Commercial Requirements...

purdue1014

Pre-takeoff checklist
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Brent
Hello All,

I am going to start going after the Commercial Pilot Certificate experience requirements, I'm looking to make sure that I understand them properly so I don't have to redo anything.....

Sec. 61.129 - Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least -- Including any PIC/SOLO time I logged as a student, correct?
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes. Can this include the 50 PIC XC I have for the IR?
(3) 20 hours of training read dual recieved on the areas of operation listed in §61.127(b)(1) of this part that includes at least --
(i) 10 hours of instrument training of which at least 5 hours must be in a single-engine airplane; Can this include the 40+ simulated instrument hours I have for the IR?
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, FWIW, I could get 10 hours in a 172 RG, and then get the Comm in a BO?--Just for arguements sake... or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;
(iii) One cross-country flight of at least 2 hours in a single-engine airplane in day VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure; So a XC that is > than 100 NM total. Could this be the dual XC I took with my CFI that was a student? Or how about a VFR XC that my CFII took with me under the hood most of the way?(iv) One cross-country flight of at least 2 hours in a single-engine airplane in night VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure; so another XC that is > 100 NM. If my one dual night XC as a student was 2.0 even, I could include this, correct? and
(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.
(4) 10 hours of solo flight in a single-engine airplane on the areas of operation listed in §61.127(b)(1) of this part, which includes at least --
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. A-B-C is at least 300 NM. A landing at A, B, C. Either B or C has to be > 250 NM from A.? However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and (ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower. A total of 5 hours of night time, with a total of 10 night landings, which do not have to be in the same flight.

So, Ron, et al., how did I do?

Thanks,

Purdue
 
You may also want to consider Part 141. This is what I am doing because I did not have the 250 hours time. You did not state your total time & type of time.

141 is 55 hours of dual instruction, 65 hours of solo/pic/XC combined time. I am doing the King 141.
 
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For the night landings those have to also be at a control towered airport. I had to rush and get 4 more as I had plenty of night control tower takeoffs and plenty of night landings but at non-CT fields.

I headed over to DPA one Wednesday night and knocked them out.

The long XC has to be solo!

the >100NM have to be dual with a CFI

As to whether they can be form you student pilot days is an argument. My DPE said it was ok as did the FSDO, the CFIs at my flight school, and the Chief Instructor at one of the big ATP schools down the road in Florida where I took my commercial checkride. Ron Levy says otherwise. Ron and I will not come to any sort of agreement on this, I would suggest that you check with your DPE and the FSDO where you will do the checkride.

Your instrument time from you instrument rating will count.

The VFR XCs also have to be VFR with you flying it VFR, under the hood is simulated instrument and you would have logged it as such.
 
(2) 100 hours of pilot-in-command flight time, which includes at least -- Including any PIC/SOLO time I logged as a student, correct?
Correct.
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes. Can this include the 50 PIC XC I have for the IR?
Yes.
(i) 10 hours of instrument training of which at least 5 hours must be in a single-engine airplane; Can this include the 40+ simulated instrument hours I have for the IR?
Yes.
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, FWIW, I could get 10 hours in a 172 RG, and then get the Comm in a BO?--Just for arguements sake...
Yes, but I doubt anyone will let you have that Bonanza without another 10 hours in type -- insurance, and all that. Plus, you'd need an HP endorsement.
(iii) One cross-country flight of at least 2 hours in a single-engine airplane in day VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure; So a XC that is > than 100 NM total. Could this be the dual XC I took with my CFI that was a student?
Flight Standards says "no." They say these flights must be post-PPL training for the commercial, not training for the PPL.
Or how about a VFR XC that my CFII took with me under the hood most of the way?
Again, Flight Standards says no -- gotta be visual nav.

(iv) One cross-country flight of at least 2 hours in a single-engine airplane in night VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure; so another XC that is > 100 NM. If my one dual night XC as a student was 2.0 even, I could include this, correct?
Again, Flight Standards says no.
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. A-B-C is at least 300 NM. A landing at A, B, C. Either B or C has to be > 250 NM from A.?
Correct.
(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower. A total of 5 hours of night time, with a total of 10 night landings, which do not have to be in the same flight.
Correct, and you have to log 10 night takeoffs, too.
So, Ron, et al., how did I do?
Not bad, for a non-CFI.
 
Wow, most of these requirements I have knocked out already. :D
 
Just to make sure I have it with the two Day, one night XC flights and 10 night landings.

Do they all have to be Solo?

For the XC flights the 250 / 300 requires three landings do the shorter day and night ones also require three landing or will a quick round trip suffice?

Can these flights be on an IFR flightplan with some time in IFR conditions?
 
Just to make sure I have it with the two Day, one night XC flights and 10 night landings.

Do they all have to be Solo?

For the XC flights the 250 / 300 requires three landings do the shorter day and night ones also require three landing or will a quick round trip suffice?

Can these flights be on an IFR flightplan with some time in IFR conditions?

The long XC is SOLO, the other two are dual.

The solo long XC is the one that require 3 landings at different airports with one airport being 250NM for the origin.

The dual XC, night and day, are to be training, so that mean dual with a CFI on board. Only one landing is required but they are to be 100NM XCs not 50NM each way. I had to do one more night dual XC as my only dial night XC was 75NMs long.
 
Just to make sure I have it with the two Day, one night XC flights and 10 night landings.
Not necessarily two Day/one Night -- just one day dual, one night dual, and one long solo (day, night, or combination).
Do they all have to be Solo?
There solo XC can be day or night. The dual XC's must be one day, one night, although they may be on the same trip -- two hours out in the light, land more than 100nm from home, then two hours back in the dark. Alternatively, you could put one student in the front and one in the back, fly out 2 hours, land more than 100nm from home, trade seats, and fly 2 hours home, all in the day, and both students have the day dual XC square filled -- then do the same thing at night.
For the XC flights ...do the shorter day and night ones also require three landing or will a quick round trip suffice?
The dual XC's require one landing at least 100nm from the point of departure. They need not even be a round trip (see above).
Can these flights be on an IFR flightplan with some time in IFR conditions?
As of now, Flight Standards want the duals to be VFR using visual navigation, but that may change next year. The solo may be VFR, IFR, or a combination -- just solo.
 
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As of now, Flight Standards...
Are there any publicly-available references to what Flight Standards wants? Or even privately available documents. You seem to refer to them in a way that suggests that you have read them, as one could have with the disowned FAQ or can with the FAA Legal opinions.
 
Thanks All!

Just to verify before I go fly it tomorrow, the three separate landings (at 3 different airports) for the "long XC," can include landing at my home airport, no? I'll go out 260 NM, and on the return stop half way in between, before coming home...

Also, to show my ignorance, I thought that it was Chief Counsel's opinion that mattered, not Flight Standard's, what am I missing?

Finally, is there any specific way I should log these requirements, so I don't have to redo them? I figured I'd put something like, "Long Comm XC per <FAR # here>"

Thanks,

Purdue
 
When your examiner looks at your log, he's gonna decide if the flight qualifies. If he doesn't KNOW it does, he'll consult the FSDO for guidance, and will go with what he's told. If you don't LIKE the answer he gets from flight standards, you can raise the issue with the FAA counsel. Don't get rusty waiting for an answer - your medical might expire first. The fact that there's no published counsel opinion on this means nobody's officially asked the question in such a way that Counsel has deigned to answer. They do NOT answer every query that comes in.
 
Thanks All!

Just to verify before I go fly it tomorrow, the three separate landings (at 3 different airports) for the "long XC," can include landing at my home airport, no? I'll go out 260 NM, and on the return stop half way in between, before coming home...

Also, to show my ignorance, I thought that it was Chief Counsel's opinion that mattered, not Flight Standard's, what am I missing?

Finally, is there any specific way I should log these requirements, so I don't have to redo them? I figured I'd put something like, "Long Comm XC per <FAR # here>"

Thanks,

Purdue

Hey Purdue,

If the weather holds, I'll also be doing a 260NM XC -- but from the looks of it right now it will more likely be Saturday.

I went over it with my CFI and the local DE, who was in the room. I'm going to stop at three airports (IJD, SFZ, and ORH) but they both said that if the time starts to run short, I can skip ORH and just fly over it on the way back and I'll still be ok.

Good luck on your trip and have fun!
 
Are there any publicly-available references to what Flight Standards wants?
Generally not. Just the "disowned" FAQ file, which has always reflected Flight Standards' thinking, whether the Chief Counsel had approved it or not. Having been watching this for a couple of years since the "de-officializing" letter from AFS-1, everything in the FAQ file has stayed the way AFS does things except when the Chief Counsel has specifically overruled them after someone objected to what was in the FAQ file. Thus, I assume that what was written there remains the best guidance available on Part 61 issues unless there is something more recent that says otherwise. So far, it's been pretty accurate -- it's been a very long time since I've seen anyone get in trouble for doing it the way the FAQ file says. Do it any other way, and you're betting that the Chief Counsel will say Flight Standards is wrong, which hasn't happened very often -- out of like 650 Q&A's, I know of only a handful which the Chief Counsel has said are wrong.
 
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Also, to show my ignorance, I thought that it was Chief Counsel's opinion that mattered, not Flight Standard's, what am I missing?
The Chief Counsel's opinion ultimately matters, but the ultimate authority of the Chief Counsel over regulatory interpretation does not mean that no one else within the FAA can do so and make it stick.

Happens all the time.
 
Generally not. Just the "disowned" FAQ file,
As you know from other posts, I don't share Ed's view of the complete worthlessness of the document and don't really care about whether it has Chief Counsel approval or not.

But I do think using a document that was not really official to begin with, had acknowledged errors, specifically disowned by the FAA, and pulled (what, at least 2 years ago now?) as a source for saying "As of now, Flight Standards want..." without mentioning the source, is improper.
 
The Chief Counsel's opinion ultimately matters, but the ultimate authority of the Chief Counsel over regulatory interpretation does not mean that no one else within the FAA can do so and make it stick.

Happens all the time.
It is my understanding that with regard to Part 61 questions, the first people the Chief Counsel's office asks about the intent of the rule is the office that wrote them (AFS-800), and the person in that office who usually handles the matter is John Lynch -- the author of the "no-longer-official" FAQ file. In addition, with Part 61 rules where no Chief Counsel interpretation exists, you'll be dealing with the FSDO (i.e., Flight Standards), and their answer will be what happens unless/until you get the Chief Counsel to overrule Flight Standards.
 
specifically disowned by the FAA
Having spoken with some folks in AFS-800 about that, the principal issue was that the Chief Counsel's office objected to the FAQ file being "official" without review and approval by the Chief Counsel's office. The whole reason AFS-800 invented the thing in the first place was the 4-month wait for interpretations from the Chief Counsel's office, which got in the way of the smooth functioning of the Flight Standards Service -- when someone shows up with a logbook, they don't have four months to decide if the application will be accepted. At the end of the day, the Chief Counsel won that battle, and the FAQ file was "de-officialized" and taken out of public view. However, I was told that we should expect about 98% of what's in it to be left intact as the officialization process plods onward and the material is transferred to the "official" FAA Q&A site http://faa.custhelp.com/.
 
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