commercial requirements

[shenanigans]

I'm about to finish the instrument rating and figured I might as well get the commercial rating done while I'm still in the training mindset. A while ago I read about proposed changes to eliminate the complex aircraft requirement from the commercial rating. Is this going to happen in the near future? I have more than the required time in a complex plane, but the instructor I want to use for the commercial training doesn't have access to one for training. I could get one for the test, but it seems a bad idea to do training in one type and the test in another. On the other hand, I'd rather not be forced to use a less experienced instructor simply because the one I want doesn't have the plane I need.

Also, I remember reading about some issue with examiners not accepting instrument instruction from the instrument rating for the required 10 hours of commercial instrument time. Does anyone know anything more about this?

 

[EdFred]

I'm about to finish the instrument rating and figured I might as well get the commercial rating done while I'm still in the training mindset. A while ago I read about proposed changes to eliminate the complex aircraft requirement from the commercial rating. Is this going to happen in the near future?

No.

I have more than the required time in a complex plane, but the instructor I want to use for the commercial training doesn't have access to one for training. I could get one for the test, but it seems a bad idea to do training in one type and the test in another. On the other hand, I'd rather not be forced to use a less experienced instructor simply because the one I want doesn't have the plane I need.

Many people do all the check ride in a non-complex plane, and only use the complex plane to demonstrate what the complex is necessary for on the check ride. I did it this way.

Also, I remember reading about some issue with examiners not accepting instrument instruction from the instrument rating for the required 10 hours of commercial instrument time. Does anyone know anything more about this?

Those examiners need to be relieved of their duties.

 

[Gary F]

I assume that you can take the commercial check ride with a 3rd class medical. Is this correct?

 

[Ted]

I assume that you can take the commercial check ride with a 3rd class medical. Is this correct?

Yes. The 2nd class medical is only required for exercising the privileges of the commercial certificate, not for having it or for taking the checkride.

 

[poadeleted20]

A while ago I read about proposed changes to eliminate the complex aircraft requirement from the commercial rating. Is this going to happen in the near future?

Unknown. That NPRM has completed its public comment period, and unless someone is getting information from someone prohibited from giving such information, there's no way for anyone outside the internal FAA process to know. It could happen tomorrow, it could happen next month, it could happen next year, it could happen never.

I have more than the required time in a complex plane, but the instructor I want to use for the commercial training doesn't have access to one for training. I could get one for the test, but it seems a bad idea to do training in one type and the test in another. On the other hand, I'd rather not be forced to use a less experienced instructor simply because the one I want doesn't have the plane I need.

Unfortunately, as the rules are now, the recommendation ride must cover complex procedures, so if you can't get training in a complex plane from the instructor you want to use, you'll have to get at least some training (including the practical test endorsement) from one who can train you in a complex airplane.

Also, I remember reading about some issue with examiners not accepting instrument instruction from the instrument rating for the required 10 hours of commercial instrument time. Does anyone know anything more about this?

Yes. Unless the training for your IR specifically documents in your logbook that it included 10 hours of training "using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," you'll have to do more training. The fact that it was training for the IR is irrelevant -- what's important is that 10 hours of training in those skills are documented. If the examiner waves the Theriault letter at you, show him/her the clarifying Hartzell letter.
http://www.faa.gov/about/office_org...terpretations/data/interps/2010/Theriault.pdf
http://www.faa.gov/about/office_org...nterpretations/data/interps/2010/Hartzell.pdf

 

[poadeleted20]

Yes. The 2nd class medical is only required for exercising the privileges of the commercial certificate, not for having it or for taking the checkride.

And if anybody asks, the reference is 14 CFR 61.39(a)(4).

 

[drizzt76]

In ref. to the Hartzell .pdf //
AOPA = Airliner Owners and Pilots Association
I guess we are all human

 

[weilke]

Yes. Unless the training for your IR specifically documents in your logbook that it included 10 hours of training "using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," you'll have to do more training. The fact that it was training for the IR is irrelevant -- what's important is that 10 hours of training in those skills are documented. If the examiner waves the Theriault letter at you, show him/her the clarifying Hartzell letter.
http://www.faa.gov/about/office_org...terpretations/data/interps/2010/Theriault.pdf
http://www.faa.gov/about/office_org...nterpretations/data/interps/2010/Hartzell.pdf

So if I read that correctly, if someone starts an instrument rating today, he should have his instructor put a note in his logbook after a 10hr block of training that states : the flights from so and so to so and so included training "using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," and everything is golden for a later commercial checkride.
(Got to love the FAA. Someone who does his entire instrument rating in 'actual' would not qualify.....)

 

[poadeleted20]

So if I read that correctly, if someone starts an instrument rating today, he should have his instructor put a note in his logbook after a 10hr block of training that states : the flights from so and so to so and so included training "using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," and everything is golden for a later commercial checkride.

Not exactly. Each flight made should log the training done on that flight. As long as you can find 10 hours of instrument flight training which in toto (not necessarily all on one flight) include all those tasks, you've got it made. And frankly, if someone gets an IR without having logged 10 hours of training which include all those tasks, either someone's instructor lied in the practical test recommendation endorsement about having covered all the Areas/Tasks for the PTS, or someone's instructor didn't comply with 61.51(h)(2)(ii) by "Includ[ing] a description of the training given" on each training flight.

(Got to love the FAA. Someone who does his entire instrument rating in 'actual' would not qualify.....)

Well, I suppose not, but I doubt anyone gets their IR without at least ten hours of training under the hood. Further, I suspect that if the issue were raised to AFS-800, they'd probably reconsider and say training time in actual instrument conditions counts.

 

[weilke]

Not exactly. Each flight made should log the training done on that flight. As long as you can find 10 hours of instrument flight training which in toto (not necessarily all on one flight) include all those tasks, you've got it made.

Ok, so you just have to make sure that that verbiage appears in the lesson descriptions.

And frankly, if someone gets an IR without having logged 10 hours of training which include all those tasks, either someone's instructor lied in the practical test recommendation endorsement about having covered all the Areas/Tasks for the PTS,

Well, makes the FAAs point of view on this all the more silly. If you passed the IR checkride, you received instruction in this stuff. Why the IR in your license is not sufficient evidence of that fact.....

Well, I suppose not, but I doubt anyone gets their IR without at least ten hours of training under the hood. Further, I suspect that if the issue were raised to AFS-800, they'd probably reconsider and say training time in actual instrument conditions counts

The only reason the letter is worded that way because it is lawyer thinking that creates the wording, not common sense.

 

[poadeleted20]

Ok, so you just have to make sure that that verbiage appears in the lesson descriptions.

You got it, and you should have been doing that anyway. For instructors who've been doing it right all along, there's no change as a result of these two letters.

Well, makes the FAAs point of view on this all the more silly. If you passed the IR checkride, you received instruction in this stuff. Why the IR in your license is not sufficient evidence of that fact.....

Beats me. Maybe they're just trying to push instructors to document properly during IR training, maybe they're concerned that instructors are skimping somehow, [insert your own guess]

 

[shenanigans]

Unfortunately, as the rules are now, the recommendation ride must cover complex procedures, so if you can't get training in a complex plane from the instructor you want to use, you'll have to get at least some training (including the practical test endorsement) from one who can train you in a complex airplane.

Any chance you have a reference for this? All I see is the 3 hours in a single engine plane within 60 days. Also, for the test endorsement, how does that work if you have multiple instructors? In that case, any given instructor would only have done part of the required train, but then signs off on all of it?

 

[poadeleted20]

Any chance you have a reference for this? All I see is the 3 hours in a single engine plane within 60 days. Also, for the test endorsement, how does that work if you have multiple instructors? In that case, any given instructor would only have done part of the required train, but then signs off on all of it?

14 CFR 61.39(a):

(6) Have an endorsement, if required by this part, in the applicant's logbook or training record that has been signed by an authorized instructor who certifies that the applicant--
(i) Has received and logged training time within 2 calendar months preceding the month of application in preparation for the practical test;
(ii) Is prepared for the required practical test; and
(iii) Has demonstrated satisfactory knowledge of the subject areas in which the applicant was deficient on the airman knowledge test; and

If you haven't checked every testable Area/Task in the PTS, you can't certify that the applicant is prepared for that test. While the three hours of test prep you mention may be given by different instructors, the one who finally signs the 61.39(a)(6) endorsement must have checked everything testable on that practical test. There's just no provision for joint endorsements by more than one instructor.