Part 61 Instrument to Part 61 Commercial

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HerrGruyere

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Oh boy - this dreaded topic.

I've been researching online about this and I just want to set the record straight:

I know for Part 61 Instrument, you need a prerequisite of 50hrs PIC XC time. From there, you need an additional 40 of instruction (of which 20 can be done in a sim) plus ground school.

For Part 61 Commercial, I know you need 250 hours of which 100 is in a plane. The extra 100 hours is more XC time and stuff in complex planes.

What I need is a basic breakdown, because the legalese of the regs is giving me a headache.

Also, could all of the time I logged thus far count toward my 250 hours? Or would that only be solo time? Because if it's all the time, then I would only need the endorsement for the high performance/complex plane and some extra XC time as well as time to learn new maneuvers. The way I see it is I'll have about 45 or 50 hours total in my book when I'm done with my PPL. I'll have 100 total with the added XC time. After instrument, I'll have about 150. Would that mean I'd only need another 100 hours to be eligible for my commercial?

I just want to know, because I was just doing some random planning and thinking about my path and wanted to make sure I had everything in check. It would help me decide on whether or not to opt for 141 instruction on the instrument and then switch back to 61 for the commercial. However, I think doing that would make it even more expensive.

I'd prefer to stick with Part 61 because it's a better pace and not so structured.

Does anyone happen to have a small breakdown or maybe know it off the tops of your heads? I feel bad for asking this, since I know this topic has been beaten to death.
 
You are incorrect. The instrument rating takes 40 hours of INSTRUMENT TIME but it is not necessarily all instruction. Only 15 hours must be instrument instruction.

Any time you have now that meets the requirements of the rating/certificate you are applying for counts. All the time you spent under the hood for whatever reason counts for the 40 hours.

61.129 spells out the time for the commercial
61.109 spells out the time for the instrument.

Yes some of these hours can overlap. Some of which can overlap even with your private.

The caveats:

Your flight by instruments you had for the private doesn't count as instrument training for the later ratings.

The stuff in the commercial that says SOLO means SOLO (or with a dummy in the right seat while you play PIC).
 
flyingron said:
Your flight by instruments you had for the private doesn't count as instrument training for the later ratings.
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Emphasis added. It does not count for the 15 hours of instrument training for the IR, ibut it does count for the 40 hours of total instrument time for the IR.

The stuff in the commercial that says SOLO means SOLO (or with a dummy in the right seat while you play PIC).
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If by "dummy" you mean Mortimer Snerd, that would be true. If by "dummy" you mean a live human who either knows or does nothing, it would not.
 
HerrGruyere said:
I know for Part 61 Instrument, you need a prerequisite of 50hrs PIC XC time. From there, you need an additional 40 of instruction (of which 20 can be done in a sim) plus ground school.
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There is no "prerequisite" of XC PIC time before starting your IR training under Part 61, but you must have it done before you take the IR practical test. You can, if you and your instructor organize it properly, get many or even most of that XC PIC time as part of your IR training. Also, as FRon noted, you only need 15 hours of instrument training for the IR, although few get it with that little. The 40 hours is total instrument time, which includes the instrument time you got preparing for Private, hood time you get with a safety pilot, and the instrument training you get with an instrument instructor.

For Part 61 Commercial, I know you need 250 hours of which 100 is in a plane.
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You only need 50 hours in airplanes -- the 100 is in "powered aircraft," which would include helicopters, gyroplanes, powered parachutes, and airships (and powered-lift aircraft if the Bell 609 ever gets certified) as well as airplanes. The other 150 could include gliders, balloons, and any other nonpowered aircraft. However, the number of folks who mix and match like that is pretty small.

The extra 100 hours is more XC time and stuff in complex planes.
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There is nothing in 61.129 which says anything like that.

What I need is a basic breakdown, because the legalese of the regs is giving me a headache.
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OK -- how about this (assuming you only fly airplanes)?

  • 250 hours total time (of which 50 hours may be instruction received in a sim)
  • 100 hours PIC time, inclouding 50 hours XC PIC time
  • 20 hours of post-Private training, including:
    • 10 hours in a complex airplane
    • Two XC's (one day, one night) of at least 2 hours each
    • 10 hours of instrument training (can be from IR training)
    • 3 hours of test prep
    • (the above can be combined, but must add up to at least 20 total hours of post-Private training received)
  • 10 hours of solo (or "simualted solo" with an instructor -- not including the training time above) including:
    • One log XC of at least 300 nm with one landing at least 250nm from the starting point
    • 5 hours of night, including 10 takeoffs and landings at a towered airport
Also, could all of the time I logged thus far count toward my 250 hours?
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Assuming it's all in airplanes, yes.

Because if it's all the time, then I would only need the endorsement for the high performance/complex plane and some extra XC time as well as time to learn new maneuvers.
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Because part of the Commercial practical test must be in a complex plane, you will need the complex endorsement. However, unless you choose to use a plane which is also high performance, you will not need that endorsement, because there is no requirement for any time in a high performance airplane for the CP.

The way I see it is I'll have about 45 or 50 hours total in my book when I'm done with my PPL. I'll have 100 total with the added XC time. After instrument, I'll have about 150. Would that mean I'd only need another 100 hours to be eligible for my commercial?
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More or less so.
 
Ron Levy said:
Because part of the Commercial practical test must be in a complex plane, you will need the complex endorsement. However, unless you choose to use a plane which is also high performance, you will not need that endorsement, because there is no requirement for any time in a high performance airplane for the CP.
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Ron, do you think this is a regulatory oversight? I do.
 
Jaybird180 said:
Ron, do you think this is a regulatory oversight? I do.
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I have no idea. Personally, given the paucity of retractable singles in operations requiring a CP-ASEL, I think the complex requirement is unnecessary and inappropriate, and supported the regulatory change a couple of years ago to remove it.
 
Thanks for the responses, everyone! I just needed a little help spelling it out.

As for "instrument time," does that mean I am just flying under the hood in VMC with a safety pilot on board? I wouldn't think that I would be flying in IMC without my rating.

And, theoretically, the 50 hours XC PIC time could be done under the hood while receiving instruction for my instrument rating so that it coincides with the 40 hours instrument time?
 
HerrGruyere said:
As for "instrument time," does that mean I am just flying under the hood in VMC with a safety pilot on board?
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That includes what you said, as well as time under the hood getting training from an instructor, and any actual instrument time (i.e., in the weather without a hood) with an instructor or other person qualified to act as PIC under those conditions.

I wouldn't think that I would be flying in IMC without my rating.
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You could certainly be doing that as part of your IR training with an instrument instructor. I try to take my instrument trainees into the weather if it all possible.

And, theoretically, the 50 hours XC PIC time could be done under the hood while receiving instruction for my instrument rating so that it coincides with the 40 hours instrument time?
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Theoretically, yes, it could.
 
HerrGruyere said:
As for "instrument time," does that mean I am just flying under the hood in VMC with a safety pilot on board? I wouldn't think that I would be flying in IMC without my rating.
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Flying in actual IMC was by far my favorite part of IFR training. I even did my long cross country in and out of IMC the whole time. It has really made me more confident in my abilities to deal with real weather once I do my checkride (which will be very soon).

Of course, understand that you need to have an instructor with you, or an instrument-rated safety pilot, to do that. But it's my opinion that you should DEFINITELY try to get a good bit of IMC time during your training.

And, theoretically, the 50 hours XC PIC time could be done under the hood while receiving instruction for my instrument rating so that it coincides with the 40 hours instrument time?
Click to expand...

I had about 35 hours of PIC XC when I started the IR. I did a little VFR XC flying on the side during training, but also did enough XC flying under the hood to meet the 50 hour requirement while also accumulating the 40 hours of instrument time and the 15 hours of instrument instruction.
 
Ron Levy said:
There is no "prerequisite" of XC PIC time before starting your IR training under Part 61, but you must have it done before you take the IR practical test. You can, if you and your instructor organize it properly, get many or even most of that XC PIC time as part of your IR training. Also, as FRon noted, you only need 15 hours of instrument training for the IR, although few get it with that little. The 40 hours is total instrument time, which includes the instrument time you got preparing for Private, hood time you get with a safety pilot, and the instrument training you get with an instrument instructor.

You only need 50 hours in airplanes -- the 100 is in "powered aircraft," which would include helicopters, gyroplanes, powered parachutes, and airships (and powered-lift aircraft if the Bell 609 ever gets certified) as well as airplanes. The other 150 could include gliders, balloons, and any other nonpowered aircraft. However, the number of folks who mix and match like that is pretty small.

There is nothing in 61.129 which says anything like that.



OK -- how about this (assuming you only fly airplanes)?

  • 250 hours total time (of which 50 hours may be instruction received in a sim)
  • 100 hours PIC time, inclouding 50 hours XC PIC time
  • 20 hours of post-Private training, including:
    • 10 hours in a complex airplane
    • Two XC's (one day, one night) of at least 2 hours each
    • 10 hours of instrument training (can be from IR training)
    • 3 hours of test prep
    • (the above can be combined, but must add up to at least 20 total hours of post-Private training received)
  • 10 hours of solo (or "simualted solo" with an instructor -- not including the training time above) including:
    • One log XC of at least 300 nm with one landing at least 250nm from the starting point
    • 5 hours of night, including 10 takeoffs and landings at a towered airport
Assuming it's all in airplanes, yes.

Because part of the Commercial practical test must be in a complex plane, you will need the complex endorsement. However, unless you choose to use a plane which is also high performance, you will not need that endorsement, because there is no requirement for any time in a high performance airplane for the CP.

More or less so.
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What am I missing? 61.107 calls for three hours of flight training in control of the aircraft by instrument reference...how does that become instrument flight time?

Bob Gardner
 
bobmrg said:
What am I missing? 61.107 calls for three hours of flight training in control of the aircraft by instrument reference...how does that become instrument flight time?

Bob Gardner
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I can understand it not counting as the 15 hours of instrument instruction, but assuming you flew under the hood for those 3 hours, how else would you log that time? It's simulated instrument time... and while it's not PIC, why wouldn't it count towards your 40 hours of instrument time?

From 61.65: "Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged: ... (2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section..."

As far as the paragraph (c) requirements go, I wouldn't think each hour would have to cover ALL of those requirements. Certainly the three hours received from your primary instruction covers at the minimum number 4: "(4) Flight by reference to instruments;"
 
bobmrg said:
What am I missing? 61.107 calls for three hours of flight training in control of the aircraft by instrument reference...how does that become instrument flight time?

Bob Gardner
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Because it meets the requirement in 61.51(g)(1) to be logged as instrument flight time. What it does not qualify as is instrument flight training.
 
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Ron Levy said:
  • 250 hours total time (of which 50 hours may be instruction received in a sim)
  • 100 hours PIC time, inclouding 50 hours XC PIC time
  • 20 hours of post-Private training, including:
    • 10 hours in a complex airplane
    • Two XC's (one day, one night) of at least 2 hours each
    • 10 hours of instrument training (can be from IR training)
    • 3 hours of test prep
    • (the above can be combined, but must add up to at least 20 total hours of post-Private training received)
  • 10 hours of solo (or "simulated solo" with an instructor -- not including the training time above) including:
    • One log XC of at least 300 nm with one landing at least 250nm from the starting point
    • 5 hours of night, including 10 takeoffs and landings at a towered airport
Click to expand...
Please correct me if I am wrong. I am about ready to take my IR ride and would like to take my commercial ride soon after.

A week ago last Sat, I took my CFI to a fly-in in my Arrow and then on the way back had him introduce me to the commercial manuevers. One hour of dual. I assume that would count toward the test prep?

I have plenty of time, including the post-private dual, complex dual, night, and the instrument time.

I have my long IR xc for the two hour day. I have night xc but not with an instructor and not quite two hours.

So I need a two hour night xc with instructor? Can that count toward test prep?

I don't have a long xc of required length.

So it seems that, just as far as hours are concerned, I only need one dual night xc and one long solo xc?

Is there a time limit on the test prep?

Thanks.
 
alfadog said:
Please correct me if I am wrong. I am about ready to take my IR ride and would like to take my commercial ride soon after.

A week ago last Sat, I took my CFI to a fly-in in my Arrow and then on the way back had him introduce me to the commercial manuevers. One hour of dual. I assume that would count toward the test prep?
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For the Commercial, as long as you take that ride within the next two calendar months.

I have my long IR xc for the two hour day.
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OK

I have night xc but not with an instructor and not quite two hours.
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if it wasn't with an instructor, it's not training, so...

So I need a two hour night xc with instructor?
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Yes.

Can that count toward test prep?
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as long as it includes training in the Areas and Tasks on the practical test. However, if I'm your instructor, you're still going to have to do at least one satisfactory practice practical test with me before I endorse you for the ride, and that won't be happening at night.

I don't have a long xc of required length.
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Remember that one must be solo, I.e., you are the sole living human occupant.

So it seems that, just as far as hours are concerned, I only need one dual night xc and one long solo xc?
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See what I wrote above.

Is there a time limit on the test prep?
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Yes -- two calendar months.

All that said, if you've only been "introduced" to the Commercial maneuvers, you're almost certainly a lot more than two training hours from the practical test.
 
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Ron Levy said:
Because it meets the requirement in 61.51(g)(1) to be logged as instrument flight time. What it does not qualify as is instrument flight training.
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Tortured reasoning, IMHO, but I see where you are coming from. While I can't put my cursor on a citation (John Lynch, where are you?), I have read in many places that the pre-private three hours is not to be included in the instrument time requirement under 61.65. If I come up with something, you will be the first to know.

Bob
 
alfadog said:
Isn't it odd that they require a licensed private pilot to fly solo?
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Not at all. Military pilots are subject to the FARs and do not get a PPL. They can submit military training records for application and consideration for CPL. They must meet same experience requirements.
 
Looks like my instrument rating may cost a couple thousand more than I had anticipated.

Originally, I had thought I would need 50 hours of PIC XC and then I would do an extra 40 hours of instrument time. That sounded wicked expensive.

Now it looks like I can squeeze some of that PIC XC time in with that 40 hours of instrument training somehow. I dunno how. I'd rather not have to pay for an instructor during non-instrument PIC XC time. Alternatively, I might be able to have the instructor in the plane with the hood on while on a XC flight for some of that time.

I must have been mislead by the school (both my program and the actual flight school) that it would cost x amount of money (about the same as my PPL), but I think they are going off of Part 141 instruction.



With that said, if I continue with Part 61 through Commercial, will I possibly spend less for the Commercial compared to Part 141? I looked at some price breakdowns with 141 and it is super expensive compared to Part 61 Commercial. I reckon it's because 141 needs more hours or has "lagged behind," so to speak, when doing instrument (as you don't need the 50 hours PIC XC for Instrument 141).


Edit: I hate I'm kind of coming to this crossroads now. I am really looking forward to getting my instrument rating, since it's the one I want most.
 
Are you aware that the regs now allow combined PPL/IR rating via 141?
 
alfadog said:
Isn't it odd that they require a licensed private pilot to fly solo?
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Part of it is demonstrating that you can handle the long flight without someone to talk to...prep for cheque runs and the like!
 
JeffDG said:
Part of it is demonstrating that you can handle the long flight without someone to talk to...prep for cheque runs and the like!
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But if I bring my dog then I will have someone to talk to. :D
 
HerrGruyere said:
Now it looks like I can squeeze some of that PIC XC time in with that 40 hours of instrument training somehow. I dunno how.
Click to expand...

Well, instead of going 10 miles down the road, shooting an approach and coming home, you might be able to schedule slightly longer lessons. Go hit an approach nearby, then fly to an airport 50 miles away from your origin and shoot an approach, and then come back home. On the enroute phase you can do some unusual attitudes, partial panel, or just practice intercepting/tracking etc. Instead of just flying around in a practice area you just head 50 miles in one direction, land, and then come home. That's an easy way to get 2.0 instrument training and 2.5 cross country on a single flight.

I'd rather not have to pay for an instructor during non-instrument PIC XC time.
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Just to be clear... you understand that the 50 hours of XC PIC doesn't have to be VFR or with your eyes outside, right? It can be 100% under the hood if you want it to be (with an instructor obviously).
 
JeffDG said:
Part of it is demonstrating that you can handle the long flight without someone to talk to...prep for cheque runs and the like!
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Most "cheques" have been sent via the Internet for over a decade. (Which is why it was relatively easy for banks to offer mobile Apps that you just shoot a photo of a check to deposit it these days... that's all they're doing with fast scanners. Most are doing it right at the ATM now...)
 
bobmrg said:
Tortured reasoning, IMHO, but I see where you are coming from. While I can't put my cursor on a citation (John Lynch, where are you?), I have read in many places that the pre-private three hours is not to be included in the instrument time requirement under 61.65. If I come up with something, you will be the first to know.

Bob
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When you find it, you'll see it discusses only the 15 hours of instrument flight training, not the 40 hours of instrument flight time.

And John retired several years ago.
 
HerrGruyere said:
Looks like my instrument rating may cost a couple thousand more than I had anticipated.

Originally, I had thought I would need 50 hours of PIC XC and then I would do an extra 40 hours of instrument time. That sounded wicked expensive.

Now it looks like I can squeeze some of that PIC XC time in with that 40 hours of instrument training somehow. I dunno how.
Click to expand...
You include one landing more than 50 nm from the training base on every flight. That way, it is all XC PIC time. Or, you could do the whole IR program under 141 and then there is no 50 hour XC PIC requirement -- just 35 hours of instrument training with an instructor on top of your PP.

I'd rather not have to pay for an instructor during non-instrument PIC XC time.
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Why would you have to? Nothing says you need an instructor to log XC PIC time.

Alternatively, I might be able to have the instructor in the plane with the hood on while on a XC flight for some of that time.
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Right -- you get that landing out there during your IR training flights so that whole flight counts as XC PIC time.

With that said, if I continue with Part 61 through Commercial, will I possibly spend less for the Commercial compared to Part 141?
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Too hard a question without your logbook and their rates in front of me.

I looked at some price breakdowns with 141 and it is super expensive compared to Part 61 Commercial. I reckon it's because 141 needs more hours or has "lagged behind," so to speak, when doing instrument (as you don't need the 50 hours PIC XC for Instrument 141).
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It's because their 141 Commercial program is 190 hours soup-to-nuts, while their 61 CP program assumes you already have the 250 hours (or close to it).
 
Jaybird180 said:
But he can't read a check list to you. I think it's to ensure you can handle all tasks single pilot
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It is. And they just don't want to get into arguments over whether your two year old kid or old Aunt Matilda can or cannot be of such assistance.
 
Jaybird180 said:
Are you suggesting that a winged (Naval for example) Aviator would not meet the requirement, even freshly winged?
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I have no idea, and it doesn't matter. You show up with the orders making you a military pilot, take the written, fill out an 8710-1, and you get your FAA CP. No check for hours involved.
 
Ron Levy said:
I have no idea, and it doesn't matter. You show up with the orders making you a military pilot, take the written, fill out an 8710-1, and you get your FAA CP. No check for hours involved.
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game.set.match
 
dukeblue219 said:
Well, instead of going 10 miles down the road, shooting an approach and coming home, you might be able to schedule slightly longer lessons. Go hit an approach nearby, then fly to an airport 50 miles away from your origin and shoot an approach, and then come back home. On the enroute phase you can do some unusual attitudes, partial panel, or just practice intercepting/tracking etc. Instead of just flying around in a practice area you just head 50 miles in one direction, land, and then come home. That's an easy way to get 2.0 instrument training and 2.5 cross country on a single flight.


Just to be clear... you understand that the 50 hours of XC PIC doesn't have to be VFR or with your eyes outside, right? It can be 100% under the hood if you want it to be (with an instructor obviously).
Click to expand...

Bingo. I think this solved my problem. It's like killing two birds with one stone.

Ron Levy said:
You include one landing more than 50 nm from the training base on every flight. That way, it is all XC PIC time. Or, you could do the whole IR program under 141 and then there is no 50 hour XC PIC requirement -- just 35 hours of instrument training with an instructor on top of your PP.

Why would you have to? Nothing says you need an instructor to log XC PIC time.

Right -- you get that landing out there during your IR training flights so that whole flight counts as XC PIC time.

Too hard a question without your logbook and their rates in front of me.

It's because their 141 Commercial program is 190 hours soup-to-nuts, while their 61 CP program assumes you already have the 250 hours (or close to it).
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I might try to take a couple PIC XC trips by myself or with my friends/girlfriend to get some food or just roam around. I'd like to at least enjoy my new ticket on my own terms without immediately beginning new training!

I am tempted to do 141 for my IR, but then I'd like to switch back to Part 61. I may get in touch with a CFI-I at the FBO regarding this.
 
FWIW, I now try to make all my flying XC to meet an agreed upon pre-req from my intended CFII. I used to sweat it (that it was a tall order) but now I'm thinking I'll far exceed it by the time I'm ready to start actual training.

Best to you and your projections. Recommend that you focus and finish your PPL first. Too few students start and too few complete.
 
Don't forget, you Solo XCs from before you get your private count as Cross Country-PIC time, and since they have to be >50nm too, they're applicable to the instrument.
 
I'm almost done with my PPL and haven't lost sight of the light at the end of the tunnel! I love flying waaaaaaaaaaay too much to stop.
 
HerrGruyere said:
Bingo. I think this solved my problem. It's like killing two birds with one stone.
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Yes.

I might try to take a couple PIC XC trips by myself or with my friends/girlfriend to get some food or just roam around. I'd like to at least enjoy my new ticket on my own terms without immediately beginning new training!
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That would be a really good idea. It is the experience you gain from that flying which is important to being comfortable flying IFR. Get flight following all the time, too, so you become comfortable communicating with ATC.
 
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