Instrument-Helicopter training requirements

[RussR]

This was prompted by a post on askacfi.com, but the question isn't really relevant to that post. Plus, this is a better forum for discussions, whereas that forum is better for just answers.

My question (not really pertinent in any way, more of an academic question) is, "how much instrument training IN A HELICOPTER is an applicant for an Instrument-Helicopter rating required to have?"

This may sound a bit stupid, but 61.65 is a confusingly-written regulation in some ways.

A close reading of 61.65e (pertaining to helicopters, though the wording is similar for airplanes), shows that there are only three requirements that specifically need to be met in helicopters:

10 hours of helicopter XC as PIC
3 hours of training in the last two months in a helicopter.
A 100-nm training XC in a helicopter.

The rest are "total experience" type requirements, that can be met in any type of aircraft.

Notice that 61.65e(2) requires 40 hours of simulated instrument time, "of which 15 hours must have been with an authorized instructor who holds an instrument-helicopter rating".

A literal reading of this does NOT say that the 15 hours have to be in a helicopter, but just that they have to be with a CFI who is an instrument-helicopter instructor. It appears that doing the training in an airplane, but with a dual-rated CFI, would meet the letter of this regulation.

Notice that the wording in 61.65d, for airplanes, is identical (and 61.65f as well).

This seems like the type of thing that would have been brought up to the FAA Chief Counsel, but I searched the interpretations and didn't find anything.

So the way I read it, assuming an applicant already has the 10 XC PIC helicopter hours, then all that is required IN A HELICOPTER is 3 hours of instruction in the last two months, if that 3 hours includes the 100-nm XC. The rest of the training could be done in an airplane.

But this doesn't seem to make a lot of sense (not that the regulations always make sense, of course), so am I missing something?

 

[RussR]

I really didn't think it was THAT dumb of a question...

 

[Velocity173]

Not a dumb question and the FARs aren’t that clear on it. I just always assumed the 15 had to be in a helicopter.

I never really dug into 61.55 much because my initial IFR was helicopter and used military competency. It was a given that my simulated was all helicopter.

 

[Tarheelpilot]

I’m currently dual rated but do not have instrument privileges for helicopter. I’m doing 25 hours of dual in Heli and going straight to the ATP. The question I have for you is do you think it’s prudent not to do the time in a helicopter.

I’m going to the ATP just because I wanted more time under the hood getting trained because the 15 didn’t seem to be enough time . I figured why not.

 

[MauleSkinner]

The obvious interpretation to me is that the requirement for time with an “authorized instructor” implies that the time must be spent in an aircraft for which that authorization is required.

 

[RussR]

The obvious interpretation to me is that the requirement for time with an “authorized instructor” implies that the time must be spent in an aircraft for which that authorization is required.

Perhaps, but that’s not what it says. We have seen repeatedly how when asked for interpretations, the FAA Chief Counsel pretty regularly sticks to an exact, literal reading of the regulations. Examples are the “CFI checkrides don’t reset the Flight Review clock” interpretation that actually took rulemaking action to change, and the “can’t mix and match solo and PDPIC time to meet the 61.129 requirements” that hinges on the placement of the word “or”.

 

[smv]

Looks like three hours, three approaches, and a 100-mile cross country to me...



(2) Forty hours of actual or simulated instrument time in the areas of operation listed under paragraph (c) of this section, of which 15 hours must have been with an authorized instructor who holds an instrument-helicopter rating, and the instrument time includes:

(i) Three hours of instrument flight training from an authorized instructor in a helicopter that is appropriate to the instrument-helicopter rating within 2 calendar months before the date of the practical test; and

(ii) Instrument flight training on cross country flight procedures, including one cross country flight in a helicopter with an authorized instructor that is performed under instrument flight rules and a flight plan has been filed with an air traffic control facility, and involves -

(A) A flight of 100 nautical miles along airways or by directed routing from an air traffic control facility;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.

 

[Tarheelpilot]

Looks like three hours, three approaches, and a 100-mile cross country to me...



(2) Forty hours of actual or simulated instrument time in the areas of operation listed under paragraph (c) of this section, of which 15 hours must have been with an authorized instructor who holds an instrument-helicopter rating, and the instrument time includes:

(i) Three hours of instrument flight training from an authorized instructor in a helicopter that is appropriate to the instrument-helicopter rating within 2 calendar months before the date of the practical test; and

(ii) Instrument flight training on cross country flight procedures, including one cross country flight in a helicopter with an authorized instructor that is performed under instrument flight rules and a flight plan has been filed with an air traffic control facility, and involves -

(A) A flight of 100 nautical miles along airways or by directed routing from an air traffic control facility;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.

The 15 hours from an instructor with helicopter cfi is something I don’t have. I’m going to do all the time in a helicopter. I have plenty of instrument time in airplanes.

 

[MauleSkinner]

Perhaps, but that’s not what it says. We have seen repeatedly how when asked for interpretations, the FAA Chief Counsel pretty regularly sticks to an exact, literal reading of the regulations. Examples are the “CFI checkrides don’t reset the Flight Review clock” interpretation that actually took rulemaking action to change, and the “can’t mix and match solo and PDPIC time to meet the 61.129 requirements” that hinges on the placement of the word “or”.

So your contention would also include the ability for me (an instrument-airplane instructor) to give 10 hours of the 15 instrument training hours required for an instrument-airplane rating in a glider, as I’m also a glider instructor?