Commercial multi rating without private multi?

Is is possible to get your commercial multiengine rating as your initial multiengine rating? 61.129(b)(4) says you need "10 hours of solo flight time in a multiengine airplne or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor..."

'Performing the duties', to me, is a little vague. Does that mean you need a multi rating to perform the duties of PIC or could just being with an instructor satisfy the performing the duties as long as the instructor signs off as such?


Look at "performing the duties" as meaning the time after an instructor "would" sign the student off for solo. Most insurance companies won't allow very low time solo, so this is a compromise. Even the FAA realizes that and allows an Instructor to "ride along" for the ten hours for an inital CMEL. Note this does not include the "dual time" required just prior to the checkride.
 
Look at "performing the duties" as meaning the time after an instructor "would" sign the student off for solo. Most insurance companies won't allow very low time solo, so this is a compromise. Even the FAA realizes that and allows an Instructor to "ride along" for the ten hours for an inital CMEL. Note this does not include the "dual time" required just prior to the checkride.

No joke, insurance companies are tough on multi.
We had to play ball with them just so I could "ferry" the plane to my MEI check ride, solo. Even after the ride they didn't want me to take it 'solo', but taking a fresh faced kid up and teaching him Vmc demos and full feather shut downs was A-Okay.
funny business.
:panic:
 
Look at "performing the duties" as meaning the time after an instructor "would" sign the student off for solo. Most insurance companies won't allow very low time solo, so this is a compromise. Even the FAA realizes that and allows an Instructor to "ride along" for the ten hours for an inital CMEL. Note this does not include the "dual time" required just prior to the checkride.


so basically the absolute minimum for a student with no prior complex time going for his cmel would be 13 hours?
 
no it is not a bs reg and there are no bs regs.

you need to look at 61.63 (C) (4)

no joke look at, it will blow your mind.

Not sure why you referred to that reg. I was referring to the "performing the duties of PIC" as a BS reg, which it is.

sorry mojo, that was my bad.
The referred reg was for the original poster, so he could find all the information he needed to add-on certificates and rating.
 
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