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Old 10-03-2018, 08:35 AM   #1  
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Default Commercial Pilot Training

(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) 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 single engine airplane;

(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

(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 nautical miles from the original point of departure;

(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 nautical miles from the original point of departure; and

(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

(4) Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under §61.127(b)(1) that include—

(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 in the traffic pattern) at an airport with an operating control tower.



As a private pilot who is currently building cross country hours for the instrument rating. I'm wondering if I should go ahead and try to meet the requirements for a commercial rating as well, at least the number 4. So if I were to log a 300 nm solo cross country with one leg of 250 nm and 3 stops. Will that satisfy it for Part 4 of the regulations here or I have to do that afterwards as part of commercial training? Same for Part 4b. If I do a night cross country solo and 10 take offs and landings in the pattern (say 2 on each leg at each airport about 50nm away), will that count?

Finally regarding number 3. Wouldn't I satisfy 3i as part of instrument rating training or that'll have to be done separately after commercial, and what about 3ii and 3iii, do those have to be with an instructor as well for special commercial training. I feel part 3 is strict commercial training, but I'd like to at least take care of section 4 requirements while building cross country for the instrument rating
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Old 10-03-2018, 10:14 AM   #2  
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As a private pilot who is currently building cross country hours for the instrument rating. I'm wondering if I should go ahead and try to meet the requirements for a commercial rating as well, at least the number 4. So if I were to log a 300 nm solo cross country with one leg of 250 nm and 3 stops. Will that satisfy it for Part 4 of the regulations here or I have to do that afterwards as part of commercial training? Same for Part 4b. If I do a night cross country solo and 10 take offs and landings in the pattern (say 2 on each leg at each airport about 50nm away), will that count?
You're reading the regulation out of context.

You can fly the cross country on your own and it will credit toward your commercial certification. There is no need to do your night landings as part of a cross country flight; you can do them locally, if you wish.

The long cross country referenced in 14 CFR 61.129(a)(4)(i) need not be done at night.

The night landings in 61.129(a)(4)(ii) need not be done on a cross country flight.

https://www.ecfr.gov/cgi-bin/text-id..._1129&rgn=div8

This flight time, the 10 hours of 61.129(a)(4)(i), can be done solo, or with an instructor, but not a combination of both. The FAA Chief Legal Counsel stated in 2016 that the regulation doesn't permit doing part of those 10 hours as instruction received and the other part solo; it's either one or the other, but not both: https://www.faa.gov/about/office_org...rpretation.pdf

The FAA has held in legal interpretations that the use of the language in the regulation, where it references other regulation, must be taken into account. In this case, 61.129(a)(4) allows that the cross country and night landings may be done with an instructor or solo, but also notes that instruction received must be done to cover the requirements of 61.127(b)(1). 61.127(b)(1) regards the areas of operation required for training toward the commercial certificate. The use of this language means that the night landings and cross country should be associated with training toward the commercial certificate (as opposed to having done a long solo flight as a student pilot, for example). It also means that if the night landings had been conducted during preparation for the private, they would not count; this requirement applies specifically to preparation for the commercial.

https://www.ecfr.gov/cgi-bin/text-id..._1127&rgn=div8

Because you can do the cross country and the landings solo or with an instructor, you can do your cross country and landings now, and it will be credited toward the commercial certificate. If you had done this with an instructor in prior training, such as toward your private, it would not count toward the commercial, as it must be on the areas of operation in 61.127(b)(1), meaning it must be done in commercial training. In this case, you're asking about doing it solo, as a private pilot: you can go do the landings now if you like, and the cross country. You do not need to do the night landings as part of a cross country flight, and you do not need to do the cross country flight at night.

The intent of the regulation is that your long cross country flight and your night landings are done in conjunction with your training for the commercial pilot certificate, that those requirements are met while you're receiving your instruction, and training to a higher level of certification.

If you choose to do the cross country instruction, you can combine it with instrument training under the hood. The FAA chief legal counsel has noted that this is acceptable. The following legal interpretation applies, though the specific question asked regards helicopters. https://www.faa.gov/about/office_org...rpretation.pdf

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Originally Posted by pilotrs View Post
Finally regarding number 3. Wouldn't I satisfy 3i as part of instrument rating training or that'll have to be done separately after commercial, and what about 3ii and 3iii, do those have to be with an instructor as well for special commercial training. I feel part 3 is strict commercial training, but I'd like to at least take care of section 4 requirements while building cross country for the instrument rating
Again, if you read the language of the regulation, the requirements of 61.129(a)(3)(i) are specific to the areas of operation for the commercial pilot certificate. Your training toward the private won't count: training under a hood for flight by reference to instruments as part of your private certificate, cannot be credited toward the requirements for the commercial.

That said, if you're doing your instrument rating and undergoing the necessary instruction, it will count toward 61.129(a)(3)(i). You must receive instrument training specific to 61.127(a)(1), which is commercial training, and includes performance maneuvers, slow flight and stalls, emergency operations, etc.

It's important to understand how this applies; you can get a commercial pilot certificate without an instrument rating; the instrument training requirements of the commercial pilot certificate recognize that and set minimum instrument instruction requirements that must be met by someone who does not hold an instrument rating.

Finally, while not specific to your question, the latter part of the following legal interpretation applies, because it addresses the issue of training received prior to commercial training. It points to the need to have training applicable specifically to the level of certification you're seeking. Simply put, per the prior example, training received toward the private wouldn't count toward the commercial; training for the commercial must be specific to the commercial: when you see language in the regulation which references another regulation (in this case, 61.129 referencing 61.127), it should be read that the training and time logged must be specific and applicable to that other regulation (eg, commercial).

If you're working on your instrument rating and hammering out the hours toward that, which is leading into your commercial, and your training has included the areas of operation in 127(a)(1), then you'll have met the requirements of 61.129(a)(3)(i). https://www.faa.gov/about/office_org...rpretation.pdf
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Old 10-03-2018, 10:17 AM   #3  
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IIRC, all should overlap.

You can get a CPL without an instrument rating, so the minimum instrument requirements for CPL are geared towards a non-IR pilot who needs some instrument training just in case he inadvertently goes VFR-into-IMC.

That's for part 61, unless otherwise specified, for the most part any training done at a given certificate level counts towards aeronautical experience requirements for the next certificate. As a private pilot, you meet the "prerequisite" to perform CPL training.

That's for training, ie specified activities with or without a CFI. For flight time, that can be done at any time. Ie a PPL with 1000 hours will not need to complete an additional 1500 hours to get an ATP after he gets his CPL. He can get the 1500 at any time student, PPL or CPL (although it's not really the intent that you solo for 1500 hours as a student pilot, and the FSDO would have words with the CFI in that case).

If you do CPL under part 41, you'll probably have to the syllabus in order although you might be able to get partial credit for some previous flight time.
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