Private Multi & Commercial Multi - Intial

F

FDX8891

Well-Known Member
I'm having trouble interpreting part 61 regarding this issue.

When dealing with students working on their initial private and commercial in a multi-engine airplane, how much time do the applicants need to have in a twin? If anyone could help me interpret this, that would be greatly appreciated.
 
If its the initial certificate I think all of the XC, dual, and solos have to be done in the class sought.
 
Private 61.109 (b) 30 hours. 20 with an "authorized instructor" (MEI), and 10 solo.

Commercial 61.129 (b) same: 30 hours: 20 dual & 10 solo
 
nosehair said:
Private 61.109 (b) 30 hours. 20 with an "authorized instructor" (MEI), and 10 solo.

Commercial 61.129 (b) same: 30 hours: 20 dual & 10 solo
Click to expand...

For the solo requirement in commercial, that 10 solo can actually be 10 performing duties of PIC under supervision of an authorized instructor. THis time then gets logged in the PIC column, with a statement required in the remarks by the CFI thats states, "performing duties of PIC under supervision" or PICUS, then signed by CFI. The instructor logs pic but not dual given. THe student is not technically the PIC, but is performing the duties. THis info comes from the SDL FSDO. Also remember that a private minimum under part 61 is 40 hrs, not 30 total, whbich leaves 10 hrs of either dual or solo, just as in SEL.
 
It is possible to do the initial commercial multi with 20 hours in the twin, you just have to make sure the flights get logged in the right columns.
 
Ziggyfuzz said:
For the solo requirement in commercial, that 10 solo can actually be 10 performing duties of PIC under supervision of an authorized instructor. THis time then gets logged in the PIC column, with a statement required in the remarks by the CFI thats states, "performing duties of PIC under supervision" or PICUS, then signed by CFI. The instructor logs pic but not dual given. THe student is not technically the PIC, but is performing the duties. THis info comes from the SDL FSDO.
Click to expand...
Interesting. I have not heard this local FSDO ruling, however, I am in the ATL FSDO, and we usually are the last to "get the word".
Of course, a local FSDO ruling has no real legal power of FAR interpretation, so, do you know of any FAA Legal Letter of Interpretation that supports that?
 
mojo6911 said:
It is possible to do the initial commercial multi with 20 hours in the twin, you just have to make sure the flights get logged in the right columns.
Click to expand...
This sounds like you are combining the dual and 'solo with a CFI' required times....
 
nosehair said:
Interesting. I have not heard this local FSDO ruling, however, I am in the ATL FSDO, and we usually are the last to "get the word".
Of course, a local FSDO ruling has no real legal power of FAR interpretation, so, do you know of any FAA Legal Letter of Interpretation that supports that?
Click to expand...

Perhaps I'm misunderstanding the issue here, but the 'Acting as PIC' isn't an issue of interpretation.

14 cfr 61.129 (b) For an airplane multiengine rating...a person who applies for a commercial pilot certificate with an airplane category and multiengine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
...
(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), ...

... am I missing the point?

-Fox
 
nosehair said:
This sounds like you are combining the dual and 'solo with a CFI' required times....
Click to expand...

Nope.

20 hours of training doesn't have to be in a multi-engine aircraft.

(3) 20 hours of training on the areas of operation listed in Sec. 61.127(b)(2) 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 multiengine airplane;]

(ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine-powered, or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine seaplane that has flaps and a controllable pitch propeller;
Click to expand...

The part I bolded imply that the 20 hours of training doesn't all have to be in a multi-engine aircraft, only 10 hours. If you combine the required 5 hours of instrument training in a multi with the dual cross countries, you can easily get 10 hours of training and 5 hours of instrument. That satisfy the training requirement.

Then, you have the remaining 10 hours "performing the duties of PIC" for a total of 20 hours.

This is from the old FAA FAQ:

http://www.boundvortex.com/Downloads/Multiengine Training FAQ61-13.pdf

So the grand total is 20 hours for the final tabulation of absolute minimum flight time in a
multiengine airplane. The rule requires 10 hours of dual training time and 10 hours of solo or
performing the duties as a PIC with an instructor on board.
Click to expand...
 
nosehair said:
Private 61.109 (b) 30 hours. 20 with an "authorized instructor" (MEI), and 10 solo.

Commercial 61.129 (b) same: 30 hours: 20 dual & 10 solo
Click to expand...

So far for a private multi applicant who's doing their initial in a twin, I'm coming up with this as far as what's required to be done in a twin:

10 hours solo
3 hours xc
3 hours night
3 hours hood
3 hours w/in 2 cal mos in prep for the practical.

That brings a grand total of 22 hours required in a twin from what I'm counting. Am I missing something here? I see the 20 hours of training and 10 hours of solo, but only really see 22 hours where the regs state things must be done in a twin.
 
View attachment 61.129 Ruling.pdf
nosehair said:
Interesting. I have not heard this local FSDO ruling, however, I am in the ATL FSDO, and we usually are the last to "get the word".
Of course, a local FSDO ruling has no real legal power of FAR interpretation, so, do you know of any FAA Legal Letter of Interpretation that supports that?
Click to expand...

I work in the region of the country that does more flight training and certifications than any other in the US. Pretty accurate here, as I understand we here in Arizona pretty much set the bar. Here is a ruling from John Lynch, FAA chief counsel regarding this issue. See attachment top left of this post. I got this from Mr Lynch in 2009 after raising the issue with a large "ATP" flight school to be "un-named"! The school was improperly training students at the time and I called em out on it, this letter and ruling cleared thigs right up. Some in my favor, some in theirs, we both learned from it.
 
Ziggyfuzz said:
For the solo requirement in commercial, that 10 solo can actually be 10 performing duties of PIC under supervision of an authorized instructor. THis time then gets logged in the PIC column, with a statement required in the remarks by the CFI thats states, "performing duties of PIC under supervision" or PICUS, then signed by CFI. The instructor logs pic but not dual given. THe student is not technically the PIC, but is performing the duties. THis info comes from the SDL FSDO. Also remember that a private minimum under part 61 is 40 hrs, not 30 total, whbich leaves 10 hrs of either dual or solo, just as in SEL.
Click to expand...

The second sentence, should actually have read "this time then does not get logged in the PIC column".
 
FDX8891 said:
So far for a private multi applicant who's doing their initial in a twin, I'm coming up with this as far as what's required to be done in a twin:

10 hours solo
3 hours xc
3 hours night
3 hours hood
3 hours w/in 2 cal mos in prep for the practical.

That brings a grand total of 22 hours required in a twin from what I'm counting. Am I missing something here? I see the 20 hours of training and 10 hours of solo, but only really see 22 hours where the regs state things must be done in a twin.
Click to expand...


read 61.109 (b) that entire section is in a multi engine airplane. Acutally states in the very first line, "20 hours of flight training and 10 hrs of solo flight on the areas of operation listed in 61.107 (b)(2). 40 hours total...the only part that does not specifically mention "in a multi -engine airplane" is the 10 hrs solo time. Most insurance companies will not allow an un-certificated pilot to solo in a twin, the Feds know this and have accomodated somewhat. So, you are looking at 30 hrs in a twin. BTW, just a split hair or two here, the FAA does not issue pilots licenses, they are "certificates". You may look up on your own what the difference is! I was made aware of this fact a few years ago while in DPE training in OKC.
 
Acrofox said:
Perhaps I'm misunderstanding the issue here, but the 'Acting as PIC' isn't an issue of interpretation.

14 cfr 61.129 (b) For an airplane multiengine rating...a person who applies for a commercial pilot certificate with an airplane category and multiengine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
...
(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), ...

... am I missing the point?

-Fox
Click to expand...
My point was that the "acting as PIC w/authorized instructor" time is not loggable as PIC time. It is creditable towards the 'solo' requirement, but still does not meet any of the 61.51 requirements for PIC.
Similar to 'sim time'. Simulator time may be credited towards required instrument time, but is not loggable as PIC time, or flight time.
 
Ziggyfuzz said:
read 61.109 (b) that entire section is in a multi engine airplane. Acutally states in the very first line, "20 hours of flight training and 10 hrs of solo flight on the areas of operation listed in 61.107 (b)(2). 40 hours total...the only part that does not specifically mention "in a multi -engine airplane" is the 10 hrs solo time. Most insurance companies will not allow an un-certificated pilot to solo in a twin, the Feds know this and have accomodated somewhat. So, you are looking at 30 hrs in a twin. BTW, just a split hair or two here, the FAA does not issue pilots licenses, they are "certificates". You may look up on your own what the difference is! I was made aware of this fact a few years ago while in DPE training in OKC.
Click to expand...

So how would a private pilot applicant who's doing their initial in a twin meet the 10 hour solo requirement? Would they have to go into a single engine airplane and meet the solo requirements that way?
 
nosehair said:
My point was that the "acting as PIC w/authorized instructor" time is not loggable as PIC time. It is creditable towards the 'solo' requirement, but still does not meet any of the 61.51 requirements for PIC.
Similar to 'sim time'. Simulator time may be credited towards required instrument time, but is not loggable as PIC time, or flight time.
Click to expand...

Ah. It wasn't clear to me that the discussion was about logging time.

In that case, I've heard the bit about logging PIC is explicitly stated in the preamble. Only thing is... where the heck can I find the preamble? I've spent hours searching through the GPO website trying to dredge up the exact verbiage.

Thoughts?

-Fox
 
Acrofox said:
Ah. It wasn't clear to me that the discussion was about logging time.

In that case, I've heard the bit about logging PIC is explicitly stated in the preamble. Only thing is... where the heck can I find the preamble? I've spent hours searching through the GPO website trying to dredge up the exact verbiage.

Thoughts?

-Fox
Click to expand...

See an earlier post I made with a PDF attachment from FAA chief legal counsel...
 
FDX8891 said:
So how would a private pilot applicant who's doing their initial in a twin meet the 10 hour solo requirement? Would they have to go into a single engine airplane and meet the solo requirements that way?
Click to expand...

If they couldn't be insured, that would be correct, since the reg read "10 hours solo time in an airplane". 61.109 (b)(5) The rest of the section specifically mentions a "multi engine airplane".
 
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