What does the word "training" mean...

ahsmatt7

ahsmatt7

Well-Known Member
(b) For an airplane multiengine rating. Except as provided in paragraph (i) of this section, 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:

(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)(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;
(iii) One 2-hour cross country flight in a multiengine 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 multiengine 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 multiengine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.
(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 §61.127(b)(2) of this part that includes at least—
(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 with a traffic pattern) at an airport with an operating control tower.
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Does the word training mean that this the requirements listed must be done in the dual fashion? It doesn't mention using an "authorized instructor" until the three hours required for checkride preparation.

I am looking to get my CMEL as my initial Comm cert. and I already have my Private AMEL. I had done the two 100 mile XC already thinking I could have done them solo but now I am having doubts. I was also under the impression that the 10 hrs i was with an instructor for my PPL-AMEL could be used towards the CMEL.

Whats the deal? I have 30 hrs multi already.... I don't feel like shoveling out money when I don't need someone next to me to warm the right seat......especially if I have already met the requirements.
 
ahsmatt7 said:
Does the word training mean that this the requirements listed must be done in the dual fashion?
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It means the 20 hours must include all of the stuff listed below. Except that the 10 solo can include an instructor and be counted towards the 20 hours of training... Unless you already have a C-ASEL, C-ASES, or C-MES, in which case there are no minimum required hours (61.63). Which is why cheapskates like me would prefer to do a multi add on in 4 hours dual instead of 20 ;)
 
I am still confused :p... So the 20 hours required of the section does not have be done with an instructor in the right seat?
 
ahsmatt7 said:
Does the word training mean that this the requirements listed must be done in the dual fashion?
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Yes. Look at 61.51 (the Universal Rule of Logging Flight Time) and find what is loggable as "training." You can also look for the definiiton of "training" - I forget offhand if it's in FAR 1.1 or 61.1.
 
MidlifeFlyer said:
Yes. Look at 61.51 (the Universal Rule of Logging Flight Time) and find what is loggable as "training." You can also look for the definiiton of "training" - I forget offhand if it's in FAR 1.1 or 61.1.
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So, does logging sim or ground with an authorized instructor count as "training" (not logging flight time)?
 
My instructor got confused with that. I'd had 1 commercial maneuver lesson and 2 X-Cs required for commercial and he still thinks that I need 20 hours with him minus the 1 lesson. He apparently doesn't think that the dual X-Cs I did a few months back for the rating count toward the 20 hours required.
 
I am still confused on this reg. The word " training" is defined as a flight with an authorized instructor. However, if one looks at the PPL aeronautical experience requirment reg., under solo flight, it states that the student needs 10 hours of "training." How can a student log training time as solo time if training time can only be logged as dual?
 
ahsmatt7 said:
I am still confused :p... So the 20 hours required of the section does not have be done with an instructor in the right seat?
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Some of it does and some of it doesn't. You already have your PPL Multi raing, so you've probably already done the 10 hours of complex airplane training. If you're Instrument rated with Multi Engine privileges, you may or may not be able to count that toward your commercial training. You'll definitely need to do the 2 hour, 100 mile Day VFR Night VFR dual flights, and also the 300 mile solo cross country, and if you haven't accumulated the 5 hours of night VFR and 10 night take offs & landings, in the traffic pattern at a controlled airport,you'll need to complete those too.
 
ahsmatt7 said:
I was also under the impression that the 10 hrs i was with an instructor for my PPL-AMEL could be used towards the CMEL.
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This is a very, very common misunderstanding that is also mis-understood and/or abused by flight instructors and examiners.

Flight training in preparation for a PP certificate cannot be used as training for a commercial certificate. Says so right there in the regs. Always has.
.
The 20 hours of required training you are quoting in FAR 61.129(b)(3) is training on the areas of operation listed in 61.127(b)(2)
61.127(b)(2) seems the same as 61.107(b)(2) for a PP multi, but the standards are different.
61.127(b)(2) is for PP certification PTS standards, while 61.129(b)(2) is training to commercial PTS standards.

No double-dipping. I know it has been done - a lot, but that is how the legals read it. That's also why the training for instrument does not fill the requirement for the commercial under 61.129(b)(3)(i). Those hours were in training for an IR as a PP under 61.65
 
nosehair said:
This is a very, very common misunderstanding that is also mis-understood and/or abused by flight instructors and examiners.

Flight training in preparation for a PP certificate cannot be used as training for a commercial certificate. Says so right there in the regs. Always has.
.
The 20 hours of required training you are quoting in FAR 61.129(b)(3) is training on the areas of operation listed in 61.127(b)(2)
61.127(b)(2) seems the same as 61.107(b)(2) for a PP multi, but the standards are different.
61.127(b)(2) is for PP certification PTS standards, while 61.129(b)(2) is training to commercial PTS standards.

No double-dipping. I know it has been done - a lot, but that is how the legals read it. That's also why the training for instrument does not fill the requirement for the commercial under 61.129(b)(3)(i). Those hours were in training for an IR as a PP under 61.65
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If properly documented, it CAN count and you CAN double dip.
 
How does one go about "properly documenting" a flight like the long XC? just put in the remarks that its for the IFR and CSEL rating and cert?
 
ahsmatt7 said:
I am still confused on this reg. The word " training" is defined as a flight with an authorized instructor. However, if one looks at the PPL aeronautical experience requirment reg., under solo flight, it states that the student needs 10 hours of "training." How can a student log training time as solo time if training time can only be logged as dual?
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I think you might not be parsing the reg and it's basic outline format correctly.

==============================
(b) For an airplane multiengine rating. Except as provided in paragraph (i) of this section, 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:

(1)...

(2)...

(3) 20 hours of trainin
​
g on the areas of operation... that includes at least—
(i)...
(ii)...
(iii)...
(iv)...
(iv)...​


(4) 10 hours of solo flight time in ...that includes at least—
(i)...​
==============================

The training (dual) and solo requirements are separate.
 
ahsmatt7 said:
How does one go about "properly documenting" a flight like the long XC? just put in the remarks that its for the IFR and CSEL rating and cert?
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Pretty much. There's been no guidance as to whether it requires reference to the specific regs for the requirements, but (strictly personal opinion) that a comment that clearly indicates that the flight was do to satisfy both requirements would be acceptable.
 
mojo6911 said:
If properly documented, it CAN count and you CAN double dip.
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Depends what you are trying to double-dip. Instrument for Commercial? Sure. There's overlap.



But. as nosehair pointed out, the issue has always been that each certificate and rating has requirements that relate to certain operations.

Last year, the FAA Chief Counsel opened the door to properly documented double-dipping in the context of the instrument rating and the commercial certificate, recognizing that there was some overlap and that the 10 hours of instrument work required for the commercial could conceivably have been accomplished during instrument training (but not vice versa).

But this year, the FAA Chief Counsel, closed that door when it came to double-dipping private and commercial requirements. Read the rationale and you'll find it is very similar to what nosehair has said in this and other threads in which the question has come up.

==============================
Because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards, the type oftraining contemplated by § 61. 129(a)(3)(iii) is not interchangeable with the kind required for a private pilot certificate. See id.; 60 Fed. Reg. at 41181-82. Accordingly, any cross-country training experienced by a student pilot would not be credited toward the requirements of § 61.129(a)(3)(iii).
==============================


http://www.faa.gov/about/office_org.../interpretations/data/interps/2011/Murphy.pdf
 
MidlifeFlyer said:
It's not questionable at all; it was an intentional change to the regs in 2009. They don't have to be VFR.
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Upon further review, Midlife is correct; they don't have to be VFR conditions. They DO need to be dual instruction, however. Also, the 300 mile solo cross country does not necessarily have to be solo
 
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