of explanation, but the short answer is "yes, if the CFI doing the instrument training writes it up correctly." The 2010 Hartzell interpretation deals with this one specifically.

The explanation: The FAA has a general policy against "double dipping" - applying tasks from one certificate or rating to another. The reason is that even the "same" task is qualitatively different. The key is the phrase "on the areas of operation." So, for a common example, dual cross countries done as a student pilot can't be used to meet commercial dual requirements because the level of cross country task performance expected from a commercial candidate is different than that for a private pilot candidate. I think in the case of instrument training, the FAA took a softer line, for pretty obvious reasons.

2 and 3. That's much simpler: Yes. There's no reason one can't combine tasks so long as you meet the requirements for each.

 

[tcco94]

The answer to 1 should be no. DPE's have talked to CFI's especially about this one. You cannot transfer required training from one certificate and then apply it to another certificate...example he used: you cannot use cross countries from your private and then apply them as cross countries on your commercial certificate.... so the 10 hours of instrument time should be in your commercial syllabus. That's how I took it...plain and simple.

Also, to number 3....I think the answer would be yes. If you really wanted to make it a 5 hour cross country that included 10 night takeoffs/landings, sounds okay to me. Number 2 also sounds fine.

 

[ahw01]

Yeh I did a 5 hour night cross country with 10 take offs and landings combining 2 items.

I also did the long cross country seperately.

 

[tcco94]

Or you could do the day cross country and land. Get food or something and wait until it's night. Fly back at night cross country. I did that for my multi. 4.4 hour flight...2.2 day and 2.2 night. Especially for Montana weather, saved me from getting 2 good weather days. Just a suggestion if you're trying to cut down days.

 

[MidlifeFlyer]

Or you could do the day cross country and land. Get food or something and wait until it's night. Fly back at night cross country. I did that for my multi. 4.4 hour flight...2.2 day and 2.2 night. Especially for Montana weather, saved me from getting 2 good weather days. Just a suggestion if you're trying to cut down days.

Excellent suggestion for the two required dual cross countries. Can even make the flight to an airport with a good restaurane.

But that doesn't help with the 5-hour/10 solo night takeoff and landing requirement. That you could combine with the "long" solo cross country.

 

[tcco94]

Excellent suggestion for the two required dual cross countries. Can even make the flight to an airport with a good restaurane.

But that doesn't help with the 5-hour/10 solo night takeoff and landing requirement. That you could combine with the "long" solo cross country.

Yeah, it all depends but I was just throwing that out there as a suggestion for other ways to cut down total days.

 

[gocaps16]

example he used: you cannot use cross countries from your private and then apply them as cross countries on your commercial certificate.... so the 10 hours of instrument time should be in your commercial syllabus.

So, If I'm a IR private pilot with a complex endorsement, I cannot use that time for apply for my commercial requirements or did you mean by you cannot apply your cross country time while training for your private pilot license? I'm about to start my CPL training and I rather complete the 250nm cross country in a complex with 3 different stops by myself since it would cost an additional $500 for CFI cost. Would that count towards my CPL?

 

[tcco94]

So, If I'm a IR private pilot with a complex endorsement, I cannot use that time for apply for my commercial requirements or did you mean by you cannot apply your cross country time while training for your private pilot license? I'm about to start my CPL training and I rather complete the 250nm cross country in a complex with 3 different stops by myself since it would cost an additional $500 for CFI cost. Would that count towards my CPL?

You can obviously use your total time for your commercial certificate. You don't have to go out and get a whole new set of 250 hours. Just look under 61.129 (a) for the requirements and what cross countries you need. What you CANNOT do, is use a cross country flight from your PPL and say "I already did that, so it's good for CPL" ...that isn't okay. You have the cross country TIME, true....but the cross country itself was already used for that certificate. For the long cross country, you can do that solo or with an instructor per 61.129 (a)(4) and then if you read the next thing down (i) you'll see the one cross country flight of 300 NM and everything else included.

If you do it now, that's fine. As long as it isn't used towards your IR or PPL certificate training. If you have a PPL IR then you're fine to do it now because per 61.129(a)(4) because it can be solo or PIC responsibilities with an instructor on board. That being said, it does NOT need to be in a complex aircraft either. Do it in a cheap 172. The only thing in the regs about a complex aircraft being used for Commercial is 61.129 (a)(2)(ii) which must be PIC time (I assume because that's what subpart 2 is for...PIC time)

I was a 141 program but we did all our time building in the Archers and then after all cross countries and time building was done, I moved to our Bonanza and just did xride prep and got my endorsement. I hope that answers your question and if someone sees and error please correct me but I waited to get out my regs to make sure and site where I'm getting this info. I'd do the cross country solo in a single engine fixed gear cheap airplane. That's what I did. Still cost me a ton of money but saved from an instructor and the double (almost triple) cost of our Bonanza.

Go Avs.

 

[tcco94]

Also, I'm pretty sure the PTS says you only need a complex aircraft for the takeoff and landing section. I think that's what it read for my CFI, at least...I could be wrong but look it up in the PTS. You'll probably do the entire checkride in that one aircraft anyways, but to be "technical". Commercial time shouldn't all be done in a complex for the amount of extra money you're paying when you don't need too.