Instrument training time toward commercial?

[dell30rb]

Is there any consensus on the use of IR time toward the CPL? I've seen threads on this before but I cannot remember.

The scenario is that I just earned my instrument rating and so, obviously I have recently spent 10 hours of training under the hood with an instructor.

Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

(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 a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

If the time counts, how should it be logged? Is it reasonable to request my instructor to change his entry in my logbook for the flights, to reflect that the work done may be credited to the commercial pilot rating?

Also, those two hour flights must be dual correct? Does the Long IFR x/c (mine was over 2 hours and I landed at a point over 100mi away) count? Any logbook changes necessary here

 

[flyingron]

Any training counts, be it while you were working on another certificate or rating (even the private counts).

I'm not sure what "log book entry" needs to be changed. If the training meets the experience requirements it doesn't need to be specifically tagged as for the commercial certificate.

Training is always "dual" (though it might result in loggable PIC time), it can not be solo.

 

[dell30rb]

If the training meets the experience requirements it doesn't need to be specifically tagged as for the commercial certificate.

Thanks. I was unsure. My instructor probably over does his log entries.

Reading better would have helped. I re-read the requirements and see that the two hour flights are under the subheading of "training" There is a solo x/c requirement listed later.

 

[JeffDG]

Yep...it counts.

One question on the private time...does it count if the instructor is only a CFI or does the instructor need to be a II to give "instrument instruction".

One point to note...this is only simulated instrument time...it doesn't count if it's actual:

Ten hours of instrument training using a view-limiting device

Oh, and before someone says it...I think it's a stupid distinction too, but the way the reg is worded is pretty clear.

 

[bobmrg]

Yep...it counts.

One question on the private time...does it count if the instructor is only a CFI or does the instructor need to be a II to give "instrument instruction".

One point to note...this is only simulated instrument time...it doesn't count if it's actual:

Oh, and before someone says it...I think it's a stupid distinction too, but the way the reg is worded is pretty clear.

The three hours of flight training required by 61.109 for the private pilot certificate can be administered by any CFI...because it is not instrument training.

Bob Gardner

 

[flyingron]

The three hours of flight training required by 61.109 for the private pilot certificate can be administered by any CFI...because it is not instrument training.

And as well, the non CFII is not authorized to give the instrument instruction required for the commercial rating:

(c) Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.
​

 

[Greg Bockelman]

And as well, the non CFII is not authorized to give the instrument instruction required for the commercial rating:

(c) Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.
​

You misread that. That is two different sections. The first part is that the CFI must be instrument rated. (I know, I know. Aren't CFI's supposed to be instrument rated? But there MAY be one or two left that got their certificates before an instrument rating became mandatory.)

The second part is that the CFI must hold Category and Class of the airplane being instructed in.

 

[poadeleted20]

Any training counts, be it while you were working on another certificate or rating (even the private counts).

Not so. The training for the PP is not "instrument flight training," and so does not count towards the 61.129(a)(3)(i) requirement for 10 hours of instrument flight training. The PP training is by regulation "flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight." It counts as simulated instrument time towards the 40 hours of total instrument time for the IR, but it does not count towards either the 15 hours of instrument flight training required for the IR or the 10 hours of instrument flight training required for the CP. This does not change even if the instructor giving the PP training holds an IA rating on his/her CFI.

That does not stop a CFI-IA from giving additional training to a pre-PP trainee that is "instrument flight training" above and beyond the 61.109(a)(3) requirement and have that count for IR or CP, but it would have to be clearly logged as such, and would not count for the PP requirement.

I'm not sure what "log book entry" needs to be changed. If the training meets the experience requirements it doesn't need to be specifically tagged as for the commercial certificate.

Sort of true. To count for the CP instrument training requirement, the instrument flight training must specifically be in the areas of "attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems." That (or a reference to 61.129(a)(3)(i)) would have to be in the Remarks of the logbook entry of the instrument flight training given by an instrument flight instrument instructor if those hours are to count for the CP requirement.

See the Hartzell interpretation which clarified the Theriault interpretation.

 

[flyingron]

You misread that. That is two different sections. The first part is that the CFI must be instrument rated. (I know, I know. Aren't CFI's supposed to be instrument rated? But there MAY be one or two left that got their certificates before an instrument rating became mandatory.)

The second part is that the CFI must hold Category and Class of the airplane being instructed in.

No, I don't believe I am. The passage clearly requires the appropriate instrument rating (for whatever class you're in) on both the instructors PILOT and INSTRUCTORS certificates.

A non-II CFI can not give the ten hours of instrument instruction required for the commercial.

 

[poadeleted20]

No, I don't believe I am. The passage clearly requires the appropriate instrument rating (for whatever class you're in) on both the instructors PILOT and INSTRUCTORS certificates.

A non-II CFI can not give the ten hours of instrument instruction required for the commercial.

FRon is correct. Those ten hours of instrument flight training must be given by a CFI with both aircraft and instrument ratings on his/her CFI ticket. It is the specific definition of the training for PP in 61.109(a)(3) which says that the training for PP is not "instrument flight training" that allows a CFI with only an aircraft rating to give that training, and that fact is why that training cannot be used for the CP or IR "instrument flight training" requirements. This was discussed in the NPRM and preamble to the FR which made that change in wording in 61.109.

 

[flyingron]

Not so. The training for the PP is not "instrument flight training," and so does not count towards the 61.129(a)(3)(i) requirement for 10 hours of instrument flight training. The PP training is by regulation "

Correct, it's not instrument training, just training for flight by reference to instruments (unless it was given as instrument training by a II, I suppose). I was thinking more along the lines of the cross countries.

 

[poadeleted20]

Correct, it's not instrument training, just training for flight by reference to instruments (unless it was given as instrument training by a II, I suppose).

Doesn't matter who gives it -- training to meet 61.109(a)(3) is not "instrument flight training."

 

[Greg Bockelman]

FRon is correct.

Oh for the lack of a comma. But frankly, that doesn't make much sense to me. Pretty much means a non instrument CFI can't give ALL the training for the Commercial cert. But not many people get teh commercial without the instrument rating so it is kind of moot anyway.

 

[Jaybird180]

Not so. The training for the PP is not "instrument flight training," and so does not count towards the 61.129(a)(3)(i) requirement for 10 hours of instrument flight training. The PP training is by regulation "flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight." It counts as simulated instrument time towards the 40 hours of total instrument time for the IR, but it does not count towards either the 15 hours of instrument flight training required for the IR or the 10 hours of instrument flight training required for the CP. This does not change even if the instructor giving the PP training holds an IA rating on his/her CFI.

So the 3hrs PP hood time counts toward the 40 for the IR, but not the 15 for the IR, nor the 10 for the CP????WHAT????

 

[flyingron]

So the 3hrs PP hood time counts toward the 40 for the IR, but not the 15 for the IR, nor the 10 for the CP????WHAT????

Yes, the 40 hours is just instrument time. It doesn't need to be any form of training or instruction.

I correct my statements on using other time. The absolutely unsupported by the regulations inane opinions in Theriault preclude using training for the commercial that wasn't specifically being targeted for that rating. This is one of those completely idiotic places where if they wanted it to work that way, they should darn well go through the proper regulatory process to enact it not pulling decisions out of their posterior.

If they want to make all the aeronautical experience specific for the commercial beyond what is literally written, they should have added the caveat as exists in other places that say things like "in preparation for the flight test."

 

[poadeleted20]

Oh for the lack of a comma. But frankly, that doesn't make much sense to me. Pretty much means a non instrument CFI can't give ALL the training for the Commercial cert.

Correct.

But not many people get teh commercial without the instrument rating so it is kind of moot anyway.

Agreed.

 

[poadeleted20]

So the 3hrs PP hood time counts toward the 40 for the IR, but not the 15 for the IR, nor the 10 for the CP????

Correct.

 

[poadeleted20]

The absolutely unsupported by the regulations inane opinions in Theriault preclude using training for the commercial that wasn't specifically being targeted for that rating. This is one of those completely idiotic places where if they wanted it to work that way, they should darn well go through the proper regulatory process to enact it not pulling decisions out of their posterior.

AFS did write the regs that way. AGC explained it badly in Theriault, but they re-explained it better in Hartzell. At the end of the day, it's all about proper training documentation, about which the FAA is getting strict. Document the training properly, and there's no problem. Document it sloppily, and they won't let it count.

 

[Jaybird180]

Can the 61.65 250nm XC be performed using Direct To or GPS waypoints?

 

[poadeleted20]

Can the 61.65 250nm XC be performed using Direct To or GPS waypoints?

The choice of navigational means is up to the trainee and instructor as long as you do three different types of approaches. Of course, the route will have to be acceptable to ATC since it must be done under IFR.

 

[Jaybird180]

I'm specifically asking about wherein it says that it must be on an airway or ATC routing.

 

[dell30rb]

A GPS clearance would qualify as "ATC Routing". So long as you are on an IFR clearance / flight plan during your flight. Basically I guess the wording is only there to keep folks from flying around willy nilly in class G and calling it an IFR flight.

 

[poadeleted20]

A GPS clearance would qualify as "ATC Routing".

Yup..