complex aiarcraft training issue

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dwtd

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dwtd
Hello,

Any help will be highly appreciated! I'll try to explain my situation here, maybe some of us may come up an idea. Here it is;

I live in Puerto Rico and after the hurricane Maria, my school had lost complex aircraft in the fleet and that was the only one. And school haven't replaced it with the new one yet it has been almost 1 year. I need only 6 hours of complex training to take faa checkride and i cant' go further because of this missing 6 hours. And school always coming with another excuse to me and made me waiting for nothing. I was just wondering if i start my multi engine rating training and fly those 6 hours with multi which is complex aircraft, will i be eligible to take commercial pilot licence (single engine land) faa checkride? I already checked the regulation and it's really complicated. I would like to get my licence before August 27, i already lost time and i do not want to wait anymore. If anyone can give me any advice about this issue, i would be so happy. I am in part 141.
 
I don't have the fars in front of me but I'd like to believe the multi would satisfy the 6 hours of complex time. You'd be taking the checkride in a single and demonstrating single engine commercial proficiency maneuvers. So I think youd be alright.

That said, I find it really hard to believe nobody in Isla Grande didn't ferry an arrow or the like back from the CONUS. Its an absolutely moneymaker down there given the water locked nature of training.
 
Thanks for the replies. I am really appreciate it! things are getting interesting cause when I read the FAR , It seems that you can fly with the multi complex aircraft to meet the requirements and one of the comments in boldmethod.com mentions that some schools fly with multi engine complex aircraft in the beginning of the training to meet those requirements for ASEL commercial. However, I sent an e-maoil to local FAA office and explain my situation about it answer was different than that. Here is the answer;


"As for doing complex hours in a multiengine airplane to meet 61.129(a) the rule states, “10 hours of training in an airplane…” 61.129(a)(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine powered, or for an applicant seeking single-engine seaplanr rating, 10 hours of training in a seaplane that has flaps and controllable pitch propeller. It does not differentiate between single or multiengine for training purposes,



HOWEVERr, if you look at 61.129 (b), it states “10 hours of training in a multiengine that’s has a retractable landing gear…”

(ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine powered, or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine sea[lane that has flaps and controllable pitch propeller. It does differentiate between single engine or multiengine. For training purpose it states it must be done in a multiengine aircraft that meets complex requirements.



Therefore, you cannot use the multiengine hours to apply for an initial commercial ASEL, it must be in a single engine complex. The only change was that you don’t need to demonstrate the complex aircraft the day of the check ride. Hope this clarifies your request."

So, i am confused! I am worry about the weather (for a chance of developing another hurricane) that's why I would like to get my license before august 27 even though regulation will change after and won't need those complex aircraft. Technical advance aircraft would do the job. :(
 
dwtd said:
Thanks for the replies. I am really appreciate it! things are getting interesting cause when I read the FAR , It seems that you can fly with the multi complex aircraft to meet the requirements and one of the comments in boldmethod.com mentions that some schools fly with multi engine complex aircraft in the beginning of the training to meet those requirements for ASEL commercial. However, I sent an e-maoil to local FAA office and explain my situation about it answer was different than that. Here is the answer;


"As for doing complex hours in a multiengine airplane to meet 61.129(a) the rule states, “10 hours of training in an airplane…” 61.129(a)(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine powered, or for an applicant seeking single-engine seaplanr rating, 10 hours of training in a seaplane that has flaps and controllable pitch propeller. It does not differentiate between single or multiengine for training purposes,



HOWEVERr, if you look at 61.129 (b), it states “10 hours of training in a multiengine that’s has a retractable landing gear…”

(ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine powered, or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine sea[lane that has flaps and controllable pitch propeller. It does differentiate between single engine or multiengine. For training purpose it states it must be done in a multiengine aircraft that meets complex requirements.



Therefore, you cannot use the multiengine hours to apply for an initial commercial ASEL, it must be in a single engine complex. The only change was that you don’t need to demonstrate the complex aircraft the day of the check ride. Hope this clarifies your request."

So, i am confused! I am worry about the weather (for a chance of developing another hurricane) that's why I would like to get my license before august 27 even though regulation will change after and won't need those complex aircraft. Technical advance aircraft would do the job. :(
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Try asking a different FSDO...They're known for giving different answers to the same question, especially in cases like this where they read something into a reg that isn't there.

Better yet, ask the examiner you're planning to use.
 
dwtd said:
"As for doing complex hours in a multiengine airplane to meet 61.129(a) the rule states, “10 hours of training in an airplane…”
...........

Therefore, you cannot use the multiengine hours to apply for an initial commercial ASEL, it must be in a single engine complex.
Click to expand...

Huh? I read it exactly the opposite. If you're going for a single-engine rating, then (a) applies and it does not specify the number of engines, and (b) which is about multi-engine ratings, is irrelevant. Same reading that you originally read.
 
The San Juan fsdo is out to lunch on that one. The reg doesn't imply the complex time has to be single engine for the CSEL just because the multi engine regs specify multi complex time for the CME(L/S).
 
That is the dumbest thing I’ve read in a long time from a FSDO.

The local DPEs need to see that so they can collectively go slap that inspector upside the head.

NO national level organization I’ve seen publishing anything about the recent changes for complex aircraft and the initial Commercial, has interpreted that, in that way, not one.

If the law writers wanted a class requirement on the complex time countable for the single engine ride, they’d have put it there. It’s NOT there.
 
dwtd said:
Thanks for the replies. I am really appreciate it! things are getting interesting cause when I read the FAR , It seems that you can fly with the multi complex aircraft to meet the requirements and one of the comments in boldmethod.com mentions that some schools fly with multi engine complex aircraft in the beginning of the training to meet those requirements for ASEL commercial. However, I sent an e-maoil to local FAA office and explain my situation about it answer was different than that. Here is the answer;


"As for doing complex hours in a multiengine airplane to meet 61.129(a) the rule states, “10 hours of training in an airplane…” 61.129(a)(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine powered, or for an applicant seeking single-engine seaplanr rating, 10 hours of training in a seaplane that has flaps and controllable pitch propeller. It does not differentiate between single or multiengine for training purposes,



HOWEVERr, if you look at 61.129 (b), it states “10 hours of training in a multiengine that’s has a retractable landing gear…”

(ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine powered, or for an applicant seeking a multiengine seaplane rating, 10 hours of training in a multiengine sea[lane that has flaps and controllable pitch propeller. It does differentiate between single engine or multiengine. For training purpose it states it must be done in a multiengine aircraft that meets complex requirements.



Therefore, you cannot use the multiengine hours to apply for an initial commercial ASEL, it must be in a single engine complex. The only change was that you don’t need to demonstrate the complex aircraft the day of the check ride. Hope this clarifies your request."

So, i am confused! I am worry about the weather (for a chance of developing another hurricane) that's why I would like to get my license before august 27 even though regulation will change after and won't need those complex aircraft. Technical advance aircraft would do the job. :(
Click to expand...
That is simply ridiculous. Is it the Orlando FSDO?
 
Whoever answered that letter from the FSDO is a moron, and should be immediately fired for suffering from recto-cranial inversion. Probably the same idiot that said GPS can't be used to determine where an NDB is.
 
midlifeflyer said:
I asked about Orlando because they seem to be a bit (in)famous for creating their own interpretations.
Click to expand...
no, that was the answer of San Juan FSDO.

and I called the examiner who will give me a checkride and he also told me that "I CAN'T FLY WITH MULTI ENGINE COMPLEX TO MEET THOSE 10 REQUIREMENTS TO TAKE COMMERCIAL ASEL" so I am totally ****ed off! I have to wait till august 27 till the regulation changes after that date. I am part 141 that is why I can't go for other school. I don't know who is right?

My opinion is, if you fly multi engine complex to meet 10 hours, you should be fine taking the faa checkide, that's what I understand from FAR! but somehow examiner and FSDO thinks differently!
 
dwtd said:
no, that was the answer of San Juan FSDO.

and I called the examiner who will give me a checkride and he also told me that "I CAN'T FLY WITH MULTI ENGINE COMPLEX TO MEET THOSE 10 REQUIREMENTS TO TAKE COMMERCIAL ASEL" so I am totally ****ed off! I have to wait till august 27 till the regulation changes after that date. I am part 141 that is why I can't go for other school. I don't know who is right?

My opinion is, if you fly multi engine complex to meet 10 hours, you should be fine taking the faa checkide, that's what I understand from FAR! but somehow examiner and FSDO thinks differently!
Click to expand...
Ah. Part 141 raises issues beyond the FAR.
 
dwtd said:
I am part 141
Click to expand...

That changes things significantly. You have to fly to their approved syllabus once you choose 141. Their curriculum and syllabus are FAA approved, and if not written to take advantage of certain things, they’re not flexible.

You get some small breaks on the flight time required and other things that the Part 61 folks don’t, including the ability to do it all on massive student loan debt, but the syllabus is essentially “law” once you choose the 141 path.

Most people choose 141 for the loans. I highly recommend against it, at current pay scales, since it usually is a path to ten years of massive personal debt, but some people don’t mind the huge risk it introduces into their personal finances.

And if I worked for a 141, I’d probably have to keep my mouth shut about that. Running off customers who have already decided debt is fine, isn’t usually a good idea. Maybe a private discussion early on about the real world consequences of huge loans early in life, and that’s it. One talk.

Most younger instructors and staff at 141 schools need every second of flight time they can get, so they can leave to go to a better paying flying job sooner. They’re not going to give sound fiscal or life advice to anyone. That’s just reality, and not a hard knock on them.

There’s even some good to the 141 programs in that the lack of variability and a forced syllabus means there’s at least a bit of a standard for newbie instructors to follow, especially ones with no interest in teaching, long-term. So there’s that, for whatever it’s worth.
 
denverpilot said:
That changes things significantly. You have to fly to their approved syllabus once you choose 141. Their curriculum and syllabus are FAA approved, and if not written to take advantage of certain things, they’re not flexible.

You get some small breaks on the flight time required and other things that the Part 61 folks don’t, including the ability to do it all on massive student loan debt, but the syllabus is essentially “law” once you choose the 141 path.
Click to expand...


that explains everything now! since I am part 141 and school doesn't have another complex aircraft under its name and I am stuck! Switching to part 61 is an option but as you mentioned above it's expensive than 141. So I will have to wait till August 27 and cross my finger for a chance of developing another hurricane which will put me backward another one year!

thanks for everybody, appreciate it!
 
Update: back to the question in the non-141 context. Just last month, there was a Chief Counsel interpretation dealing with this issue in a different context - private pilot ASEL training. One of the questions was whether some of the 40 hours total and 20 hours training could be in a multi. The answer was split based on the language of the regulation. Summarizing (read the 2018 Domingo memo to reach your own conclusion), if the training is "in the areas of operation" for the certificate/rating, it's implicit it must be in the same category and class as the rating sought. If it's not, it does not have to be.

So, the opinion concludes, "Because § 61.1 09(a) requires the 20 hours of flight training from an authorized instructor to cover the areas of operation prescribed in §61.107 (b)(I), the FAA interprets § 61.1 09(a) as requiring the 20 hours of flight training from an authorized instructor to be conducted in a single-engine airplane."

That makes the commercial complex training requirement in a multi raised by the OP problematic since the language of 61.129 makes the 10 hours of complex/TAA/turbine training part of the 61.129(a)(3) "20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part." IOW, it's not just training in a complex airplane, it's training in a complex airplane in the areas of operation required for commercial certificate with an ASEL rating.

I can see some potential wiggle room in applying the Duncan letter to the commercial complex requirement, but I would not rely on it without another Chief Counsel interpretation.
 
Wouldn't it be wonderful if the FAA addressed these concerns and wrote the FARs to actually address them. Nah, guess not.
 
mscard88 said:
Wouldn't it be wonderful if the FAA addressed these concerns and wrote the FARs to actually address them. Nah, guess not.
Click to expand...
Wonderful, yes. Realistic, no. Unfortunately, in the real world, writing regulations and statutes, like everything else, is not a perfect art. There will always be interpretations.

Yeah, in this case, we have regulatory language in the same regulation (and other similar ones) which specifies "in a single engine airplane" or other category/class for certain tasks. That "should" tell us it's not required for other tasks which don't use that terminology. But this isn't the first time the Chief Counsel, IMO, starts with a desired policy result and interprets the regs to fit it. And it won't be the last. Sometimes it works to our benefit; sometimes not.
 
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