Commercial Student part 141 vs 61

holyshirt

New Member
Im a CFI at a University in the flight department and I could use some peoples help if anyone has experience with this.. I have 2 commercial students who were working on their certificate under part 61, which was allowed by the school at the time. Both students have about 220 hours and were on track to be ready by around the 250 hour mark. Well a few days ago the Chief Pilot moved these students into the 141 commercial program without much notification to anyone. All I got was a memo. Number one, I am very confused right now b/c I dont see how this is beneficial at this point, although the CP thinks this is going to help. Number 2 the CP says to give the students credit for everything they did toward their commercial certificate and log it toward their 141 training. So that means I have to go through the Syllabus (were using the Jeppeson Commercial/Inst BTW) and some how check off everything we did and log it in their training folders... This is very confusing for me b/c I dont see how I can just start going through a syllabus and check off everything (which is blocked as individual lessons) and give credit for everything, when we have not been following any syllabus at all! I have been instructing the students on a needs basis and tailoring it to what they need to meet for part 61 regs. If ANY other instructor can make any sense of this please help me out.. And what I REALLY want to know is if it is possible for my students to benefit in any way from switching to 141 program so late (220 hours). BTW all of their training was done at this University.
 
R

Roger, Roger

Guest
Yikes! With the record-keeping requirements for 141, that's going to be a huge pain.
 

ILS37R

Well-Known Member
It's definitely a bit late to get them much advantage by switching to a 141 program. The big benefit of 141 is being able to get the commercial cert. at about 190 hours, which they've already surpassed. I guess it depends on how far along they are as to whether they could still get it done under the 250 Part 61 requirement and get some benefit from a cost standpoint.

I would be careful about backfilling a 141 syllabus; was your school approved for 141 at the time the training was conducted (and had you been approved to give 141 training--usually a quick ride with the CP)? Do you have paperwork covering the completed ground work? Honestly, I doubt it will come up, but those are the sorts of questions to consider.

If it were me, I'd continue their training via the 141 syllabus, per the boss' demands, but make sure they meet the Part 61 experience requirements before they take the checkride (and fill out an appropriate, back-up 8710, just in case). That way if the examiner has any concerns, your students are still good to go.
 

Ruff T

Well-Known Member
I don't think that it's benefitial at this point of training for your students to switch between 61 and 141 since they're so close to being done. And like Roger said,
Yikes! With the record-keeping requirements for 141, that's going to be a huge pain.
Do you know if your students will have to go back and do the "stage/phase checks" required under 141?
 
R

Roger, Roger

Guest
I think ILS has the best suggestion...do the rest of their commercial training following the 141 lesson outlines, but just do all the paperwork part 61. Transferring/backdating/filling out 141 paperwork is at best going to be a pain in the butt and at worst get you in trouble with the FAA if you make a mistake. Again, 141 record keeping is a BIG deal and you don't want to mess with anything there unless you and your Chief Instructor know exactly what is going on.
 

minitour

New Member
Number 2 the CP says to give the students credit for everything they did toward their commercial certificate and log it toward their 141 training. So that means I have to go through the Syllabus (were using the Jeppeson Commercial/Inst BTW) and some how check off everything we did and log it in their training folders...
I'd avoid doing it.

One: How is the chief flight instructor going to fudge the enrollment certificate? That's required to be sent to your POI.

So the chief flight instructor (and the school) can get in trouble there. Not good.

Two: If you start back-dating training records in his training folder, it isn't going to match the logged flights in his logbook. You've just falsified a required record. Now you're in a bad spot. If your student is dumb enough to sign it and agree to this, now he's set up to potentially be in a bad spot.

Remember, under 141 a fed can stop in ANY TIME and go through the records and contuct final/end of stage/course checks AND the practical test for the certificate or rating. No one gets to say "no thanks".

I don't want to be in that position where I'm all of a sudden trying to explain an enrollment certificate that wasn't sent in on time or flights that were logged before they were entered into the folder, etc.

This is just a dumb idea and your chief needs slapped. The students have 30 hours to go before they're able to get a 61 commercial. Just finish them up.

-mini
 

holyshirt

New Member
UPDATE:

Is it legal for the CP to backdate 141 enrollment certificates????

Heres what I mean.. two of my commercial students were training under part 61. Well after I found out that the students were enrolled into the 141 program I checked their certificates of enrollments which were signed by the CP and back dated. In fact, one of my students enrollment certificates was backdated for over a year ago (almost 2 to be exact).. And guess what? It was signed by the CP but he was not the CP back then.. Isnt this a problem?!!!

This is very frustrating for me and the student because the CP says to "give credit" for what they did during their part 61 training toward their part 141 training. And he think that somehow they will get done in less time now that they are in the 141 program.

Number one I have no clue how to "give credit". Hes not very good at explaining this part to me or the students.

Number two I thought that according to the 141 regs that only 25% of prior training (part 61) can be accepted toward the 141 training.

Again.. even so, im pretty darn sure our CP cant just "backdate" enrollment certificates like this and he completely messed this one up because the date which he signed it for he was NOT chief pilot!

Im very very confused... and quite frankly Im afraid to get myself into trouble with this.

Any help would be appreciated.
 

ILS37R

Well-Known Member
UPDATE:

Is it legal for the CP to backdate 141 enrollment certificates????

Heres what I mean.. two of my commercial students were training under part 61. Well after I found out that the students were enrolled into the 141 program I checked their certificates of enrollments which were signed by the CP and back dated. In fact, one of my students enrollment certificates was backdated for over a year ago (almost 2 to be exact).. And guess what? It was signed by the CP but he was not the CP back then.. Isnt this a problem?!!!

This is very frustrating for me and the student because the CP says to "give credit" for what they did during their part 61 training toward their part 141 training. And he think that somehow they will get done in less time now that they are in the 141 program.

Number one I have no clue how to "give credit". Hes not very good at explaining this part to me or the students.

Number two I thought that according to the 141 regs that only 25% of prior training (part 61) can be accepted toward the 141 training.

Again.. even so, im pretty darn sure our CP cant just "backdate" enrollment certificates like this and he completely messed this one up because the date which he signed it for he was NOT chief pilot!

Im very very confused... and quite frankly Im afraid to get myself into trouble with this.

Any help would be appreciated.
Serious red flags. Don't get involved in this. Don't let your students get caught up, either. Finish up Part 61. There's some grey area in a transition from 61 to 141, but that isn't it.

Explain to the CP that you'd be happy to start new students Part 141, but that it just doesn't make sense for your current students to switch over so late in the game. Don't fight with him about the FARs and legality and, if you have drop back to something, whip out those dusty old FOIs: your course should be tailored to the individual needs of the student, and switching to 141 doesn't meet your students' needs.
 

Nihon_Ni

Well-Known Member
Explain the whole thing to your students, including the risk and benefits they could get from doing part 141. Then let them decide. If they don't want to enroll in part 141, the CP cannot force them. He could discontinue part 61 instruction, which means they would have to leave the school, but do you think he would turn away customers?
 
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