61.129
01-14-2011, 07:42 AM
#1
Gets Weekends Off
Thread Starter
Joined APC: Mar 2006
Position: DHC-8 SIC
Posts: 634
61.129
As I am preparing for my commercial, I was a little taken aback by some of the contents of 61.129.
1) 100 hours in powered aircraft, of which 50 hours must be in airplanes. (I have this)
2) 100 hours of PIC time including 50 hours in airplanes, 50 hours x-country, etc. (I will have it by the time I reach the 250 hours)
3) 20 hours of training on the areas of operation...
i. 10 hours of instrument training etc etc.
ii. 10 hours of training in an airplane that has a retractable gear etc etc
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 n.m.
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 n.m.
4) 10 hours of PIC time to include
i. 1 cross country flight of not less than 300 n.m...with landings at a minimum of 3 points one of which is a straight-line distance of at least 250 n.m.
ii. 5 hours in night VFR conditions with 10 take offs and landings at an airport with an operating control tower.
My question is simple. What if I have already met some of these requirements during my PPL and instrument training? Does this mean I have to obtain 10 more hours of instrument training even though I just got my instrument rating? Also would it be cheaper to do this by taking an instructor along on some of these cross country flights and being under the hood? Also I have about 180 hours now and my plan was to built some solid solo time until I reached around 200 hours or so. According to this regulation I will need a good 30 hours of dual time...Any suggestions are highly appreciated....From what I can understand not all of the commercial candidates have a fresh instrument rating and thus the regulation. I will need at least 20 hours in a complex/high performance airplane. So let's do the math.
Currently 180 hours. + 30 PIC cross country time = 210.
+10 for instrument training, + 20 for complex training = 240~
The rest can be full-filled by either training for commercial maneuvers in a Skyhawk/150 or cross country time.
1) 100 hours in powered aircraft, of which 50 hours must be in airplanes. (I have this)
2) 100 hours of PIC time including 50 hours in airplanes, 50 hours x-country, etc. (I will have it by the time I reach the 250 hours)
3) 20 hours of training on the areas of operation...
i. 10 hours of instrument training etc etc.
ii. 10 hours of training in an airplane that has a retractable gear etc etc
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 n.m.
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 n.m.
4) 10 hours of PIC time to include
i. 1 cross country flight of not less than 300 n.m...with landings at a minimum of 3 points one of which is a straight-line distance of at least 250 n.m.
ii. 5 hours in night VFR conditions with 10 take offs and landings at an airport with an operating control tower.
My question is simple. What if I have already met some of these requirements during my PPL and instrument training? Does this mean I have to obtain 10 more hours of instrument training even though I just got my instrument rating? Also would it be cheaper to do this by taking an instructor along on some of these cross country flights and being under the hood? Also I have about 180 hours now and my plan was to built some solid solo time until I reached around 200 hours or so. According to this regulation I will need a good 30 hours of dual time...Any suggestions are highly appreciated....From what I can understand not all of the commercial candidates have a fresh instrument rating and thus the regulation. I will need at least 20 hours in a complex/high performance airplane. So let's do the math.
Currently 180 hours. + 30 PIC cross country time = 210.
+10 for instrument training, + 20 for complex training = 240~
The rest can be full-filled by either training for commercial maneuvers in a Skyhawk/150 or cross country time.
01-14-2011, 10:26 AM
#3
Prime Minister/Moderator
Joined APC: Jan 2006
Position: Engines Turn Or People Swim
Posts: 39,261
What Josh said, part 61 aeronautical experience requirements can be met with any and all previous flight experience you have accumulated as long as it meets the stated conditions. You did not need to be "working on" the rating in question when you did the flying.
they just want you to have the experience, they don't care what your status was when you got it (as long as it was legal).
they just want you to have the experience, they don't care what your status was when you got it (as long as it was legal).
01-14-2011, 12:34 PM
#4
Gets Weekends Off
Joined APC: Nov 2008
Posts: 826
I'm going to have to disagree in part with the other answers.
When it comes to general experience, such as the 250 hours of flight time or the 100 hours of PIC in certain types of aircraft, those are all cumulative.
But for anything that is a "training" requirement, it has to be at least post-private training. So, for example, if you happened to do a 2-hour, 100 nm night dual cross country to satisfy your private night cross country training requirement, it would not count toward the commercial.
The FAA Chief Counsel even went so far as to say recently that even an instrument rating doesn't satisfy the instrument training requirement in 61.129. There's a huge controversy about that one with even AOPA stepping in to get the FAA to change its mind.
Here's the opinion...
http://www.faa.gov/about/office_org/.../Theriault.pdf
a follow-up reaffirming that private experience doesn't count:
http://www.faa.gov/about/office_org/...011/Murphy.pdf
Here's the AOPA dealing with the instrument training issue:
AOPA Online: FAA clarifies commercial-pilot instrument requirements
I don't think that page requires membership but in case it does:
==============================
FAA clarifies commercial-pilot instrument requirements
AOPA urges applicants, CFIs: Log time precisely
By Dan Namowitz
On Dec. 17, the FAA issued a formal response to AOPA’s request for clarification on a letter of interpretation (LOI) that stated that hours used to obtain the instrument rating would not count toward the commercial certificate.
“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 reported Nov. 4 on Hartzell’s letter to the FAA requesting clarification of its LOI.
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.
AOPA believes that the original FAA interpretation, rendered in response to an inquiry by pilot Richard Theriault, “was not the intent of the requirement of 61.129.” Without this clarification, applicants could have found themselves in the situation of having to acquire additional time to meet the requirements of 14 CFR 61.129 even if they had an instrument rating.
The FAA’s new clarification of that LOI said in part, “We anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under 61.129.”
When it comes to general experience, such as the 250 hours of flight time or the 100 hours of PIC in certain types of aircraft, those are all cumulative.
But for anything that is a "training" requirement, it has to be at least post-private training. So, for example, if you happened to do a 2-hour, 100 nm night dual cross country to satisfy your private night cross country training requirement, it would not count toward the commercial.
The FAA Chief Counsel even went so far as to say recently that even an instrument rating doesn't satisfy the instrument training requirement in 61.129. There's a huge controversy about that one with even AOPA stepping in to get the FAA to change its mind.
Here's the opinion...
http://www.faa.gov/about/office_org/.../Theriault.pdf
a follow-up reaffirming that private experience doesn't count:
http://www.faa.gov/about/office_org/...011/Murphy.pdf
Here's the AOPA dealing with the instrument training issue:
AOPA Online: FAA clarifies commercial-pilot instrument requirements
I don't think that page requires membership but in case it does:
==============================
FAA clarifies commercial-pilot instrument requirements
AOPA urges applicants, CFIs: Log time precisely
By Dan Namowitz
On Dec. 17, the FAA issued a formal response to AOPA’s request for clarification on a letter of interpretation (LOI) that stated that hours used to obtain the instrument rating would not count toward the commercial certificate.
“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 reported Nov. 4 on Hartzell’s letter to the FAA requesting clarification of its LOI.
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.
AOPA believes that the original FAA interpretation, rendered in response to an inquiry by pilot Richard Theriault, “was not the intent of the requirement of 61.129.” Without this clarification, applicants could have found themselves in the situation of having to acquire additional time to meet the requirements of 14 CFR 61.129 even if they had an instrument rating.
The FAA’s new clarification of that LOI said in part, “We anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under 61.129.”
01-14-2011, 04:11 PM
#5
Gets Weekends Off
Thread Starter
Joined APC: Mar 2006
Position: DHC-8 SIC
Posts: 634
Originally Posted by NoyGonnaDoIt
I'm going to have to disagree in part with the other answers.
When it comes to general experience, such as the 250 hours of flight time or the 100 hours of PIC in certain types of aircraft, those are all cumulative.
But for anything that is a "training" requirement, it has to be at least post-private training. So, for example, if you happened to do a 2-hour, 100 nm night dual cross country to satisfy your private night cross country training requirement, it would not count toward the commercial.
The FAA Chief Counsel even went so far as to say recently that even an instrument rating doesn't satisfy the instrument training requirement in 61.129. There's a huge controversy about that one with even AOPA stepping in to get the FAA to change its mind.
Here's the opinion...
http://www.faa.gov/about/office_org/.../Theriault.pdf
a follow-up reaffirming that private experience doesn't count:
http://www.faa.gov/about/office_org/...011/Murphy.pdf
Here's the AOPA dealing with the instrument training issue:
AOPA Online: FAA clarifies commercial-pilot instrument requirements
I don't think that page requires membership but in case it does:
==============================
FAA clarifies commercial-pilot instrument requirements
AOPA urges applicants, CFIs: Log time precisely
By Dan Namowitz
On Dec. 17, the FAA issued a formal response to AOPA’s request for clarification on a letter of interpretation (LOI) that stated that hours used to obtain the instrument rating would not count toward the commercial certificate.
“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 reported Nov. 4 on Hartzell’s letter to the FAA requesting clarification of its LOI.
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.
AOPA believes that the original FAA interpretation, rendered in response to an inquiry by pilot Richard Theriault, “was not the intent of the requirement of 61.129.” Without this clarification, applicants could have found themselves in the situation of having to acquire additional time to meet the requirements of 14 CFR 61.129 even if they had an instrument rating.
The FAA’s new clarification of that LOI said in part, “We anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under 61.129.”
When it comes to general experience, such as the 250 hours of flight time or the 100 hours of PIC in certain types of aircraft, those are all cumulative.
But for anything that is a "training" requirement, it has to be at least post-private training. So, for example, if you happened to do a 2-hour, 100 nm night dual cross country to satisfy your private night cross country training requirement, it would not count toward the commercial.
The FAA Chief Counsel even went so far as to say recently that even an instrument rating doesn't satisfy the instrument training requirement in 61.129. There's a huge controversy about that one with even AOPA stepping in to get the FAA to change its mind.
Here's the opinion...
http://www.faa.gov/about/office_org/.../Theriault.pdf
a follow-up reaffirming that private experience doesn't count:
http://www.faa.gov/about/office_org/...011/Murphy.pdf
Here's the AOPA dealing with the instrument training issue:
AOPA Online: FAA clarifies commercial-pilot instrument requirements
I don't think that page requires membership but in case it does:
==============================
FAA clarifies commercial-pilot instrument requirements
AOPA urges applicants, CFIs: Log time precisely
By Dan Namowitz
On Dec. 17, the FAA issued a formal response to AOPA’s request for clarification on a letter of interpretation (LOI) that stated that hours used to obtain the instrument rating would not count toward the commercial certificate.
“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 reported Nov. 4 on Hartzell’s letter to the FAA requesting clarification of its LOI.
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.
AOPA believes that the original FAA interpretation, rendered in response to an inquiry by pilot Richard Theriault, “was not the intent of the requirement of 61.129.” Without this clarification, applicants could have found themselves in the situation of having to acquire additional time to meet the requirements of 14 CFR 61.129 even if they had an instrument rating.
The FAA’s new clarification of that LOI said in part, “We anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under 61.129.”
01-14-2011, 05:01 PM
#6
Gets Weekends Off
Joined APC: Nov 2008
Posts: 826
Problem is that there have been a couple weird opinions recently. The basic concept that training on the requirements for a commercial are at least qualitatively different than for the private and have to be done separately makes sense. But it's some of the results.
Like those two opinions. The "clarification" to the AOPA aside, the opinion does say that 10 hours of instrument training give for the commercial certificate (which, remember, doesn't even have to be to a pilot with an instrument rating) isn't already dealt with in the instrument rating requirements. That's a reality disconnect.
And the other one. Well, it does say that you have to already be a private pilot, which pretty much negates the advanced certificates and ratings of those pilots who started real early and began their instrument and commercial training before they were old enough to take their private ride.
You have to wonder whether that situation was even contemplated by the author of the opinion.
Like those two opinions. The "clarification" to the AOPA aside, the opinion does say that 10 hours of instrument training give for the commercial certificate (which, remember, doesn't even have to be to a pilot with an instrument rating) isn't already dealt with in the instrument rating requirements. That's a reality disconnect.
And the other one. Well, it does say that you have to already be a private pilot, which pretty much negates the advanced certificates and ratings of those pilots who started real early and began their instrument and commercial training before they were old enough to take their private ride.
You have to wonder whether that situation was even contemplated by the author of the opinion.
01-15-2011, 07:12 AM
#8
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Joined APC: May 2009
Position: autopilot abuser
Posts: 166
Originally Posted by jonnyjetprop
AOPA is fighting it. The 10 hr instrument time was in the regulation because you can get a commercial ticket without being instrument rated.
The real question should be.... What do they mean by "ADVANCED instrument training".
I know what instrument training is, I have done plenty of it. Why add language to something that is clear. Also keep in mmind that once you are private rated any training after that could be considered training towards a commercial cert.
01-16-2011, 08:22 AM
#10
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Joined APC: Jul 2007
Posts: 1,213
4) 10 hours of PIC time to include
i. 1 cross country flight of not less than 300 n.m...with landings at a minimum of 3 points one of which is a straight-line distance of at least 250 n.m.
ii. 5 hours in night VFR conditions with 10 take offs and landings at an airport with an operating control tower.
I believe this is 10 hours of SOLO time or "performing the duty of PIC" with a qualified instructor on board.
i. 1 cross country flight of not less than 300 n.m...with landings at a minimum of 3 points one of which is a straight-line distance of at least 250 n.m.
ii. 5 hours in night VFR conditions with 10 take offs and landings at an airport with an operating control tower.
I believe this is 10 hours of SOLO time or "performing the duty of PIC" with a qualified instructor on board.
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