CSEL 20 hours dual question (part 61)

T

turbojet28

Well-Known Member
Okay, just to clarify. 14 CFR 61.129 requires 20 hours of dual on the areas of operations listed, and of that, 10 hours are instrument instruction and 10 hours are in a complex. So, since I have my instrument rating, the only dual I need yet to fulfill the legal requirements are the 10 hours in the complex, right? I have started flying the Arrow at a local FBO, and have about 5 hours of dual in it doing the commercial maneuvers. I just always get in those modes where I read stuff and just need a second opinion to make sure I'm not off my rocker as I get closer. Thanks.
 
turbojet28 said:
Okay, just to clarify. 14 CFR 61.129 requires 20 hours of dual on the areas of operations listed, and of that, 10 hours are instrument instruction and 10 hours are in a complex. So, since I have my instrument rating, the only dual I need yet to fulfill the legal requirements are the 10 hours in the complex, right? I have started flying the Arrow at a local FBO, and have about 5 hours of dual in it doing the commercial maneuvers. I just always get in those modes where I read stuff and just need a second opinion to make sure I'm not off my rocker as I get closer. Thanks.
Click to expand...

That is what I was told by my CFII, IFR training and some basic IFR refresher before the exam. Flying a 180 or 200hp Arrow?
 
NO, you still need 20 hours, I have to leave for work right now so I cant look it up, but its note 4 on an interpretation of 61.129
 
GlideSlope said:
So, if I have my CMEL do I need still need the 20 hours of dual for the CSEL?
Click to expand...
No. All of the 61.129 requirements start out with, "a person who applies for a commercial pilot certificate with an..."

When you add a rating to a commercial certificate, you are not applying for a commercial pilot certifciate. You already have one.

The requirements for add-on ratings are more limited, especially if you are adding only a class rating. See 61.63.
 
I really should bookmark this, it gets asked about daily at work.

From Aeronautical Experience Checklist:


NOTE 4: Applicants for a commercial pilot certificate with the airplane single engine, airplane multiengine, helicopter, gyroplane, or powered-lift ratings and who already holds an instrument rating that is appropriate to the category and class rating sought are not required to accomplish an additional “. . . 10 hours of instrument training . . .” as stated in § 61.129(a)(3)(i); § 61.129(b)(3)(i); § 61.129(c)(3)(i); § 61.129(d)(3)(i); and § 61.129(e)(3)(i). However, the required commercial pilot training hour requirements [i.e., ". . . on the areas of operation listed in § 61.127 . . ."] of 20 hours in § 61.129(a)(3), (b)(3), (c)(3), (d)(3), and (e)(3) cannot be reduced to 10 hours.
Click to expand...
Full document:
[SIZE=-1]www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs800/afs810/checklist/media/aero-exp.doc[/SIZE]
 
OK. So can I just say "hey look at that! 10 of the hours for my instrument rating doubled as commercial training!" Or, "Hey look at that! I had 10 extra hours of instrument training before I got my instrument rating, so they were actually commercial training too?"
 
mhcasey said:
OK. So can I just say "hey look at that! 10 of the hours for my instrument rating doubled as commercial training!" Or, "Hey look at that! I had 10 extra hours of instrument training before I got my instrument rating, so they were actually commercial training too?"
Click to expand...
If you have the IR, then you dont need to do additional instrument training; but still need to have 20 hours of instruction received specifically for the COMM.


If you don't have the IR, then 10 of the 20 hours must be spent on instrument training; not sure if it could be counted towards the 15 for the IR, but at the very least you could count it towards the 40 hours of simulated or actual flight required for the IR.
 
bdhill1979 said:
If you have the IR, then you dont need to do additional instrument training; but still need to have 20 hours of instruction received specifically for the COMM.
Click to expand...

Not buyin' it. Explain how anything accomplished in training for an instrument rating isn't encompassed by 61.127. And where are you getting the idea that one must "still need to have 20 hours of instruction received specifically for the COMM". Instruction received is instruction received. Seems to me you could apply a fair amount of the training you received for your PPL to this as well, provided you still meet the 3 hrs in the 60 days prior to application rule.

In fact, the argument the FAA makes in Note 6 just as readily applies to Part 61 training:

If an applicant is undergoing a combined Part 141 Commercial Pilot Certification and Instrument Rating approved course then that applicant need not accomplish an additional “. . . 10 hours of instrument training . . .”. Because in this situation, the applicant is getting instrument training and there would be no way, or need, to differentiate the instrument training required in the Instrument Rating course with the instrument training required in the Commercial Pilot Certification course.
Click to expand...
(Emphasis mine.)
 
It seems as though almost all of the dual recieved for the PPL could count for the 20 of CSEL dual, because the areas of operation are pretty much the same, with the exception of high altitude operations for the commercial.
 
aloft said:
Not buyin' it. Explain how anything accomplished in training for an instrument rating isn't encompassed by 61.127. And where are you getting the idea that one must "still need to have 20 hours of instruction received specifically for the COMM". Instruction received is instruction received. Seems to me you could apply a fair amount of the training you received for your PPL to this as well, provided you still meet the 3 hrs in the 60 days prior to application rule.

In fact, the argument the FAA makes in Note 6 just as readily applies to Part 61 training:

(Emphasis mine.)
Click to expand...
It was explained to me this way by the DPE, you know who; his exact words were "No double dipping". He specifically said none of the time prior to the PPL checkride could count towards a Commercial as that dual received was training for the PPL, not the Commercial. If you already have the IR then it is pretty clearly spelled out in the FAA document that I posted that you must still have 20 total hours of dual received for the commercial.

Granted some DPEs are not as picky about this as the one I had my ride with, but I think it is pretty plain that 20 hours is the requirement.

Edit: I just noticed the note you quoted as referring to part 141, I'm talking about part 61
Apples and Oranges
 
ok, let me get this straight.

if the person does not have the IR, then at least 10 hours need to go towards instrument training. but if they do, they still need 20 hours total of dual (of which none HAS to be instrument training)
 
BuickCFI said:
ok, let me get this straight.

if the person does not have the IR, then at least 10 hours need to go towards instrument training. but if they do, they still need 20 hours total of dual (of which none HAS to be instrument training)
Click to expand...
That is exactly what the above posted "Aeronautical Experience Checklist: note 4" says;
[FONT=&quot]Applicants for a commercial pilot certificate ... who already holds an instrument rating that is appropriate to the category and class rating sought are not required to accomplish an additional . . . 10 hours of instrument training [/FONT]

However, the required commercial pilot training hour requirements ... of 20 hours ...cannot be reduced to 10 hours
Click to expand...
(cleaned up a little)
 
bdhill1979 said:
Edit: I just noticed the note you quoted as referring to part 141, I'm talking about part 61
Apples and Oranges
Click to expand...
The note mentions instrument rating and commercial done together under Part 141, I've done essentially the same thing under Part 61, and there's nothing in the FARs that says dual received for the instrument rating cannot also cover 10 of the 20 hrs dual requirement for the commercial. My point is, the same argument made in that note applies:
...there would be no way, or need, to differentiate the instrument training required in the Instrument Rating course with the instrument training required in the Commercial Pilot Certification course.
Click to expand...

PM me which DPE you're talking about....
 
bdhill1979 said:
It was explained to me this way by the DPE, you know who; his exact words were "No double dipping". He specifically said none of the time prior to the PPL checkride could count towards a Commercial as that dual received was training for the PPL, not the Commercial. If you already have the IR then it is pretty clearly spelled out in the FAA document that I posted that you must still have 20 total hours of dual received for the commercial.

Granted some DPEs are not as picky about this as the one I had my ride with, but I think it is pretty plain that 20 hours is the requirement.
Click to expand...
It's an old battle that started with the old Part 61 FAQ - Lynch took the position that there was no "double dipping" - that you could not use any student pilot training toward any of the other certificates or ratings.

Whatever the ultimate validity of that view, the whole analysis becomes a problem later on. Except in Part 141, where you have enrollment and restrictions on what prior training you can use, there's no such thing, from a reg sense, as "going for" a certificate.

Easy example. 2 weeks after getting the private certificate, there's a strong crosswind day. So, you grab an instructor and go up, just to increase your proficiency.

Who says that wasn't instruction toward the commercial certificate? What in the logbook entry would differentiate it from instruction that was after you made the decision?

Maybe it's a bit easier to avoid the double-dip with the instrument - the document you quited from seems to require it. But really...
 
MidlifeFlyer said:
It's an old battle that started with the old Part 61 FAQ - Lynch took the position that there was no "double dipping" - that you could not use any student pilot training toward any of the other certificates or ratings.

Whatever the ultimate validity of that view, the whole analysis becomes a problem later on. Except in Part 141, where you have enrollment and restrictions on what prior training you can use, there's no such thing, from a reg sense, as "going for" a certificate.

Easy example. 2 weeks after getting the private certificate, there's a strong crosswind day. So, you grab an instructor and go up, just to increase your proficiency.

Who says that wasn't instruction toward the commercial certificate? What in the logbook entry would differentiate it from instruction that was after you made the decision?

Maybe it's a bit easier to avoid the double-dip with the instrument - the document you quited from seems to require it. But really...
Click to expand...

I think that the reg just needs to be clearly re-written so that there is no confusion or need for "Note 4".
I have witnessed one and have heard of a few examiners working out of the SLC FSDO that have sent students away for not having the 20 hours of training met.

Just another example of "Governmentese" being a foreign language.
 
You must log in or register to reply here.
Back
Top