Consolidation 14 CFR 121.434
#1
Line Holder
Thread Starter
Joined APC: Jul 2018
Posts: 55

Trying to wrap my head around this regulation since there are a lot of undefined words. From my understanding, 100 hours within 120 days, can be extended to 150 days with the appropriate actions. My questions are in regards to what counts towards the 100 hours.
IOE supposedly counts, now is that block time, or a maximum set of hours per leg?
Flying has to be done under Part 121, Part 91 doesn't count, if the operator also does Part 121. Is that understood correctly?
IRO (flying as a relief officer) does not count correct? You have to be in the seat for Takeoff and Landing for the hours to count. So flying as an IRO for someone else's IOE would not count.
As for part F), what exactly is Group 2 transition training? Because that part mentions being able to substitute up to %50 of the hours with takeoff and landings.
Thanks in advance for any answers and clarification!
IOE supposedly counts, now is that block time, or a maximum set of hours per leg?
Flying has to be done under Part 121, Part 91 doesn't count, if the operator also does Part 121. Is that understood correctly?
IRO (flying as a relief officer) does not count correct? You have to be in the seat for Takeoff and Landing for the hours to count. So flying as an IRO for someone else's IOE would not count.
As for part F), what exactly is Group 2 transition training? Because that part mentions being able to substitute up to %50 of the hours with takeoff and landings.
Thanks in advance for any answers and clarification!

#2
Disinterested Third Party
Joined APC: Jun 2012
Posts: 5,400

Consolidation is the period that you consolidate the flying skills and training you've been given, in the aircraft type, in pilot operations, for that operator.
How many hours can you occupy the pilot seat? Eight hours? You can log time for consolidation that you are in the pilot seat. You can't log more than 8 hours. Time in the IRO seat is not part of consolidation.
These are questions you should address to your check airman at your operation. Yes, up to 50% of your consolidation can be accounted by landings on a one for one basis (one landing for one hour), but that's what the FAA allows. Many operators don't: they want you to log the full 100 hours of consolidation as pilot. Simply because the FAA allows that, doesn't not mean that your operator does.
121.434 was amended in 1971 to allow time spent in ferry and maintenance flights to also be included in the consolidation requirements. The Federal Register preamble at the time of the final rule notes that United Airlines (et al) argued that pilots having completed initial training had sufficient experience to go on the line. The FAA disagreed and pressed the issue of consolidation as necessary, but made allowances for opportunities to gain the hours, including other than line operations.
You will find aircraft groups defined in 121.400. Group I are propeller driven, including turboprop and reciprocating powered airplanes. Group II are turbojet powered. 121.400 has the definitions that you're looking for.
How many hours can you occupy the pilot seat? Eight hours? You can log time for consolidation that you are in the pilot seat. You can't log more than 8 hours. Time in the IRO seat is not part of consolidation.
These are questions you should address to your check airman at your operation. Yes, up to 50% of your consolidation can be accounted by landings on a one for one basis (one landing for one hour), but that's what the FAA allows. Many operators don't: they want you to log the full 100 hours of consolidation as pilot. Simply because the FAA allows that, doesn't not mean that your operator does.
121.434 was amended in 1971 to allow time spent in ferry and maintenance flights to also be included in the consolidation requirements. The Federal Register preamble at the time of the final rule notes that United Airlines (et al) argued that pilots having completed initial training had sufficient experience to go on the line. The FAA disagreed and pressed the issue of consolidation as necessary, but made allowances for opportunities to gain the hours, including other than line operations.
You will find aircraft groups defined in 121.400. Group I are propeller driven, including turboprop and reciprocating powered airplanes. Group II are turbojet powered. 121.400 has the definitions that you're looking for.
#3
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,211

Trying to wrap my head around this regulation since there are a lot of undefined words. From my understanding, 100 hours within 120 days, can be extended to 150 days with the appropriate actions. My questions are in regards to what counts towards the 100 hours.
IOE supposedly counts, now is that block time, or a maximum set of hours per leg?
Flying has to be done under Part 121, Part 91 doesn't count, if the operator also does Part 121. Is that understood correctly?
IRO (flying as a relief officer) does not count correct? You have to be in the seat for Takeoff and Landing for the hours to count. So flying as an IRO for someone else's IOE would not count.
As for part F), what exactly is Group 2 transition training? Because that part mentions being able to substitute up to %50 of the hours with takeoff and landings.
Thanks in advance for any answers and clarification!
IOE supposedly counts, now is that block time, or a maximum set of hours per leg?
Flying has to be done under Part 121, Part 91 doesn't count, if the operator also does Part 121. Is that understood correctly?
IRO (flying as a relief officer) does not count correct? You have to be in the seat for Takeoff and Landing for the hours to count. So flying as an IRO for someone else's IOE would not count.
As for part F), what exactly is Group 2 transition training? Because that part mentions being able to substitute up to %50 of the hours with takeoff and landings.
Thanks in advance for any answers and clarification!
#4
Line Holder
Thread Starter
Joined APC: Jul 2018
Posts: 55

Ok, thank you all for the clarification. From what I was told about IRO, time only counts if you are the pilot flying so PF or PM. I don't mean the time you are performing IRO duties as in sitting in the observer seat for take off or landing. I mean when you switch crews for a long flight. So you and the other IRO switch with the PF and PM to stay at the controls while the PF/PM are sleeping/resting. I thought since you are at the controls and in control of the aircraft, it should count.
#5
Disinterested Third Party
Joined APC: Jun 2012
Posts: 5,400

To be clear, you're talking about hours toward consolidation: if you're in a pilot seat, performing pilot duties, those hours count toward consolidation. It doesn't matter whether you've been assigned IRO or as the first officer for the flight.
If you're talking about logging hours in general, then it's block time for the flight, if you're a crew member on that flight.
If you're talking about logging hours in general, then it's block time for the flight, if you're a crew member on that flight.
#6
Line Holder
Thread Starter
Joined APC: Jul 2018
Posts: 55

I've been told part a) of the regulations essentially says a company cannot use you as a required crew member until you complete operating experience and the consolidation. So technically, I could not be used as IRO until I complete consolidation. So any time I did fly as an IRO would not count towards consolidation.
#7
Gets Weekends Off
Joined APC: Feb 2006
Position: B-737NG preferably in first class with a glass of champagne and caviar
Posts: 5,735

I've been told part a) of the regulations essentially says a company cannot use you as a required crew member until you complete operating experience and the consolidation. So technically, I could not be used as IRO until I complete consolidation. So any time I did fly as an IRO would not count towards consolidation.
#8
Disinterested Third Party
Joined APC: Jun 2012
Posts: 5,400

Your "operating experience," sometimes called OE, or IOE, is time that you spend as a required crew member under the supervision of a check airman captain. This is where you apply what you learned in ground school. You were taken through a type rating in ground school and in the simulator, and given a brief introduction to line operations in a line-oriented flight training (LOFT) session (for those operators that do so), but OE is when you put the academic airplane training into a practical environment. You learn how it's done the company way, and how to interact in practice, with your crew, as well as how to show up at the gate, your first walk-around, getting in and out of the cockpit, and so on. During this time, you are a required crew member.
Likewise, during the period that you're consolidating hours, you're acting as a required crew member. Only the hours spent at the controls in a pilot station may be counted toward your consolidation hours, and that includes your hours spent in OE. All of that will be as a required crew member. There's really no provision or situation in which you could be accruing hours toward OE or consolidation, unless you're a required crew member: that's what OE and consolidation is all about.
Your time spent as IRO when you are not at the flight controls is not creditable toward consolidation. If you are an IRO and spent five hours in either the right or left seat, then those five hours count toward your consolidation. If you spent another four hours in a bunk, at the IRO station, etc, then those four hours do not count toward your consolidation. If the block time is nine hours, five at a pilot station and four not, then you can log the nine hours; you may only log five toward consolidation. You're a required crew member the entire time. Being a required crew member assigned to the flight is only part of what allows you to credit time toward consolidation; you must also be at a pilot station (at the controls). You do not need to be the pilot flying; you can be the pilot not flying (pilot monitoring, non-handling pilot, yada, yada), but you must be at a pilot station in the left or right seat to credit the time toward consolidation. As a required crew member, the block time of the flight is counted against your accumulated flight time under the regulation: you can log all of it. Only the five hours at the controls counts for consolidation. All of it is time spent as a required crew member. Only five hours of it is time spent as a required crew member at a pilot station.
You keep saying, "I've been told..." but what have you read when you study the regulation?
#9
Gets Weekends Off
Joined APC: Oct 2013
Posts: 1,658

You don't need to be flying with a check airman for consolidation, only for operating experience, although all the OE hours count towards consolidation.
#10
Line Holder
Thread Starter
Joined APC: Jul 2018
Posts: 55

I have read the regulation several times thoroughly and I agree with what you all said. I am trying to pass that on to my superiors without sounding like an ass. They keep mentioning the following part:§ 121.434 Operating experience, operating cycles, and consolidation of knowledge and skills.
(a)No certificate holder may use a person nor may any person serve as a required crewmember of an airplane unless the person has satisfactorily completed, on that type airplane and in that crewmember position, the operating experience, operating cycles, and the line operating flight time for consolidation of knowledge and skills, required by this section, except as follows:
(a)No certificate holder may use a person nor may any person serve as a required crewmember of an airplane unless the person has satisfactorily completed, on that type airplane and in that crewmember position, the operating experience, operating cycles, and the line operating flight time for consolidation of knowledge and skills, required by this section, except as follows:
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