Part 61 Commercial Experience

AeroT

Well-Known Member
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least: (1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least—
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.
(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.
(4) Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under §61.127(b)(1) that include—
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and
(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.




My question is... with all of the cross country requirements does that need to be done with a CFI or can all of these requirements be done on your own solo?
 
All the tasking in section (3) is required to be with an instructor because it states the word "training" in the description of the type of time. Everything else can be solo or even while carrying friends, except for the explicit "solo" requirements of section (4).
 
So under section 3... can I use my IFR cross country with my instructor for the requirements or even my cross country from my private with an instructor towards my commercial or does it have to be all fresh and new.

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
 
So under section 3... can I use my IFR cross country with my instructor for the requirements or even my cross country from my private with an instructor towards my commercial or does it have to be all fresh and new.

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

No. LOI should be following my post soon. AOPA is currently trying to get the LOI overturned, but don't expect this to happen any time soon.
 
one interpretation...

all you need to do is add "in preparation for the commercial pilot certificate" at the end of each experience requirement.

in a way they did, by saying "(3) 20 hours of training on the areas of operation listed in §61.127..."
 
I agree with AOPA that the intent (in my opinion), of requiring the instrument training was for non-instrument rated applicants. Not sure what benefit the person receives.
 
I agree with AOPA that the intent (in my opinion), of requiring the instrument training was for non-instrument rated applicants. Not sure what benefit the person receives.
Yeah, for the non-instrument rated pilot, the additonal tasks (they go beyond the private pilot tasks) make sense. The one decent argument I've heard for applying it to the instrument rated pilot is that instrument tasks should be at a higher standard for the commercial than the private-instrument - sort of like between the private instrument standards and the ATP instrument standards.
 
Yeah, for the non-instrument rated pilot, the additonal tasks (they go beyond the private pilot tasks) make sense. The one decent argument I've heard for applying it to the instrument rated pilot is that instrument tasks should be at a higher standard for the commercial than the private-instrument - sort of like between the private instrument standards and the ATP instrument standards.

That would make sense if the commercial PTS required some instrument tasks, or if adding an instrument rating to a commercial had higher PTS than adding it to a private certificate.
 
That would make sense if the commercial PTS required some instrument tasks, or if adding an instrument rating to a commercial had higher PTS than adding it to a private certificate.
And the instrument PTS tasks for the non-instrument rated commercial applicant are...?

btw, recognizing somehting as a "decent argument" does not imply agreement, somehting we tend to forget in these polarized times.
 
Update:
http://www.aopa.org/advocacy/articles/2010/101220FAA_clarification_on_letter_of_interpretation.html

http://download.aopa.org/epilot/2010/101220theriault.pdf

“In the response, the FAA confirmed that as long as the training is documented properly, the instrument training received in pursuit of an instrument rating may be counted toward the commercial certificate,” said Kristine Hartzell, AOPA manager of regulatory affairs.

AOPA has reviewed the FAA’s clarification and urges instrument pilot applicants and flight instructors to be sure that instrument training is clearly logged to indicate that the training given meets the requirements of 14 CFR 61.65 as well as those of 14 CFR 61.129. That would avoid questions about the training’s applicability should the pilot one day advance to training for a commercial pilot certificate.
 
Update:
http://www.aopa.org/advocacy/articles/2010/101220FAA_clarification_on_letter_of_interpretation.html

http://download.aopa.org/epilot/2010/101220theriault.pdf

“In the response, the FAA confirmed that as long as the training is documented properly, the instrument training received in pursuit of an instrument rating may be counted toward the commercial certificate,” said Kristine Hartzell, AOPA manager of regulatory affairs.

AOPA has reviewed the FAA’s clarification and urges instrument pilot applicants and flight instructors to be sure that instrument training is clearly logged to indicate that the training given meets the requirements of 14 CFR 61.65 as well as those of 14 CFR 61.129. That would avoid questions about the training’s applicability should the pilot one day advance to training for a commercial pilot certificate.
So, would that mean if you fly with someone with just CFII you couldn't use it?
 
It is properly referred to as "Flight instructor — Airplane multi-engine land." Whereas CFII tickets simply say "Flight instructor - instrument."

Actually my CFII certificate said, and still says for that matter, "Instrument Airplane". Aircraft Category is still given and that is why CFIIs used to be able to do instrument instruction in multi-engine aircraft without their MEI. The reg now requires the Class to be specified on the certificate as well in order to do any flight instruction at all.

61.195 Flight instructor limitations and qualifications said:
(b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
(1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and
(2) If appropriate, a type rating.

A person that only holds a CFII only has a category specified and as a result may not do any flight training toward an instrument rating. They could do ground though.
 
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