Initial Commercial FAR requirements... I dont get it!!

K

kailuaboy

Well-Known Member
I dont understand this one.

I have been instructing since March and have sent numerous people for Commercial Multi checkrides (here we do the multi as the initial first, instead of the single). And, ive had no problem; till now.

According to 61.129 b(4) (i believe), you need either 10hrs of Solo "OR" 10hrs in a multi-engine aircraft acting PIC with an authorized instructor.

Now, heres where the problem happened. I logged the long cross country as dual (in his logbook) so I can put my sig in there as part of his requirement. Well, I was told by the examiner that I wasnt supposed to log dual in his logbook. In the remarks section i was supposed to put "Supervised Solo in accordance with Part 61.129b4, etc."

Yes, I argued with him, because I dont see where in the FARs that Im supposed to do that. I dont get this.

Also, I wouldnt have argued with him if I could just change his logbook by taking out the dual, but; the instructor before me wasnt there to take out the dual for the other flights they did together.

I left the room for a few minutes to ask our chief flight instructor and the owner, and both agreed with the examiner (im still not accepting this cause I dont see it written in there). My student is a very persuasive type of person and somehow talked his way into still taking his checkride. Dont ask me what happened, I just konw he took the checkride and passed.

If anyone can shed some light, please do so.
smile.gif


Ivan
 
Obviously examiners have differing interpretations on this reg. The examiner I work with recently came back from a meeting with the FAA and reported that logging Dual Received is acceptable for the supervised PIC portion of the commercial multi requirements. Here's a snip from the Part 61 FAQ:
[ QUOTE ]
ANSWER: Ref. § 61.129(b)(4) and § 61.51(e)(1)(i); An applicant may not log as Pilot-In-Command (PIC) for time acquired while performing the duties of pilot-in-command with an authorized instructor unless the person holds an airplane multiengine land rating on his/her pilot certificate. For logging purposes, the time shall be logged in the AMEL column, conditions of flight column, dual received column, and total time column. In the remarks column, your flight instructor should record “PIC training per § 61.129(b)(4).”

For example, let’s say the applicant performs a 5 hour cross-country flight with an authorized instructor aboard for the § 61.129(b)(4)(i) requirement. In recording this time (i.e., “. . . performing the duties of pilot in command . . . with an authorized instructor . . .”) in the applicant’s logbook, it would read as follows:

Airplane multiengine land time: 5 hours
Cross-country time: 5 hours
Dual Received time: 5 hours
Total Time: 5 hours
Description of training: PIC training per § 61.129(b)(4).
John Doe, CFI #5555555, Exp. 12-31-00

In answer to your question concerning where to record the 10 hours of performing duties of pilot in command on the FAA Form 8710?1, Airman Certificate and/or Rating Application, it is understood that the application doesn’t have a performing duties of pilot in command column. The 10 hours performing the duties as PIC with an instructor on board should be listed in the “Pilot in Command” column of the “Airman Certificate and/or Rating Application” (FAA Form 8710-1).

In answer to your question concerning whether it is possible for you to receive instruction while also "performing the duties of PIC." The intent of this provision in § 61.129(b)(4) [i.e., “. . . performing the duties of pilot in command . . . with an authorized instructor . . .”] is to permit an authorized instructor to be aboard the multiengine airplane and the instructor should only act like an SIC. The instructor should observe, evaluate, and may train the student on performing the duties of pilot in command in a multiengine airplane (e.g., CRM training). The instructor should confine their activities to giving training on “. . . performing the duties of pilot in command . . . on the areas of operation listed in § 61.127(b)(2) . . .” The instructor should put more emphasis on acting like an SIC so the applicant gets the benefit and experience of performing the duties of a pilot in command in crew concept setting (e.g. CRM training). The intent of § 61.129(b)(4), in essence, is to provide for the kind of training that is commonly referred to as crew resource management (CRM) training.


[/ QUOTE ]
 
Thanks for that..... Yeah, it looks like examiners do their own thing and interpret the FARS which ever way suits them.

I think on monday ill call the Oklahoma City office and get a definate answer.... i dont wanna call Orlando fisdo cause i think thats where he got this whole thing.

I hope others will post here too, to give their side of it.
smile.gif
 
Notice that the FAQ talks about how to record it on the 8710, not how to log it. It's not really solo, because it doesn't fit the definition of solo. It's more dual than anything else. But the DE is correct in one respect. Whichever column is used, the remarks really should reflect the requirement that is being met.

You may or may not get a "definitive" answer from OK City. You are more likely to get the answer of the guy who is on the phone that day. You might get a better response mentioning the problem to the folks who write Designee Update - they are the folks who are responsible for designee standardization.

http://afs600.faa.gov/AFS640.htm

You never know. They might choose to tackle it in an upcoming issue.
 
I know this might sound dumb, but at our 141 school we don't log it as PIC, just called FPIC, but it doesn't go into the logbook.

What do other schools do for this requirement? Is it logged as PIC and Dual?"
 
Ran into this getting my intial commercial in the Seminole. I did my x/c in a Seneca as "acting PIC," and I was told to log it as solo and PIC instead of dual. I just did as I was told, which was wrong. To make matter worse, my instructor didn't endorse the entry and had gone on to fly for XJT. Luckily, I still had his number so I was able to fax him a copy of the entries and get them signed. It's definately NOT solo, since that person is not the sole occupant of the aircraft. It's acting PIC, and not real PIC. I found this out when I got my MEI, and all that acting PIC does NOT count towards the 15 hours as PIC for the MEI (it's in the FAA FAQ, and I don't have a handy link). The way to log the supervised PIC time (according to the Ft Worth FSDO, AOPA and two local DEs) is as acting PIC and dual recieved. Other DEs might vary since as we all know, opinions are a dime a dozen when it comes to FARs.
 
Im off monday, ill call them and try talk to them.... maybe they can change this to try and get this straighten out. This is real shady and they need to get to the bottom of this. It doenst make sense to have DEs (or anyone else for that matter, FISDO, whatever) making their own interpretation of the FARS.

Im not paying $300 just cause my student doesnt have the proper time requirements as per the DEs interpretation of the FARS. NO WAY is that gonna happen. That is why I want to get this right.
 
[ QUOTE ]
It doenst make sense to have DEs (or anyone else for that matter, FISDO, whatever) making their own interpretation of the FARS.



[/ QUOTE ]

WORD. I have seen this happen and our own school has dealt with this same issue. What we do is actually write down the time in the PIC column in the logbook...however we put it in parentheses and simply do not total it for page totals. That is our way of showing the acting as PIC as well as a notation in the remarks section. The examiners have agreed that is an acceptable way of doing it around here.

Good luck and I look forward to hearing what you come up with.
 
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