Commercial Requirements

[jimbtv]

I have around 430 hours PIC and my instrument rating. I am now studying for my commercial written test and have reviewed the requirements under FAR 61.129. This section of the regs reads more like a laundry list of required times and tasks, of which I have accomplished all except "(v) 3 hours in a single-engine airplane in preparation for the practical test within the 60-day period preceding the date of the test."

An instructor's endorsement is required before I can schedule a checkride but I don't see any specific requirements for formal instructor training. Of course no instructor is going to provide an endorsement without first having me demonstrate my skills. Let's imagine for a moment that I were to show up for my first scheduled time with the instructor, fully accomplished in all of the required knowledge and flight procedures and I demonstrated that to the instructor's satisfaction, would that be all that is required? Is there really no official "x - hours with an instructor" clause?

Jim

 

[poadeleted20]

I think you need to go back and re-read paragraph (a)(3) of that section (61.129), which requires 20 hours of training with an instructor in specific areas. Of course, the 10 hours of instrument training is covered by your Instrument rating training, but you also must have 10 hours of training in a complex plane and two dual XC's of 2 hours each (one day, one night) in addition to the 3 hours of dedicated test prep (all of which may be combined, say, by doing your IR training or XC's in a complex plane, as long as it all adds up to 20).

That said, if you really do meet all the requirements, then yes, I can sign you off with only 3 additional hours of test prep as long as your logbook shows that all the areas listed in 61.127(a)(1) were covered by your previous instructors and you convince me you can do all the PTS-required tasks well enough to pass the CP-ASEL practical test, plus however much ground training is needed to assure myself that you can pass the oral and now know all the areas you missed on the written test (see 61.39(a)(6)).

 

[jimbtv]

I think you need to go back and re-read paragraph (a)(3) of that section (61.129), which requires 20 hours of training with an instructor in specific areas. Of course, the 10 hours of instrument training is covered by your Instrument rating training, but you also must have 10 hours of training in a complex plane and two dual XC's of 2 hours each (one day, one night) in addition to the 3 hours of dedicated test prep (all of which may be combined, say, by doing your IR training or XC's in a complex plane, as long as it all adds up to 20).

Thanks for the reply Ron.

I do have the instrument time, as well as the complex time. I did all of my instrument training in my 177RG and have flown that aircraft exclusively for the past 3 years and 300+ hours. I think it's a little odd that the regs call for the dual cross country time to be VFR. I would think that IFR cross country time would suffice as well, both day and night. Either way, I have it covered.

That said, if you really do meet all the requirements, then yes, I can sign you off with only 3 additional hours of test prep as long as your logbook shows that all the areas listed in 61.127(a)(1) were covered by your previous instructors and you convince me you can do all the PTS-required tasks well enough to pass the CP-ASEL practical test, plus however much ground training is needed to assure myself that you can pass the oral and now know all the areas you missed on the written test (see 61.39(a)(6)).

Not to imply that I am (or would be) "checkride-ready anytime too soon. I still have a lot of work ahead of me. I'm a little amazed that there isn't some built-in time requirements for the additional maneauvers and such. The private pilot certificate requires 20 hours of instruction and the instrument rating requires 15 hours of instruction. It appears that the commercial certificate doesn't have the same prerequisite. Much of what is required can be accomplished while training for other certificates.

Jim

 

[poadeleted20]

I think it's a little odd that the regs call for the dual cross country time to be VFR. I would think that IFR cross country time would suffice as well, both day and night.

FWIW, the FAA has changed their mind on this and proposed changing 61.129 to allow IFR or VFR for those two dual XC's.

The private pilot certificate requires 20 hours of instruction and the instrument rating requires 15 hours of instruction. It appears that the commercial certificate doesn't have the same prerequisite.

As I said above, yes, it does -- see 61.129(a)(3), which requires 20 hours of training in the areas of 61.127(a)(1). The fact that 10 of those hours may be accomplished simultaneously with your IR training, or some more as part of 61.31(e) complex endorsement training doesn't change the fact that 20 hours of post-PPL flight training is required. And, FWIW, it usually takes more than 5 hours of training to get all the Commercial "Performance Maneuvers" and other Commercial-specific tasks down pat. Add that to the 10 hours of instrument training, 4 hours of XC training, and 3 hours of test prep, and you're over 20 hours total post-PPL flight training anyway.