pilotmike1

All - Given the new rules in 61.129 regarding Technologically Advanced Aircraft ("TAA") counting for the 10 hrs of Complex Endorsement of the Commercial Pilot training, has anyone encountered this scenario:

Pilot has 100 hours of training in a Cirrus SR20 (TAA) for his private pilot certificate (checkride completed in Cirrus, proficient in TAA, though no endorsement on logbook). His next 150 hours (including Instrument rating) were in a Cessna 172 (Not a TAA). Does the 100 hours in the Cirrus (TAA) count towards the commercial training? The detail is in whether you interpret 61.129(a)(3)(ii) as requiring the time in the TAA to include commercial maneuvers, or just training on how to fly the TAA. Does this pilot need to go do 10 hours of commercial maneuvers in a TAA, or can he do them in a c172 (non TAA, non complex)
Thank you



Regs below:


https://www.law.cornell.edu/cfr/text/14/61.129

TiredSoul

I’m going to go with no.

Other example:

Private pilot student, during the XC training phase can I already do the 2 hr day and 2hr night requirement for the CPL?

Answer is No as the individual has no pilot certificate yet.

So anything flown after the Private and logged as training for the CPL would count although most DPE’s would count it anyway.

So without looking up any references or letters of interpretation I’m going with no.

Xdashdriver

The closest I could get to your question in a letter of interpretation was this:

https://www.faa.gov/about/office_org...rpretation.pdf

Relevant extract:

"The third question in your inquiry asks whether an applicant for a Commercial Pilot Certificate can use the experience from a night cross-country flight that meets the requirements for a Commercial Pilot Certificate under 61.129(c), while the individual was training for a Private Pilot Certificate, to satisfy the requirement for night cross-country flight for a Commercial Pilot Certificate? The answer is no. Regardless of whether the applicant previously completed a night cross-country flight that meets the requirements under 61.129(c)(3)(iii), the applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see 61.127), not while training for a different certificate."

While not specifically addressing your question, the FAA's position seems to be "no double dipping on the training hours"

TiredSoul

That’s the one, thank you

flat_land_flyer

Two months later this pops up. What do you all make of this legal interp?

While holding an instrument rating does not meet requirements of 61.129.... Commercial applicants who hold an instrument rating will meet some, most if not all that is required under 61.129.



https://www.faa.gov/about/office_org...rpretation.pdf