Helicopter to Fixed wing transition

MikeD

Administrator
Staff member
Then you should quit pretending to be a cfi- regulatory knowledge and appropriate application of regulations is a large part of the certification process.
Sounds harsh, I know, but the lackadaisical attitude of the "occasional" cfi is a big part of the problem, sir.
I think he's only meaning that it's not fun reading. I don't read a lacksadasical attitude in his statement, necessarily, of that info being unimportant.
 

NickH

Uber Driver
Look at the part that I bolded. Thats where the 30 hours is required. You have to do 20 hours dual and the 10 hours solo. The only thing that is a carry over from the rotorcraft category is the 40 hours flight time.
Respectfully I have to disagree.

20 hours dual and 10 solo on the areas of operation in 61.107(b)(1). That includes such things as navigation which applies equally to helicopters and fixed wing.

That does not mean that the 13 hour plan is acceptable. You have to have received ground and flight training in slow flight and stalls, for example.

But the time spent with an instructor on one of the specified areas of operation can be counted toward the 20 hours of dual, regardless of the type of aircraft used for that training.
 

Rotor2Wing

Unapologetically American
Respectfully I have to disagree.

20 hours dual and 10 solo on the areas of operation in 61.107(b)(1). That includes such things as navigation which applies equally to helicopters and fixed wing.

That does not mean that the 13 hour plan is acceptable. You have to have received ground and flight training in slow flight and stalls, for example.

But the time spent with an instructor on one of the specified areas of operation can be counted toward the 20 hours of dual, regardless of the type of aircraft used for that training.
The way it has been explained to me by more than one FSDO is as follows. The "key" term that makes it required to do the full 20 hours of dual is "authorized instructor". A CFI-H is not "authorized" for the airplane-SEL when teaching a different category even if they have a CFI-A. Of the DPEs I know that do both helicopter and airplane check rides this is their stance on this also. This was also required by my DPE that did my SEL add-on to my helicopter. So I would suggest that anyone doing a rating changing category consult the DPE they are going to use and the FSDO in their area for their opinion. I know that some FSDOs do things one way where another thinks your crazy for asking about it.

FlyingScot
 

NickH

Uber Driver
A CFI-H is authorized to teach navigation. The key is in the wording. Each specific requirement lists 'in a Single engine airplane', which indicates that there is no general requirement for all that time to be in a single. Look at the distinction in item 5 '10 hours of solo flight time in a single engine airplane...'

Alternatively, skim down to 61.63(f), the requirements for gliders: (1) If the applicant for a private pilot certificate with a glider category rating has not logged at least 40 hours of flight time as a pilot in a heavier-than-air aircraft, the applicant must log at least 10 hours of flight time in a glider in the areas of operation listed in Sec. 61.107(b)(6) of this part, and that flight time must include at least-'

Very different! Here it distinctly specifies when a candidate must log this flight time specifically in a glider, as opposed to another aircraft type, on those areas of operation.

You'll also notice that, while the areas of operation include basic instrument maneuvers, there is a separate requirement for 3 hours of basic instrument maneuvers to be conducted in a single engine airplane.

Talking to your DPE and/or FSDO may be the right answer, because while the DPE's I've used and the Portland FSDO agree with my reading, it sounds like there are some out there which don't. I would be ready with a FAR on your checkride just in case..
 

Rotor2Wing

Unapologetically American
Talking to your DPE and/or FSDO may be the right answer, because while the DPE's I've used and the Portland FSDO agree with my reading, it sounds like there are some out there which don't. I would be ready with a FAR on your checkride just in case..

I agree. The FSDOs that I have dealt with that want the 20 dual 10 solo are Oakland (early 2000s) Baton Rouge (mid-2000s) Atlanta (mid2000s-now) and Nashville (with in the past year).
 

NickH

Uber Driver
It turns out there is actually a lot of debate about this. I went looking for a legal opinion, but the best I found was a discussion on VR which refers to an opinion letter, which is sadly not accessible any more.

This is one of those occasions where right or wrong seems to be less important than the person you have to convince.
 

nosehair

Well-Known Member
I think he's only meaning that it's not fun reading. I don't read a lacksadasical attitude in his statement, necessarily, of that info being unimportant.
Yeah, I actually wasn't referring so much to the actual reading and loving the FARs, so much as the maybe, innocent? attitude that the training would be as he originally indicated with starting out with a 3 hour nite x/c,and so on.
If he already has personal personal knowledge of this individual's airplane skills, in light singles, if that is the checkride type, and he is looking for the minimum time to "officially log", then normally good training would follow the basic fundamental skills first, so the stage was set in my mind ( and other young reader's minds) to hear a "quickie" rating add-on.

Now, to the question, his question about the hours. He, like many others, may be you, I don't know, have made the "break-down' argument, ie., 3 of this, single engine, 3 of that, single engine, yadda, yadda, yadda, and it doesn't come up to 20 hours dual like 61.109(a) says "20 hours of flight training from an authorized instructor(airplane cfi)...in the areas of operation listed in 61.107(b)(1)
The 61.107(b)(1) is Airplane Single Engine. That's all. That 20 hours must be in ASEL, the 109(a) break down is a list of must have in certain training areas, but these minimums do not add up to the total required.
Look at the total required at first in 109(a), 40 total, 20 dual, 10 solo. That's 30. The individual makes up the program.

And I know the interpretation of that 107(b), has been "deemed" by some FSDOs and many DEs over the years, but, that's slowly changing, too, like the current sudden awareness that the 10 hours instrument in commercial are not exempted by merely having the instrument rating. The regulation has always required this under 61.129 which governs "commercial training", not "instrument training", which is non-commercial.
The intent would be to further advance the already instrument rated commercial applicants, or upgrade the non-instrument rated commercial applicants to at least a 10 hours level.

But, of course, that "interpretation" wasn't very economically popular, so it became habit to accept the instrument rating as acceptable for the commercial 10 hour requirement, but not any more.

And so is the gradual changing to the legal reading of the 61.109 reference to 61.107 as all single engine.
Depends on your neighbor hood.

And I do apologize for being rude and snappy. Wasn't nice and it never works.
 

rframe

pǝʇɹǝʌuı
But, of course, that "interpretation" wasn't very economically popular, so it became habit to accept the instrument rating as acceptable for the commercial 10 hour requirement, but not any more.
Eh? Has something "new" developed in this area?

Last clarification I saw was a letter from the FAA about 2 years ago (Hartzell, Dec 17, 2010) saying in most cases the instrument rating training could apply to the commercial requirements. To quote the FAA, "we anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet some, if not most, or quite often, meet all the requirements for instrument aeronautical experience required under 61.129."

Other than the screwed up FAA interpretation from a few years ago that caused a ruckus in the first place, I've never heard of an interpretation otherwise. The intent has always appeared to require the Commercial applicant to have 10 hours of instrument training, nothing more, and is clearly intended to provide an experience requirement for the non-instrument rated Commercial applicant.
 

Blackhawk

Well-Known Member
You can parse words about the actual time required- I've seen several interpretations thrown around by schmucks on websites. While you might find a DE to go with fewer hours than the FAA LOI I posted I would be very hesitant to do so. If the student were to have an accident the logbook would probably be scrutinized and you might find yourself on the losing side of a lawsuit or as a future reference on this board as an NTSB legal decision; on the one hand would be you stating your opinion of the FARs, while on the other side lawyers would present as evidence the FAA LOI. Now, I'm not a lawyer but I don't think such cases normally turn out well for the defendant.
 

FlyingScot

Spanish Proficient
I think it is silly that the rules of operations are such that knowledgeable, educated people can argue in circles trying to interpret them, and have to wait for a legal interpretation from legal council in D.C. to find the true meaning of many of the regs. There are plenty of stories of one FSDO or examiner interpreting something one way and it being overturned by another representative of the FAA.

I have heard of the flight portion of a checkride being delayed till after lunch because the examiner did not like some issues of aeronautical experience logged and contacted someone in D.C. for a ruling. The FAA expert agreed with the instructors interpretation and the checkride proceeded. Later the CFI found a ruling on this issue to show that the examiner was right in questioning the aeronautical experience was not kosher, the checkride should not have happened.


Now that I have the PPL figured out I am trying to tackle comprehension of the commercial aeronautical experience. Can he "perform the duties of pilot in command" when receiving dual but not rated in the aircraft?

4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in Sec. 61.127(b)(2) of this part that includes at least--
 

Blackhawk

Well-Known Member
PROPOSED FEDERAL AVIATION REGULATION ACT

1000.A No pilot or pilots, or person or persons acting on the direction or suggestion or supervision of the pilot or pilots may try, or attempt to try or make or make attempt to try to comprehend or understand any or all, in whole or in part of the herein mentioned Federal Aviation Regulations, except as authorized by the Administrator or an agent appointed by, or inspected by the Administrator.

1000.B If the pilot, or group of associated pilots becomes aware of, or realizes, or detects, or discovers or finds that he, or she, or they, are or have been beginning to understand the Federal Aviation Regulations, they must immediately, within three (3) days notify, in writing, the Administrator.

1000.C Upon receipt of the above mentioned notice of impending comprehension, the Administrator will immediately rewrite the Federal Aviation Regulations in such a manner as to eliminate any further comprehension hazards.

1000.D The Administrator may, at his or her option, require the offending pilot, or pilots, to attend remedial instruction in Federal Aviation Regulations until such time that the pilot is too confused to be capable of understanding anything.
 
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