14 CFR 61.129(a)(3)- Question about the 10 of the 20 hour requirement for aeronautical experience.

[darthanubis]

I searched but didn't find this question asked, and argued today with a CFI about it. He couldn't explain it to me at all.

His position is that 10 of the 20 hours of training on the areas of operation listed in § 61.127(b)(1) for commercial is different than 10 hours logged already doing those maneuvers and procedures to get your privates license and that the 10 hours of the maneuvers to complete your instrument also doesn't count towards satisfying 14 CFR 61.129(a)(3).

My position is, where in the regulations does it say that your aeronautical experience doing everything in 14 CFR 61.127(b) as a private pilot doesn't count towards your commercial, and same for 14 CFR 61.129(a)(3)(i).

Please help me understand.

 

[flyingcheesehead]

I searched but didn't find this question asked, and argued today with a CFI about it. He couldn't explain it to me at all.

His position is that 10 of the 20 hours of training on the areas of operation listed in § 61.127(b)(1) for commercial is different than 10 hours logged already doing those maneuvers and procedures to get your privates license and that the 10 hours of the maneuvers to complete your instrument also doesn't count towards satisfying 14 CFR 61.129(a)(3).

My position is, where in the regulations does it say that your aeronautical experience doing everything in 14 CFR 61.127(b) as a private pilot doesn't count towards your commercial, and same for 14 CFR 61.129(a)(3)(i).

Please help me understand.

He's at least partially correct.

While it addresses helicopter training and not airplane training, the regs are analogous to what is addressed in the Thierault 2010 interpretation (attached).

While it may seem confusing, the Asp 2015 letter (also attached) references the Thierault 2010 letter but seems to draw the opposite conclusion.

The difference is that you must be getting trained and evaluated to the commercial standards for the maneuvers. If the CFI you used for your Private is willing to attest to that (in your logbook), then I believe it can be counted (and this is backed up by the clearer language in the attached McLellan letter). If not, then the CFI is correct, that the training in 61.129(a)(3) must be completed while training for the commercial pilot certificate.

For the instrument, it's kinda the same only a bit stickier thanks to the Hartzell letter, also attached, which also references Thierault and says that the instrument training for the instrument rating *may* (not "does") also meet the requirements of 61.129. Again, your CFII can make this clearer in your logbook.

 

[darthanubis]

He's at least partially correct.

While it addresses helicopter training and not airplane training, the regs are analogous to what is addressed in the Thierault 2010 interpretation (attached).

While it may seem confusing, the Asp 2015 letter (also attached) references the Thierault 2010 letter but seems to draw the opposite conclusion.

The difference is that you must be getting trained and evaluated to the commercial standards for the maneuvers. If the CFI you used for your Private is willing to attest to that (in your logbook), then I believe it can be counted (and this is backed up by the clearer language in the attached McLellan letter). If not, then the CFI is correct, that the training in 61.129(a)(3) must be completed while training for the commercial pilot certificate.

For the instrument, it's kinda the same only a bit stickier thanks to the Hartzell letter, also attached, which also references Thierault and says that the instrument training for the instrument rating *may* (not "does") also meet the requirements of 61.129. Again, your CFII can make this clearer in your logbook.

Thank you!

I intend to get my instructor certs so this classification and information is invaluable. I appreciate you taking the time and it makes sense. If I were him, I would’ve just said you need to have 10 hours evaluated to COMMERCIAL standards, that’s why the private dual doesn’t apply.

Cheers!

 

[flyingcheesehead]

Thank you!

I intend to get my instructor certs so this classification and information is invaluable. I appreciate you taking the time and it makes sense. If I were him, I would’ve just said you need to have 10 hours evaluated to COMMERCIAL standards, that’s why the private dual doesn’t apply.

Cheers!

It seems there are far too many CFIs who know the what, but not the why or the how. Giving good instruction is all about the why and the how!

Whenever there's a question like this, I search the FAA Chief Counsel interpretations, because they're the final authority on the regs:

Dynamic Regulatory System

drs.faa.gov

And when I need to get there, I just google "Search FAA chief counsel interpretations", it's the first result.