Previous IFR Training Used for Commercial Interpretation

Discussion in 'Flight Following' started by Skid, Jan 7, 2019.

  1. Skid

    Skid Pre-takeoff checklist

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    I start my commercial training soon and have been getting my logbook in order to see what I specifically need to knock out per the regs.

    The one regulation that has me hung up is the:

    "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"

    I've been doing some research on forums to get a general consensus and recently read the Hartzell letter to get an idea of what counts, but I'm still a bit unsure...It seems like most DPEs don't really care, but the letter seems to imply the logbook entry needs to state it's for 61.129.

    All the stuff I could find was from 2010 so I'm wondering if there is any other updated information out there or if the common culture says my former time is acceptable. I have 64 hours of simulated IFR training between helicopters and airplanes, so it seems a bit silly to tack on 10 more. But if it's what I have to do I'll do it.

    Thanks
     
  2. AmazonChitlin

    AmazonChitlin Pre-takeoff checklist

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    If you have previous time under the hood I'm sure that would work. Your CFI will probably do some hood work with you to ensure you're still good to go before your appointment with the DPE.

    Just curious, why not get your instrument while working on your commercial? Kill two birds with one stone

    Sent from my SM-N960U using Tapatalk
     
  3. Skid

    Skid Pre-takeoff checklist

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    Yea that's my fault for not really reading into the commercial regs ahead of time to plan accordingly. I could have ensured some of the stuff we did was notated appropriately for both.
     
  4. CC268

    CC268 Final Approach

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    Well...my time from the IR worked. Just took my CSEL in November.
     
  5. BrianNC

    BrianNC Pattern Altitude

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    Same here. Used IR time for commercial, and got CSEL in September.
     
  6. BrianNC

    BrianNC Pattern Altitude

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    You're good. No need to tack on another 10.
     
  7. KaiGywer

    KaiGywer Pre-takeoff checklist

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    I think that requirement is only listed because some people decide to get their commercial before their instrument rating and need the hood time.
     
  8. RussR

    RussR Cleared for Takeoff

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    For a commercial? I have never felt the need to do hood work with a Commercial applicant.
     
  9. midlifeflyer

    midlifeflyer Final Approach

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    Personal opinion only.

    The Hartzell interpretation only requires that the training covers the 61.129 tasks and be logged. No different than the requirement that the tasks required for the instrument rating under 61.65 be performed and logged. Unless the CFII screwed up, a pilot's training of record for the IR is going to have the same task descriptions as required for the commercial.
     
  10. genna

    genna Cleared for Takeoff

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    I'm about to do a Comm ride and my DPE wanted 10 hours of my instrument training(i have IR) annotated with 61.129 by original CFII. Since the CFII has moved long ago, an email to him with list of flights(and specific maneuvers required) and his reply with signature "certifying" that all those flights were for 61.129 training is sufficient(according to my flight school).

    EDIT: This seems completely silly to me as having IR effectively requires me to complete all that training and there is no difference in Private IR or Commercial IR. This is just a paper exercise for me. But the DPE wants to do it by the book and views FAA's interpretation letter as such.
     
    Last edited: Jan 8, 2019
  11. Unit74

    Unit74 Final Approach

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    It is silly... the requirements intent is aimed at commercial pilots with no IR.
     
  12. midlifeflyer

    midlifeflyer Final Approach

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    It is silly. Did he also want to make sure they specifically mentioned "61.65" to be sure the instrument rating was proper? And that all the pre-private tasks specifically mentioned 61.109?

    I guess different people interpret interpretations in different ways, but "We are merely clarifying the requirement that the applicant for a commercial pilot certificate provide evidence that they have met the requirements of §61.129" (the exact language from Hartzell) doesn't sound like it is necessary to say "61.129" any more than it is necessary to say "61.65" or "61.109" in entries for primary or instrument training. Post Hartzell, it has become customary for some instructors to do so as an easy way of compliance, and apparently some DPEs are looking for it, but that doesn't mean it is required.
     
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  13. BrianNC

    BrianNC Pattern Altitude

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    Ridiculous. Just requiring things that aren’t there.

    Exactly.
     
  14. genna

    genna Cleared for Takeoff

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    I don't really want to argue about validity of my DPE opinion. I haven't read the FAA's letter in question. On the face of it this is pretty silly, but it wouldn't be the first silly thing FAA required. This was a pretty easy thing for me to resolve. And I am not going to argue about regulations with a DPE before taking a test with him if it's not affecting me in the least. I wrote my post only to indicate that it is possible that OP is asked to do the same by his DPE. He should be ready for that or verify that he doesn't have to do it with his DPE.
     
  15. midlifeflyer

    midlifeflyer Final Approach

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    Here you go. 2011 Hartzell letter.

    You may have intended it as a discussion of what a DPE might do. But DPEs can be wrong too, and any time in forums on any regulatory subject should demonstrate the odds are very high discussion will surround what the rules actually are. Your desire not to argue is commendable, but doesn't stop that.

    I'm reminded of the short series of articles in the old Designee Update periodical (dunno if it is still in existence) about holds. It started with an article in which DPEs are informed they cannot fail an applicant for using the "wrong" holding entry so long as they stay within protected airspace. Eventually there was another article on the same subject saying, in essence, "We really mean it! You cannot fail an applicant for using the "wrong" holding entry so long as they stay within protected airspace. So stop doing it!"

    No one should argue with a DPE while taking a test. Even if a DPE is 180 degrees off, the proper response is, "Oh, I didn't know that. Thank you."
     
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  16. Skid

    Skid Pre-takeoff checklist

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    Thanks for all the input everyone, sounds like it should all count. In the same vein do you think the long xc required during the instrument training would also count for this:

    (Edit: The first leg of the IFR xc flight I did was over 100nm)

    "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;"

    Don't want to push my luck per say, but it would be nice to save some money on the relatively pointless crossing country flights with an instructor just sitting there.
     
  17. midlifeflyer

    midlifeflyer Final Approach

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    It can. It has never been uncommon for one to work on both at the same time — Jepp even has a syllabus and coursebook that combines the two. It's easier since the FAA dropped the requirement some years back that the commercial dual cross countries are exclusively visual.

    The instrument training question was an easy one. The tasks are the same. The key and the challenge for the cross country is that the "areas of operation" for the instrument and the commercial are different. (The FAA uses the “areas of operation” language to differentiate requirements, and it is used both literally and qualitatively — e.g., commercial pilot level tasks are presumed to be qualitatively different from student pilot level tasks.)

    Ideally, you and your CFI can come up with a plan that covers “the areas of operation” in 61.65(c), and the “areas of operation” in 61.127(b)(1). That's going to take some creative planning and your CFI's willingness to go on record and say as part of the instrument cross country flight lesson endorsement that it met the requirements of both 61.65 and 61.129. In this case, if I were doing it, I would specifically reference the two sections.