Commercial Confusion

[ImABird]

Hi. So I'm basically done with instrument training, but checkride is 38 days away.

In the meantime, I want to start commercial, but there's some confusion in the regs.

It says you need 10 hours instrument under 61.127(b)(1) and 10 hours in a TAA/Complex.

I already have more than 10 hours in a TAA but it was never logged per 61.129 in my logbook.

I also have more than 10 hours instrument but it wasn't logged under 61.127(b)(1) or 61.129 either.

What kind of instrument flying happens in commercial that 10 hours is required? Because I'm pretty sure I already have more than 10 hrs.

If my instructor retroactively logs Training per 61.129 in my previous instrument flights, will there be only 10 hrs required for training which includes 2hrs xc in night and day?

Combined those are 4 hrs, that means the last 6 hrs would be steep turns, slow flight, stalls, emergency descent, chandelles, lazy 8s, 8 on pylons, steep spirals, and accelerated stalls?

And then they ask for 10 hrs solo or with instructor which includes 300nm xc and 5 hrs vfr.

Now I already have 15 hrs night time as PIC.

And the 300nm could I do it now?

The confusion is that it says 10 hrs solo under items listed in 61.127(b)(1)

What does that mean? Am I supposed to do chandelles the whole way in the xc ??

Or is just normal xc? And after the xc which would take 4-5 hours, what do I do for the other 5 hrs? Practice commercial maenuevers on my own?

It's so complicated. And do I need to add 61.129 in my logbook remarks for my night vfr xc flights?

Can someone explain what they did?

 

[dbahn]

Can someone explain what they did?

Yes. I sat down with my instructor and checked that all of the requirements were correctly LOGGED. "Having" hours for any of those requirements means nothing if it isn't logged correctly (i.e "acceptable to the administrator").

 

[midlifeflyer]

What kind of instrument flying happens in commercial that 10 hours is required? Because I'm pretty sure I already have more than 10 hrs.

It’s there because you can get a commercial certificate without an instrument rating. It’s pretty much about the ability to handle inadvertent flight into IMC when you are exercising commercial privileges without an IR. And yes, not automatically counting an instrument rating is absurd. Referencing 61.129 was the Chief Counsel slightly backtracking from a stupider interpretation. No, you don’t have to mention 61.129 for everything else in your logbook.

The rest of the “no double dip” stuff is based on the theory that the knowledge and skill you bring as a commercial applicant is qualitatively higher than as a student pilot. No, you don’t have to do chandelles in your required cross countries. Yes, if you are a private pilot, you can do your 300 nm solo cross country right now.

Really, if you are deciding to go for your commercial, best thing is to do a logbook review with a CFI to determine what’s already been covered and what’s still needed. It’s not quite as complicated as your questions suggest.

 

[Larry in TN]

Two things:

1. You can always go back and add additional details of your flights to your logbook as long as the additional details are accurate.

2. While working on your CPL, it's a good time to work on understanding of regulations. Even more so if you plan to continue your training as a CFI. Many private pilots are weak in reading and understanding the regulations but a commercial pilot is expected to be able to read and understand the regulations to a high level. Consider it part of your CPL training.

Generally, pilots often bring assumptions into their reading of the regulations that lead to improper conclusions. The reg means exactly what it says and you need to condition the headings under which the specific regulation is listed. There are also legal interpretations of many of the regulations that give you more context and, sometimes, show a conclusion that you may not have reached from just the reading of that regulation.

One recommendation is to look that the threads on forums, such as this, that are discussing regulations and do your own research to determine the answer. Never just accept what another pilot says (including me).

 

[GeorgeC]

Have you considered bowling?

 

[EdFred]

Re-read 61.129 and make sure to separate the requirements of (1) (2) (3) and (4) when checking your boxes.

 

[eman1200]

....No, you don’t have to do chandelles in your required cross countries....

check that, I think you actually DO have to do chandelles your entire cross country. truth.

 

[EdFred]

check that, I think you actually DO have to do chandelles your entire cross country. truth.

Only 1/3 of it needs to be chandelles. The other 2/3 of the XC needs to be split between 8's on pylons and steep turns.

 

[dbahn]

check that, I think you actually DO have to do chandelles your entire cross country. truth.

Worse yet, they have to be done perpendicular to your course or you won't get to your destination.

 

[iamtheari]

check that, I think you actually DO have to do chandelles your entire cross country. truth.

It doesn't have to be Chandelles and, in fact, I don't recommend them at all. It is very hard to make 300 nm of headway doing chandelles, except in the windiest of conditions aloft. I recommend Lazy Eights. Pick a long, straight road, like I-20 between KMEI and KGGG, and fly Lazy Eights back and forth over it until you can do an emergency spiral descent into the landing pattern. (You should, obviously, use a series of Chandelles to climb out of the pattern at your starting point.)

 

[iamtheari]

In fairness to the OP, a serious response isn't out of order...

Hi. So I'm basically done with instrument training, but checkride is 38 days away.

Congratulations. The instrument rating was the one that I think I worked at the hardest. By comparison, CPL-ASEL was fun although it was hard to get instructors to work consistently with me toward it.

In the meantime, I want to start commercial, but there's some confusion in the regs.

I almost think they did that on purpose. You'll have to be able to read, understand, and explain the regulations better as a commercial pilot than you do as a private pilot, so they created some confusion just to keep applicants on their toes. You should be able to work your way through the actual requirements as long as you read them without preconceived notions of what you think would make sense.

It says you need 10 hours instrument under 61.127(b)(1) and 10 hours in a TAA/Complex.

I already have more than 10 hours in a TAA but it was never logged per 61.129 in my logbook.

Can you document that the plane was a TAA? This is where I think they messed up a bit, because you can tell from the ICAO type code whether a plane is complex or not but you need more information about how the specific tail number was equipped on that day to know if it was a TAA.

I also have more than 10 hours instrument but it wasn't logged under 61.127(b)(1) or 61.129 either.

Read the numerous threads here about this subject. @midlifeflyer tends to answer all those threads very informatively, although he isn't alone.

What kind of instrument flying happens in commercial that 10 hours is required? Because I'm pretty sure I already have more than 10 hrs.

I think the real-world difference is that you can fly IFR with an instrument rating, but if the conditions are too bad for IFR or you don't have the rating, you can fly AFR (Alaska Flight Rules).

If my instructor retroactively logs Training per 61.129 in my previous instrument flights, will there be only 10 hrs required for training which includes 2hrs xc in night and day?

Combined those are 4 hrs, that means the last 6 hrs would be steep turns, slow flight, stalls, emergency descent, chandelles, lazy 8s, 8 on pylons, steep spirals, and accelerated stalls?

Get the ACS out and you'll find that the check ride covers a lot more than the maneuvers. The entire 20+ hours of training should include working toward perfection in every part of flying. When I did my commercial check ride, the examiner had just one piece of harsh criticism about my flying, and it was how I entered the pattern at the airport I diverted to when our cross-country went awry. The certificate is a higher standard of flying, so every time you fly (with or without an instructor), you should be working toward that higher standard.

And then they ask for 10 hrs solo or with instructor which includes 300nm xc and 5 hrs vfr.

Don't get tripped up about the instructor portion of the solo hours. There are plenty of threads on that subject, as well. If you are getting your initial commercial certificate with a rating for ASEL, there is basically no reason to meet these requirements in any way but solo flight.

Now I already have 15 hrs night time as PIC.

What night flying requirements do you want to meet with 15 hours of night PIC time?

And the 300nm could I do it now?

Yes. But don't mess it up. This was one of the last requirements I met for my commercial certificate because most of my cross-country trips were a lot more than 300 nm, but either with a passenger or without enough landings along the way to qualify. (When I fly solo, I don't stop all that often.)

The confusion is that it says 10 hrs solo under items listed in 61.127(b)(1)

What does that mean? Am I supposed to do chandelles the whole way in the xc ??

Or is just normal xc? And after the xc which would take 4-5 hours, what do I do for the other 5 hrs? Practice commercial maenuevers on my own?

You don't have to do any of the maneuvers the entire way, you just have to practice the relevant parts of 61.127(b)(1). For example, (vii) Navigation. Similarly, you also don't have to do the entire trip in (viii) Slow flight and stalls or (ii) Preflight procedures. This is a badly worded regulation because it is indeed confusing to say "Ten hours of solo flight time ... on the areas of operation listed under section 61.127(b)(1)." I haven't heard of an examiner refusing to conduct a check ride because you didn't log precisely which 61.127(b)(1) areas of operation you practiced in your solo hours.

It's so complicated. And do I need to add 61.129 in my logbook remarks for my night vfr xc flights?

As long as they were logged as night VFR and otherwise meet the requirements, you should be fine.

Can someone explain what they did?

What I did was just fly a bunch and accidentally cross most of the requirements off the list along the way. My 300 nm cross country was actually 730 nm with the longest leg being 96 and the shortest being 21, performed in a J-3 Cub where the only navigational equipment I used that wasn't available when the plane was built turned out to be a magenta highlighter. The purpose of that flight was actually to visit all the far-away grass strips in my state to earn the "free" jacket you get when you have landed at every public airport in the state. When I showed up to the commercial ASEL check ride, I had over 500 hours total time, 500 cross-country, 500 PIC, 40 night, 90 dual, etc. This came from a variety of travel, fly-ins, Pilots n Paws rescues, and just going out to practice my short-field tailwheel landings.

Other than flying with an instructor to learn and refine the maneuvers, the only flights that I went on specifically to qualify for the commercial were a 2-hour out-and-back night cross-country lesson and a 3-hour cross-country to beat up the pattern at the nearest airport whose tower stayed open late enough to get in those 10 landings and takeoffs. (As with the cross-country requirement, I didn't meet this one in my regular flying because my night operations at towered airports were almost always a single landing when I arrived on a trip, and then I'd fly home with a daytime takeoff. So I went out and put in a single line in my logbook for this one.)

 

[ImABird]

It doesn't have to be Chandelles and, in fact, I don't recommend them at all. It is very hard to make 300 nm of headway doing chandelles, except in the windiest of conditions aloft. I recommend Lazy Eights. Pick a long, straight road, like I-20 between KMEI and KGGG, and fly Lazy Eights back and forth over it until you can do an emergency spiral descent into the landing pattern. (You should, obviously, use a series of Chandelles to climb out of the pattern at your starting point.)

I hope everyone realizes I was being sarcastic and sort of eliciting this response

 

[Aviatorbrew]

You can the commercial requirements anytime you want.

 

[ImABird]

In fairness to the OP, a serious response isn't out of order...



Congratulations. The instrument rating was the one that I think I worked at the hardest. By comparison, CPL-ASEL was fun although it was hard to get instructors to work consistently with me toward it.



I almost think they did that on purpose. You'll have to be able to read, understand, and explain the regulations better as a commercial pilot than you do as a private pilot, so they created some confusion just to keep applicants on their toes. You should be able to work your way through the actual requirements as long as you read them without preconceived notions of what you think would make sense.


Can you document that the plane was a TAA? This is where I think they messed up a bit, because you can tell from the ICAO type code whether a plane is complex or not but you need more information about how the specific tail number was equipped on that day to know if it was a TAA.


Read the numerous threads here about this subject. @midlifeflyer tends to answer all those threads very informatively, although he isn't alone.


I think the real-world difference is that you can fly IFR with an instrument rating, but if the conditions are too bad for IFR or you don't have the rating, you can fly AFR (Alaska Flight Rules).


Get the ACS out and you'll find that the check ride covers a lot more than the maneuvers. The entire 20+ hours of training should include working toward perfection in every part of flying. When I did my commercial check ride, the examiner had just one piece of harsh criticism about my flying, and it was how I entered the pattern at the airport I diverted to when our cross-country went awry. The certificate is a higher standard of flying, so every time you fly (with or without an instructor), you should be working toward that higher standard.


Don't get tripped up about the instructor portion of the solo hours. There are plenty of threads on that subject, as well. If you are getting your initial commercial certificate with a rating for ASEL, there is basically no reason to meet these requirements in any way but solo flight.


What night flying requirements do you want to meet with 15 hours of night PIC time?

Yes. But don't mess it up. This was one of the last requirements I met for my commercial certificate because most of my cross-country trips were a lot more than 300 nm, but either with a passenger or without enough landings along the way to qualify. (When I fly solo, I don't stop all that often.)

You don't have to do any of the maneuvers the entire way, you just have to practice the relevant parts of 61.127(b)(1). For example, (vii) Navigation. Similarly, you also don't have to do the entire trip in (viii) Slow flight and stalls or (ii) Preflight procedures. This is a badly worded regulation because it is indeed confusing to say "Ten hours of solo flight time ... on the areas of operation listed under section 61.127(b)(1)." I haven't heard of an examiner refusing to conduct a check ride because you didn't log precisely which 61.127(b)(1) areas of operation you practiced in your solo hours.

As long as they were logged as night VFR and otherwise meet the requirements, you should be fine.

What I did was just fly a bunch and accidentally cross most of the requirements off the list along the way. My 300 nm cross country was actually 730 nm with the longest leg being 96 and the shortest being 21, performed in a J-3 Cub where the only navigational equipment I used that wasn't available when the plane was built turned out to be a magenta highlighter. The purpose of that flight was actually to visit all the far-away grass strips in my state to earn the "free" jacket you get when you have landed at every public airport in the state. When I showed up to the commercial ASEL check ride, I had over 500 hours total time, 500 cross-country, 500 PIC, 40 night, 90 dual, etc. This came from a variety of travel, fly-ins, Pilots n Paws rescues, and just going out to practice my short-field tailwheel landings.

Other than flying with an instructor to learn and refine the maneuvers, the only flights that I went on specifically to qualify for the commercial were a 2-hour out-and-back night cross-country lesson and a 3-hour cross-country to beat up the pattern at the nearest airport whose tower stayed open late enough to get in those 10 landings and takeoffs. (As with the cross-country requirement, I didn't meet this one in my regular flying because my night operations at towered airports were almost always a single landing when I arrived on a trip, and then I'd fly home with a daytime takeoff. So I went out and put in a single line in my logbook for this one.)

Ok so what about the 20 hours training in which 10 hours is instrument? You skipped that part?

And what about 10 hours TAA/Complex? Did you skip that or did you do it? Like I said I have 10 hours+ in a G1000 but my instructor said it can only be logged if I fly thr G1000 under items listed id 61.127b1?

I don't want to spend 10 hours doing instrument stuff for commercial if I have done much more complicated IMC stuff in instrument training

Are the 2 xc which are day/night seperate from the 10 hours or can be included as part of the 10 hours in flying complex/TAA? These ones specifically need an instructor on board right?

Im confused about the 5 hours night with 10 takeoffs and landings

I have done like 15 hours night time in the past month cross country and the pattern, solo. Does that count? Or do I need to do a single 5 hour flight solo at night?

 

[Aviatorbrew]

I had to do the night requirement at a towered airport in 3 flights, 5 hrs, ten landings, You could do it in ten flights, if you wanted to, As long as it’s logged, night and towered, I even put in my log notes, commercial requirement

 

[robin ardoin]

I hope everyone realizes I was being sarcastic and sort of eliciting this response

Yup, I figured as much. Yes, you will fit right in here.

 

[ImABird]

Ok I usually comprehend best from examples, detailed examples.

If someone here got a PPL and then the IR, and proceeded to get the commercial, how many total hours did you do for your commercial training with or without instructor, and can you break down what flights those were and for what regulations in 61.129 they were for?

 

[EdFred]

Ok I usually comprehend best from examples, detailed examples.

If someone here got a PPL and then the IR, and proceeded to get the commercial, how many total hours did you do for your commercial training with or without instructor, and can you break down what flights those were and for what regulations in 61.129 they were for?

I went PVT -> IR -> Comm

I had exactly 0 extra hours of instrument training to cover 61.129(a)(3)(i)
DPE counted my IR to cover this. He didn't check the logbook to make sure it was logged with extreme pedantry.

I had just over 10 hours of training to cover 61.129(3)(ii)
We did NOT cover everything under 61.127(b)(1) in the Sierra, we only did (i)(ii)(iv)(ix)(xi)

I owned a Cherokee 180 at the time, so all the other 61.129(a)(3) and training covering 61.127(b)(1) stuff was done in that.

You didn't have to do all the 61.127 stuff in the G1000, you could do it in a combination of TAA/Complex and non-TAA/Complex Your instructor sounds like he went to a puppy mill.

 

[iamtheari]

Ok so what about the 20 hours training in which 10 hours is instrument? You skipped that part?

No. I had instrument training toward my instrument rating that my CFII, the CFI who helped wrap up my commercial, and the DPE who administered my commercial check ride all agreed was qualified and logged to qualify toward the commercial.

And what about 10 hours TAA/Complex? Did you skip that or did you do it? Like I said I have 10 hours+ in a G1000 but my instructor said it can only be logged if I fly thr G1000 under items listed id 61.127b1?

No. The requirement is 10 hours of training a complex, turbine-powered, or technically advanced airplane. I had 41 hours of dual in a PA-28R-180 between my private check ride and my commercial check ride. That doesn't count another 10.1 hours of dual in a mix of other aircraft that qualified, it's just one tail number whose type certificate makes it a complex aircraft. The areas of operation covered in those hours definitely included all of the items under 61.127(b)(1). The question here is what kind of flight training you got in a TAA that doesn't qualify under 61.127(b)(1)?

I don't want to spend 10 hours doing instrument stuff for commercial if I have done much more complicated IMC stuff in instrument training

Talk to your instrument instructor about clarifying his signed entries in your logbook.

Are the 2 xc which are day/night seperate from the 10 hours or can be included as part of the 10 hours in flying complex/TAA? These ones specifically need an instructor on board right?

What does the regulation say?

Im confused about the 5 hours night with 10 takeoffs and landings

What is confusing about 61.129(a)(4)(ii)?

I have done like 15 hours night time in the past month cross country and the pattern, solo. Does that count? Or do I need to do a single 5 hour flight solo at night?

What does the regulation say? How many night takeoffs did you log at airports with operating control towers? How many night landings did you log at airports with operating control towers?

 

[Clip4]

Why students don’t communicate they are progressing to commercial post instrument training and why Part 61 instructors don’t know how to log commercial applicable training without being asked is a bit baffling.

 

[dmspilot]

Still confused after the same author posted this trainwreck.

Commercial sim time requirements are confusing. Can somehow who got a commercial pilot cert with sim time help out?

Ok. I've read all the regs. Let me get this right. So the simulated instrument during private phase doesn't count for instrument time for instrument rating. The Sim time during private doesn't count for instrument rating. Does it count for commercial rating then? It's not very specific in the...

www.pilotsofamerica.com

 

[midlifeflyer]

Ok I usually comprehend best from examples, detailed examples.

If someone here got a PPL and then the IR, and proceeded to get the commercial, how many total hours did you do for your commercial training with or without instructor, and can you break down what flights those were and for what regulations in 61.129 they were for?

If the requirement says “training ” it’s with an instructor. The regs are written in outline form. Remember 5th grade?

 

[ImABird]

No. I had instrument training toward my instrument rating that my CFII, the CFI who helped wrap up my commercial, and the DPE who administered my commercial check ride all agreed was qualified and logged to qualify toward the commercial.

No. The requirement is 10 hours of training a complex, turbine-powered, or technically advanced airplane. I had 41 hours of dual in a PA-28R-180 between my private check ride and my commercial check ride. That doesn't count another 10.1 hours of dual in a mix of other aircraft that qualified, it's just one tail number whose type certificate makes it a complex aircraft. The areas of operation covered in those hours definitely included all of the items under 61.127(b)(1). The question here is what kind of flight training you got in a TAA that doesn't qualify under 61.127(b)(1)?

Talk to your instrument instructor about clarifying his signed entries in your logbook.

What does the regulation say?

What is confusing about 61.129(a)(4)(ii)?

What does the regulation say? How many night takeoffs did you log at airports with operating control towers? How many night landings did you log at airports with operating control towers?

Ok. So one of my instructors today said that for the 10 hours of simulated instrument required for commercial 61.129(a)(3)(i) , that my Instrument training flights do NOT need to be logged and have "training per 61.129(a)(3)(i)" or something like that logged to count for the 10 hours of simulated instrument. The reasoning was that since you can get a commercial pilot certificate WITHOUT being instrument rated, that the 10 hours is ONLY there to make it a step higher than private pilot. I highly doubt an examiner would look or care if my instrument training shows 61.129(a)(3)(i) in the comments. So can anyone confirm this? Despite this, the requirements for 61.129(a)(3)(i) which is the 10 hours of simulated instrument, says that the 10 hours instrument time must be logged per 61.127(b)(1), which really doesn't make much sense here.

I have 10 hours+ of TAA time which I got during instrument training, but again, it wasn't logged per 61.129(a)(3)(ii) or 61.127(b)(1), so now, I need to fly a complex for 10 hours.

Talking to my instructors may prove fruitless. I dont think they will go and retroactively put "training per 61.127(b)(1) or 61.129(a)(3)" in my logbook for my previous Instrument training flights in which I had BOTH simulated/actual instrument AND TAA.

This basically I think forces me to do 10 hours of Complex. So the 10 hours of complex, the 2 XC flights together add to 4 hours, then if I do 6 more hours conservatively, I'll have the training requirements done.

And then there's 10 hours solo only or Dual only. So if I do it solo, at least 5-6 hours will be relegated to the 300nm XC, in which I already have planned to do on May 7th. I already have 5 hours night VFR with the required takeoffs and landings done during my instrument training, so does that count for the full 10 hours solo, if I just go back in the logbook and add "flight per 61.129(a)(4)(i)???

Because with this 300nm cross country which will be 5-6 hours, and my night VFR flights over a month ago, that already places me at 10 hours of Solo flying. The only thing I'm missing is the 300nm XC which I'm doing on May 7.

Also, who is going to check if I flew solo or with a passenger anyway for the 300nm XC? Its not like they can check, and my flight school doesn't really pay attention, remember, or know what the flight is for. I see people here who redid a 300nm+ XC because in the others they took a passenger, like, come on, who would possibly know? Its not like the passenger was flying the plane.


Lastly, can anyone answer if they ever skipped to doing commercial and even commercial ME training while WAITING for an instrument checkride?


DPE availability is garbage, meaning I can't do instrument until June 5, and Commercial until god knows when (which is why against my better judgement, for my commercial, I might use another DPE that I haven't used before, whereas the instrument DPE will be the same person who did my Private).

So has anyone done Commercial and Commercial ME training while waiting on an instrument ride?

I have time to study and prepare for all 3 checkrides and writtens, and prior to each checkride, I would do checkride prep.

 

[MauleSkinner]

Ok. So one of my instructors today said that for the 10 hours of simulated instrument required for commercial 61.129(a)(3)(i) , that my Instrument training flights do NOT need to be logged and have "training per 61.129(a)(3)(i)" or something like that logged to count for the 10 hours of simulated instrument. The reasoning was that since you can get a commercial pilot certificate WITHOUT being instrument rated, that the 10 hours is ONLY there to make it a step higher than private pilot. I highly doubt an examiner would look or care if my instrument training shows 61.129(a)(3)(i) in the comments. So can anyone confirm this?

Did your instructor log “attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems”?

If so, you’re good.

Despite this, the requirements for 61.129(a)(3)(i) which is the 10 hours of simulated instrument, says that the 10 hours instrument time must be logged per 61.127(b)(1), which really doesn't make much sense here.

No, it doesn’t say it “must be logged per 61.127(b)(1).” It says you need the training required in 61.127(b)(1), and that needs to include the 61.129 requirements.

I have 10 hours+ of TAA time which I got during instrument training, but again, it wasn't logged per 61.129(a)(3)(ii) or 61.127(b)(1), so now, I need to fly a complex for 10 hours.

Was it 10 hours of training logged in a TAA? If so, you’re good.

Talking to my instructors may prove fruitless.

Then you need to either find better instructors or quit flying.

… if I just go back in the logbook and add "flight per 61.129(a)(4)(i)???

Just make a list of the flights that show you meet the requirements.

Also, who is going to check if I flew solo or with a passenger anyway for the 300nm XC? Its not like they can check, and my flight school doesn't really pay attention, remember, or know what the flight is for. I see people here who redid a 300nm+ XC because in the others they took a passenger, like, come on, who would possibly know? Its not like the passenger was flying the plane.

Aviation works on the honor system. If you don’t have honor, don’t fly. Solves all of the other issues, too.

 

[midlifeflyer]

Ok. So one of my instructors today said that for the 10 hours of simulated instrument required for commercial 61.129(a)(3)(i) , that my Instrument training flights do NOT need to be logged and have "training per 61.129(a)(3)(i)" or something like that logged to count for the 10 hours of simulated instrument. The reasoning was…

…without reading the two Chief Counsel letters on the subject?

 

[dbahn]

Also, who is going to check if I flew solo or with a passenger anyway for the 300nm XC? Its not like they can check, and my flight school doesn't really pay attention, remember, or know what the flight is for. I see people here who redid a 300nm+ XC because in the others they took a passenger, like, come on, who would possibly know? Its not like the passenger was flying the plane.

"They" don't need to check if there was a passenger. They only need documentation that it was solo, and solo doesn't mean the only pilot in the aircraft.

 

[midlifeflyer]

Ok. So one of my instructors today said that for the 10 hours of simulated instrument required for commercial 61.129(a)(3)(i) , that my Instrument training flights do NOT need to be logged and have "training per 61.129(a)(3)(i)" or something like that logged to count for the 10 hours of simulated instrument. The reasoning was that since you can get a commercial pilot certificate WITHOUT being instrument rated, that the 10 hours is ONLY there to make it a step higher than private pilot. I highly doubt an examiner would look or care if my instrument training shows 61.129(a)(3)(i) in the comments. So can anyone confirm this? Despite this, the requirements for 61.129(a)(3)(i) which is the 10 hours of simulated instrument, says that the 10 hours instrument time must be logged per 61.127(b)(1), which really doesn't make much sense here.

I have 10 hours+ of TAA time which I got during instrument training, but again, it wasn't logged per 61.129(a)(3)(ii) or 61.127(b)(1), so now, I need to fly a complex for 10 hours.

Talking to my instructors may prove fruitless. I dont think they will go and retroactively put "training per 61.127(b)(1) or 61.129(a)(3)" in my logbook for my previous Instrument training flights in which I had BOTH simulated/actual instrument AND TAA.

This basically I think forces me to do 10 hours of Complex. So the 10 hours of complex, the 2 XC flights together add to 4 hours, then if I do 6 more hours conservatively, I'll have the training requirements done.

And then there's 10 hours solo only or Dual only. So if I do it solo, at least 5-6 hours will be relegated to the 300nm XC, in which I already have planned to do on May 7th. I already have 5 hours night VFR with the required takeoffs and landings done during my instrument training, so does that count for the full 10 hours solo, if I just go back in the logbook and add "flight per 61.129(a)(4)(i)???

Because with this 300nm cross country which will be 5-6 hours, and my night VFR flights over a month ago, that already places me at 10 hours of Solo flying. The only thing I'm missing is the 300nm XC which I'm doing on May 7.

Also, who is going to check if I flew solo or with a passenger anyway for the 300nm XC? Its not like they can check, and my flight school doesn't really pay attention, remember, or know what the flight is for. I see people here who redid a 300nm+ XC because in the others they took a passenger, like, come on, who would possibly know? Its not like the passenger was flying the plane.


Lastly, can anyone answer if they ever skipped to doing commercial and even commercial ME training while WAITING for an instrument checkride?


DPE availability is garbage, meaning I can't do instrument until June 5, and Commercial until god knows when (which is why against my better judgement, for my commercial, I might use another DPE that I haven't used before, whereas the instrument DPE will be the same person who did my Private).

So has anyone done Commercial and Commercial ME training while waiting on an instrument ride?

I have time to study and prepare for all 3 checkrides and writtens, and prior to each checkride, I would do checkride prep.

Is it just my imagination or is this starting to sound like trolling?

 

[iamtheari]

Is it just my imagination or is this starting to sound like trolling?

One can hope. Because the alternative is that a person who is trying to become a commercial pilot is unable or unwilling to comprehend regulations, work with other pilots (such as asking a DPE about what he needs in his logbook), or commit to honestly log his time based on what he flew rather than what he wants an examiner to think he flew. I’m sure there are many commercial pilots like that, but we don’t need more.

 

[MauleSkinner]

Is it just my imagination or is this starting to sound like trolling?

I think if it was trolling it wouldn’t be so disorganized.

I’d probably go with willful ignorance.

 

[dbahn]

I think if it was trolling it wouldn’t be so disorganized.

I’d probably go with willful ignorance.

. . . sprinkled with a large dash of wishful thinking - not a particularly good recipe for making a commercial pilot.

 

[EdFred]

Is it just my imagination or is this starting to sound like trolling?

No, just someone who has been been spoon-fed participation trophies via helicopter parents their entire life.

 

[MauleSkinner]

No, just someone who has been been spoon-fed participation trophies via helicopter parents their entire life.

So the problem is he’s going against family and trying to learn fixed wing?

 

[ateamer]

Is it just my imagination or is this starting to sound like trolling?

I believe it. There are some really weak instructors out there.

 

[Larry in TN]

Ok. So one of my instructors today said that for the 10 hours of simulated instrument required for commercial 61.129(a)(3)(i) , that my Instrument training flights do NOT need to be logged and have "training per 61.129(a)(3)(i)" or something like that logged to count for the 10 hours of simulated instrument.

You are reading things into the regulation that aren't there. Nowhere does it say that you must cite the regulation in your log entry. What you must do is LOG the specific training and experience that the regulation requires.

If it says that it must be solo, then you must have logged it as solo, either in a SOLO column or a notation that the flight was conducted solo. If the regulation says you must receive training in XYZ then you need to log DUAL instruction and note the topic(s) that the regulation require. If the requirement is XX hours of a specific type of time then XX hours of that type of flying must be logged.

In short, the logbook entries must document that each regulatory requirement has been met.

 

[midlifeflyer]

I believe it. There are some really weak instructors out there.

The thing about this one is, AFAIK. since it first appeared almost 14 years ago, the requirement "that instrument training used to satisfy the aeronautical experience requirements under §61.129 needs to be clearly documented by the applicant for the commercial pilot certificate," 2010 Hartzell Letter, was well publicized in the DPE community. So we are not necessarily talking about a weak instructor, but one who may not have ever sent a pilot for a commercial checkride based solely on having the rating and doesn't keep up with the requirements.

 

[dbahn]

In short, the logbook entries must document that each regulatory requirement has been met.

That's it. People will often cite the regulation in the notes, which I think can be helpful when an examiner is reviewing the logs (particulary if the entry was made by the CFI) but it's not necessary.

 

[ateamer]

The thing about this one is, AFAIK. since it first appeared almost 14 years ago, the requirement "that instrument training used to satisfy the aeronautical experience requirements under §61.129 needs to be clearly documented by the applicant for the commercial pilot certificate," 2010 Hartzell Letter, was well publicized in the DPE community. So we are not necessarily talking about a weak instructor, but one who may not have ever sent a pilot for a commercial checkride based solely on having the rating and doesn't keep up with the requirements.

I guess I was lucky to have had a very thorough CFI for my CFI training, because we went over Theriault and Hartzell, and a number of scenarios for eligibility. He was a 20+ year fulltime CFI, loved his job and aside from his family his life was pretty much dedicated to training.

 

[midlifeflyer]

I guess I was lucky to have had a very thorough CFI for my CFI training, because we went over Theriault and Hartzell, and a number of scenarios for eligibility. He was a 20+ year fulltime CFI, loved his job and aside from his family his life was pretty much dedicated to training.

You were lucky for more reasons than understanding Theriault and Hartzell.

 

[ateamer]

You were lucky for more reasons than understanding Theriault and Hartzell.

Absolutely. The training was beyond thorough and exacting. The checkride, including the oral, was fairly easy - definitely easier than the training.

 

[MauleSkinner]

The thing about this one is, AFAIK. since it first appeared almost 14 years ago, the requirement "that instrument training used to satisfy the aeronautical experience requirements under §61.129 needs to be clearly documented by the applicant for the commercial pilot certificate," 2010 Hartzell Letter, was well publicized in the DPE community. So we are not necessarily talking about a weak instructor, but one who may not have ever sent a pilot for a commercial checkride based solely on having the rating and doesn't keep up with the requirements.

14 years, so roughly 4 “generations” of instructors who should be thoroughly versed in the requirements by virtue of presenting logbooks for a commercial checkride and taking CFI checkrides from DPEs who are well versed in the requirements.