Pt 61 Commercial Req's Questions - 61.129

Re: Pt 61 Commercial Req\'s Questions - 61.129

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But if you do it on an IFR flight plan, and the DE that gives you your ride has the same opinion as me (and I know the ones around here that I deal with do), then you'll have to re-do that flight and reschedule your checkride...

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Just looking at the logbook, unless intrument time was logged (which would be stupid and WOULD go against the reg), how would the DE know it was on an IFR flight plan? I don't go in and put "on IFR flight plan" or "on VFR flight plan" in my logbook.

As far as vectored into the cloud, you COULD ask for a deviation around the cloud on an IFR flight plan. If it's a decent build up and there's not much traffic in the area, odds are you'll get it.

On principle, I agree with both you and Midlife. I'd do the dual flight under VFR with my student. Just saying that it can be done and is legal.

Other regs that are written with intent (ie the supervised PIC reg for the CMEL initial) don't work like they should. For that reg, the intent is to appease the insurance companies. The FAA would prefer that that time be solo, ala the PPL requirements. At least, that's how I read it. However, that "supervised PIC" that IMO should be solo if it weren't for insurance, does NOT count towards your 15 PIC for the MEI. Ironically, if you flew it solo, it would......
 
Re: Pt 61 Commercial Req\'s Questions - 61.129

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However, that "supervised PIC" that IMO should be solo if it weren't for insurance, does NOT count towards your 15 PIC for the MEI. Ironically, if you flew it solo, it would......


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That's interesting. I guess I never thought of that situation since I already had my multi-rating when I did the 10 hours supervised PIC. Did you put those hours under the solo or pic column on the 8710?
 
Re: Pt 61 Commercial Req\'s Questions - 61.129

PIC. Can't put it under solo since the instructor is in the plane with you.

I spent about an hour on the phone trying to get some answers on that one thing. 10 min with the FSDO, and I learned they knew nothing. Talked to a DE, and he said to get something in writing from the FSDO. Oddly, AOPA was the most helpful. When I took what they told me to the FSDO, they said "Well, I guess that makes sense...."
 
Re: Pt 61 Commercial Req\'s Questions - 61.129

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61.129(a)(3)
(iii) One cross-country flight of at least 2 hours in a single-engine airplane in day VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure

- Day VFR conditions, but can it be on an IFR flight plan? This has to be dual (with CFI) correct?

61.129(a)(3)
(iv) One cross-country flight of at least 2 hours in a single-engine airplane in night VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure;

- Night VFR consitions, but can it be on an IFR flight plan? This has to be dual (with CFI) correct?

61.129(a)(4)
(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.

- This makes no mention of IFR or VFR so am I correct in thinking it can be on an IFR flight plan and in IFR conditions?

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My take on it is to perform it on a VFR flight plan while in VMC. Would an IFR flight plan be a violation? IMO, no. But to me, the intent and focus of the Commercial License is contact flying, and everything that goes with it. That is, the intent isn't instruments, nor IFR rules and regs. There's no approaches to shoot on these XCs, just as there are no contact maneuvers to train/perform during instrument training. For me, I'd leave the IFR flight plans for instrument training, or for when the CPL stud has completed the CPL to use them as he wants to. For CPL training, I consider it "advanced VFR", or "Super Private", so to speak, and train to such. It's some new regs, some new maneuvers, and tightened parameters from Private How many IFR flight plans do you file for the Private cross-countries? That's my interpertation. I too believe the regs could be a little more specific and clear on this issue, as they can on many things; but it's what we've got to deal with, so we have to make do.
 
Re: Pt 61 Commercial Req\'s Questions - 61.129

I agree with you Mike that the commercial cert is one that shows you have taken your skills to a new level... but most who get the comm are already instrument rated and by training for a commercial cert one should become more skilled in both vfr / ifr. A lot of ifr skills begin to receed when you go up and practice lazy 8s flight after flight...
 
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