Crediting past experience toward commercial

[VA Aviator]

For background, I just flew for the first time since 2008. Prior to this, I was very very familiar with the regs, LOIs, FAA orders, ACs and more. However, I stopped flying and paying attention to the changes.

NOW - I'm getting back into it, with the goal of getting my commercial certificate. I was going through my logbooks and trying to figure out what I did and didn't have. I noticed a few changes - the biggest one I noticed being that you don't have to do the 300NM trip solo and can now do that with an instructor.

I also started looking around and came across a few things that seem to have changed. See here:

http://www.askacfi.com/7513/can-ins...rds-commercial-cross-country-requirements.htm

This could seriously screw me. Specifically:

I'm instrument rated. I've got 10+ hours of training in actual and simulated IMC.
I had a 4 hour round robin cross country flight with an instructor in day VFR (partially simulated instrument) in 2004
I had a 3.2 hour round robin cross country flight with an instructor in night VFR (partially simulated instrument) in 2003


So, am I OK to credit this time toward my commercial certificate, or did this whole venture just go up in price to the tune of $2,000?

 

[Sam D]

Folks should be by shortly with the facts, but I believe the instrument time is good. On the cross countries, it matters whether this was for your private or not. If it was, I don't believe they work.

 

[Z06_Mir]

As long as it was logged correctly it will work.

 

[BillTIZ]

As long as it was logged correctly it will work.

What that means, ? the time should behave been logged to meet the traing level of 61.127(b)(1). Flying to commercial standards, not private standards.

 

[NineThreeKilo]

For background, I just flew for the first time since 2008. Prior to this, I was very very familiar with the regs, LOIs, FAA orders, ACs and more. However, I stopped flying and paying attention to the changes.

NOW - I'm getting back into it, with the goal of getting my commercial certificate. I was going through my logbooks and trying to figure out what I did and didn't have. I noticed a few changes - the biggest one I noticed being that you don't have to do the 300NM trip solo and can now do that with an instructor.

I also started looking around and came across a few things that seem to have changed. See here:

http://www.askacfi.com/7513/can-ins...rds-commercial-cross-country-requirements.htm

This could seriously screw me. Specifically:

I'm instrument rated. I've got 10+ hours of training in actual and simulated IMC.
I had a 4 hour round robin cross country flight with an instructor in day VFR (partially simulated instrument) in 2004
I had a 3.2 hour round robin cross country flight with an instructor in night VFR (partially simulated instrument) in 2003


So, am I OK to credit this time toward my commercial certificate, or did this whole venture just go up in price to the tune of $2,000?

From my understanding a CFI can ride with you on that solo 300nm (which is a odd thing to begin with), guess this was for insurance reasons. HOWEVER it can't be dual instruction, they are just their as a safety net for the owner/FBO/whatever, NOT to teach you anything.

Thus if you logged any dual time on those flights, you CANT count it
If you logged NO dual time you CAN log it.

 

[Z06_Mir]

From my understanding a CFI can ride with you on that solo 300nm (which is a odd thing to begin with), guess this was for insurance reasons. HOWEVER it can't be dual instruction, they are just their as a safety net for the owner/FBO/whatever, NOT to teach you anything.

Thus if you logged any dual time on those flights, you CANT count it
If you logged NO dual time you CAN log it.

Correct, but the CFI has to sign it with with appropriate documentation that he wasn't giving dual. Again, it's all in how it was logge.

What that means, ? the time should behave been logged to meet the traing level of 61.127(b)(1). Flying to commercial standards, not private standards.

Correct. It needs to be logged and noted that the flight met 61.129(a)(3)(iii/iv)

 

[VA Aviator]

hmm, interesting.

The two cross countries mentioned in my OP were in pursuit of my instrument rating. The only remarks in the comments were things like "ILS 33, NDB 27, sim inst" and I take it this won't suffice.

Does this mean I need to take a look at the FAA database for these guys and write a couple of letters to see if they would be willing to add additional information to my logbook?

 

[Henning]

Why not just fly the cross countries? You're gonna have to tune up your flying anyway to pass the Commercial checkride anyway.

 

[midlifeflyer]

Some is clear; some is maybe. Someone else can list them but there are a number of Chief Counsel opinions on the subject.

As background, Part 61 uses "on the areas of operation" language to identify tasks that are certificate or rating specific as opposed to general experience requirements.

It's pretty clear that certificate/rating-specific tasks done for the private can't count toward certificate/rating-specific tasks for the commercial, even if the tasks themselves sound similar or identical. So, for example, a very long solo cross country as a student pilot cannot count as the commercial solo cross country.

OTOH, instrument rating tasks might count toward similar commercial tasks so long as they are properly logged - in a way that identifies them as fitting both. The FAA is on record about this when it comes to crediting the instrument training for the instrument ratings toward the instrument training requirements for the commercial certificate.

But that one's pretty obvious and I'd have no hesitancy going back and amending my endorsement of the flight in a student's logbook entry. OTOH, I'd hesitate a and have to think a bit more before saying that an IFR cross country also accomplished 61.127 tasks.

Here you may have an additional problem: timing. If the instrument cross countries were done at a time when the commercial requirement was for dual VFR flights, I'd likely have a problem going back to say, "oh yeah, it also met the requirements that were going to be in the commercial some unknown time in the future.

But that's just one guy's personal opinion. YMMV.

 

[dell30rb]

As far as I know, its fine to use x/c's during your instrument training towards the commercial certificate if the flight meets the right requirements. I used my long IFR dual x/c towards one of them.

 

[NineThreeKilo]

hmm, interesting.

The two cross countries mentioned in my OP were in pursuit of my instrument rating. The only remarks in the comments were things like "ILS 33, NDB 27, sim inst" and I take it this won't suffice.

Does this mean I need to take a look at the FAA database for these guys and write a couple of letters to see if they would be willing to add additional information to my logbook?

The OP was asking about the 300nm "Solo" x-country
Where you can bring a CFI along with you, JUST ONY IN THE CAPACITY OF A SAFTEYNET, BUT NOT FOR INSTRUCTION.


It's really easy,

Look in your logbook, did your CFI put any time in your "Dual Recieved" column???

If he did then it was DUAL and you CAN'T log it regardless of what he signs or writes you, unless you want to white it out of the dual column and risk having your tickets pulled for BSing.

If he DID NOT put any time in the dual column then it aint dual and you're good to count it towards your CPL 300nm.

It's not complicated, look in your "Dual Receved"'box for those flight and there's your answer

 

[Henning]

The OP was asking about the 300nm "Solo" x-country
Where you can bring a CFI along with you, JUST ONY IN THE CAPACITY OF A SAFTEYNET, BUT NOT FOR INSTRUCTION.


It's really easy,

Look in your logbook, did your CFI put any time in your "Dual Recieved" column???

If he did then it was DUAL and you CAN'T log it regardless of what he signs or writes you, unless you want to white it out of the dual column and risk having your tickets pulled for BSing.

If he DID NOT put any time in the dual column then it aint dual and you're good to count it towards your CPL 300nm.

It's not complicated, look in your "Dual Receved"'box for those flight and there's your answer

Might also want to see what the instructor logged in his logbook for that flight, when the FAA goes digging, they dig hard.

 

[NineThreeKilo]

Might also want to see what the instructor logged in his logbook for that flight, when the FAA goes digging, they dig hard.

I highly doubt the FAA would be interested, just needs to show a DPE that he has the reqs for the CPL


As for the CFIs logbook, that's the CFIs problem, if he didn't put dual in the students logbook (which he signed) it ain't dual.
That's regardless with whatever the CFI wrote in his logbook, diary or told his mom :wink2:

Like I said ALL the answers to the OPs question are in the dual column of his logbook right now.

 

[VA Aviator]

The OP was asking about the 300nm "Solo" x-country
Where you can bring a CFI along with you, JUST ONY IN THE CAPACITY OF A SAFTEYNET, BUT NOT FOR INSTRUCTION.


It's really easy,

Look in your logbook, did your CFI put any time in your "Dual Recieved" column???

If he did then it was DUAL and you CAN'T log it regardless of what he signs or writes you, unless you want to white it out of the dual column and risk having your tickets pulled for BSing.

If he DID NOT put any time in the dual column then it aint dual and you're good to count it towards your CPL 300nm.

It's not complicated, look in your "Dual Receved"'box for those flight and there's your answer

Actually, that's not one I am worried about, because I've not done that long of a trip, dual or solo, I just mentioned it as one of the changes I noticed.

My question is in regard to three specific items that I listed at the bottom. More details when I'm at a real computer, but I wanted to clarify that for now.

 

[Henning]

I think it's a bust since you did partially simulated IMC on them.

 

[poadeleted20]

I'm instrument rated. I've got 10+ hours of training in actual and simulated IMC.

That should count for the 10 hours of instrument time required for the Commercial Pilot as long as the remarks show that in included "attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," as it says in 61.129(a)(3)(i).

I had a 4 hour round robin cross country flight with an instructor in day VFR (partially simulated instrument) in 2004
I had a 3.2 hour round robin cross country flight with an instructor in night VFR (partially simulated instrument) in 2003

Insufficient data. Did each of those flights go somewhere more than 100 miles straight-line distance from the original point of departure, and is that documented in the log entry? You don't need to have a landing at that point, but you must have gotten more than 100nm away (as well as the usual landing more than 50nm from the departure point).

 

[poadeleted20]

Thus if you logged any dual time on those flights, you CANT count it

Not so. The key is that the instructor signs the logbook saying the flight meets the requirement of 61.129(a)(4)(i). However, I believe the OP was asking about those two earlier flights meeting the two day/night dual XC flight requirements in 61.129(a)(3)(iii/iv), and that is easier to document.

 

[poadeleted20]

The two cross countries mentioned in my OP were in pursuit of my instrument rating. The only remarks in the comments were things like "ILS 33, NDB 27, sim inst" and I take it this won't suffice.

I don't think that matters other than showing how far you went from home, i.e., that one of those approaches (which, per 61.51(g)(3)(i), should be logged with the location as well as the type of approach) was more than 100nm from home. In applying those flights to the 61.129(a)(3)(iii/iv) requirements, the documentation need only show that it was a "2-hour cross country flight in a single engine airplane in daytime/nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure." Beyond that, it doesn't matter. So, as long as it shows the whole flight was day or the whole flight was night, and there was something showing you landed more than 50nm from the original point of departure and did something more than 100nm from the original point of departure, you've got that part covered, and you don't need to contact the instructors involved.

Now, as for applying one of those flights to the 61.129(a)(4)(i) solo/simulated solo requirement, no, it won't do at all, and probably can't be retro-documented to count.

 

[poadeleted20]

The OP was asking about the 300nm "Solo" x-country
Where you can bring a CFI along with you, JUST ONY IN THE CAPACITY OF A SAFTEYNET, BUT NOT FOR INSTRUCTION.


It's really easy,

Look in your logbook, did your CFI put any time in your "Dual Recieved" column???

If he did then it was DUAL and you CAN'T log it regardless of what he signs or writes you, unless you want to white it out of the dual column and risk having your tickets pulled for BSing.

If he DID NOT put any time in the dual column then it aint dual and you're good to count it towards your CPL 300nm.

It's not complicated, look in your "Dual Receved"'box for those flight and there's your answer

Where in the regulations did you find this? Unless you log it as "solo", the thing that matters is that the instructor certified the flight as meeting the requirements of 61.129(a)(4)(i). Whether or not "training time" was logged does not affect this matter, and if you don't log it as solo (which you can't do if that instructor was aboard), you will not be able to count it without that instructor certification.

 

[NineThreeKilo]

Where in the regulations did you find this? Unless you log it as "solo", the thing that matters is that the instructor certified the flight as meeting the requirements of 61.129(a)(4)(i). Whether or not "training time" was logged does not affect this matter, and if you don't log it as solo (which you can't do if that instructor was aboard), you will not be able to count it without that instructor certification.

Check out the link in the OPs first post.

 

[poadeleted20]

Check out the link in the OPs first post.

I see nothing there from the FAA which says what you said (that if it's logged as dual, it absolutely cannot count for 61.129(a)(4)(i)). Perhaps you can point it out?

 

[NineThreeKilo]

Ive always just had my students fly the damn things solo and plan ahead a little, no biggie.

It's been a long time since I had to deal with this, I had one student dead set to do his 300nm in a plane he didn't have enough hours to rent solo, I remember something about dual...

Off the link that was in that link

(4) Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under §*61.127(b)(1) that include—

(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. 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

I think there was a FAA letter about the dual thing, not feeling like tryin to hunt it down on my iPhone though, maybe when I'm at my real computer

 

[VA Aviator]

That should count for the 10 hours of instrument time required for the Commercial Pilot as long as the remarks show that in included "attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems," as it says in 61.129(a)(3)(i).

Insufficient data. Did each of those flights go somewhere more than 100 miles straight-line distance from the original point of departure, and is that documented in the log entry? You don't need to have a landing at that point, but you must have gotten more than 100nm away (as well as the usual landing more than 50nm from the departure point).

Ok -the Night flight sez:
K**P-K**A-K**P (121 NM) 2 Landings 2 approaches
"ILS 33 K**A, GPS 16 K**P IFR XC ***" [CFI sig]
3.2 Cross country 3.2 Night 2.7 Sim Instrument 3.2 Dual 3.2 PIC 3.2 total

The Day flight says:
K**I-K**M-K**I (188 NM) 2 landings 2 approaches
"ILS 35 @ K**M, NDB 33 @ K**I" [CFI sig]
4.0 Cross Country 4.0 Day 2.9 Sim Instrument 4.0 dual 4.0 PIC 4.0 Total


Most of my instrument stuff does NOT say what you said "verbatim" but rather lists approaches, things like holds, dme arcs, procedure turns, vectors, partial panel if that was done, unusual attitudes if they were done, etc. So I would THINK this would be sufficient for most examiners to conclude that this would work.

I have no idea if I have 10 night landings in the traffic pattern of a controlled airport, so I'm just going to go do that. The night landings are something I would want to take advantage of a CFI for - Go get night current by flying to a nearby controlled airport and do the landings there.

 

[poadeleted20]

Ok -the Night flight sez:
K**P-K**A-K**P (121 NM) 2 Landings 2 approaches
"ILS 33 K**A, GPS 16 K**P IFR XC ***" [CFI sig]
3.2 Cross country 3.2 Night 2.7 Sim Instrument 3.2 Dual 3.2 PIC 3.2 total

The Day flight says:
K**I-K**M-K**I (188 NM) 2 landings 2 approaches
"ILS 35 @ K**M, NDB 33 @ K**I" [CFI sig]
4.0 Cross Country 4.0 Day 2.9 Sim Instrument 4.0 dual 4.0 PIC 4.0 Total

Then if one of those airports listed is more than 100nm straight line distance from the original point of departure and you have documented that you made a landing more than 50nm from the original point of departure (what you posted doesn't make clear where the second landing on each flight was), those should suffice for the two dual XC's. However, if you don't have a logged landing 50nm away from home on those flights, they aren't even XC time for this purpose, no less covering those two dual XC's. This is one reason why when we do an out-and-back on training flights, I log it in the trainee's log on two lines (one out, one back) so there is no doubt that the other landing occurred more than 50nm from the original point of departure.

Most of my instrument stuff does NOT say what you said "verbatim" but rather lists approaches, things like holds, dme arcs, procedure turns, vectors, partial panel if that was done, unusual attitudes if they were done, etc. So I would THINK this would be sufficient for most examiners to conclude that this would work.

I think so, too.

 

[VA Aviator]

Then if one of those airports listed is more than 100nm straight line distance from the original point of departure and you have documented that you made a landing more than 50nm from the original point of departure (what you posted doesn't make clear where the second landing on each flight was), those should suffice for the two dual XC's. However, if you don't have a logged landing 50nm away from home on those flights, they aren't even XC time for this purpose, no less covering those two dual XC's. This is one reason why when we do an out-and-back on training flights, I log it in the trainee's log on two lines (one out, one back) so there is no doubt that the other landing occurred more than 50nm from the original point of departure.

I think so, too.

Yes, they were out and back with landings at the destination and the originating airport.

Now, one last point - I will likely attempt to regain night currency soon, obviously with an instructor. If possible, I would like to "double up" by doing some/all of the landings at a controlled airport. How should this be logged?

 

[poadeleted20]

Now, one last point - I will likely attempt to regain night currency soon, obviously with an instructor. If possible, I would like to "double up" by doing some/all of the landings at a controlled airport. How should this be logged?

Log what you fly per 61.51, and have the instructor sign with remarks "61.129(a)(4)(ii) night flight".

 

[MikeELP]

I see nothing there from the FAA which says what you said (that if it's logged as dual, it absolutely cannot count for 61.129(a)(4)(i)). Perhaps you can point it out?

As long as the student does not apply those dual hours to the 61.129(a)(3)requirements, I concur with Ron.

The dual hours in such a situation are pretty much worthless since they cannot be counted toward the needed 20 hours of commercial training, but they can still be logged as dual.

To add...by actually receiving dual instruction it does however totally defeat the spirit of the reg since the CFI should be onboard for nothing more than being an observer/insurance ballast or as 93K said, a "safety net". It is intended to be treated as "solo time" with the CFI onboard, but not actually providing instruction.

Mike

 

[poadeleted20]

To add...by actually receiving dual instruction it does however totally defeat the spirit of the reg since the CFI should be onboard for nothing more than being an observer/insurance ballast or as 93K said, a "safety net". It is intended to be treated as "solo time" with the CFI onboard, but not actually providing instruction.

The key on that is the instructor's signature next to the remark saying "61.129(a)(4)(i) long XC".

Document, document, document...