Using previous complex time for commercial requirements

ujocka

ujocka

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ujocka
Hello,

I am currently working on my commercial-SEL rating and want to know if I can use my previous 40 hours of complex time to meet the 10 hour complex requirement. I currently hold PPL-single/multi and instrument-SEL. My multi is VFR only.

I am part owner of a 182 straight leg and would prefer to only rent a retract for an hour or two of practice and the checkride. Renting the retract will run me 2x the cost. Thanks in advance for your answers.
 
61.129:
(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;

Now, this means ten hours of TRAINING in a complex airplane (single or multi). You undoubtedly got some training in a complex for your complex endorsement, or checkout, or whatever. If you don't have ten hours, though, you'll have to get however-much dual is required to come up to ten hours.

Put another way, your PIC/SOLO time in a complex doesn't count. It must be logged as dual/training time.
 
Wouldn't all of my multi-engine training fulfill this requirement? I have approx 15 hours dual between the initial rating and checkouts. I also have checkouts (dual) in single complex amounting to at least another 5 hours.
 
ujocka said:
Wouldn't all of my multi-engine training fulfill this requirement? I have approx 15 hours dual between the initial rating and checkouts. I also have checkouts (dual) in single complex amounting to at least another 5 hours.
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Assuming your multi had retractable gear, sure.
 
TMetzinger said:
Put another way, your PIC/SOLO time in a complex doesn't count. It must be logged as dual/training time.
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The fact that it's PIC time doesn't matter, as most folks already have their PP-ASEL when they get their first complex training in an ASEL aircraft, and so can log that training as both training and PIC time. However, solo clearly doesn't count since that means there's no instructor aboard, hence, no training.
 
ujocka said:
Wouldn't all of my multi-engine training fulfill this requirement? I have approx 15 hours dual between the initial rating and checkouts.
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Yes, it would. The original responders apparently assumed you were just PP-ASEL, not also AMEL. In fact, several university professional pilot programs using Diamond aircraft do the initial CP as AMEL in the complex DA-42 TwinStar and then do the additional ASEL rating in the fixed gear DA-40 DiamondStar.
 
Plenty of ways to skin that cat.

Heck I did my initial CPL in a floatplane and my land add on in a Champ, initial multi was my ATP.

From my understanding as long as you have 10'hours of dual all in on anything considered complex you're golden.
 
I've always disagreed with the common definition of "training" in the reg, as unless I am mistaken, that word isn't defined in the FARs.

I'd rather that term include training flights done solo, like practicing landings solo.
 
Ron Levy said:
The fact that it's PIC time doesn't matter, as most folks already have their PP-ASEL when they get their first complex training in an ASEL aircraft, and so can log that training as both training and PIC time. However, solo clearly doesn't count since that means there's no instructor aboard, hence, no training.
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Finished my commercial recently. Instructor said i couldn't log complex time as PIC until I had the complex endorsement since i would be unable to legally fly the aircraft without him onboard.
 
FlyingJ said:
Finished my commercial recently. Instructor said i couldn't log complex time as PIC until I had the complex endorsement since i would be unable to legally fly the aircraft without him onboard.
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:no:

The "How do I log this?" can of worms has just been opened....
 
ujocka said:
Hello,

I am currently working on my commercial-SEL rating and want to know if I can use my previous 40 hours of complex time to meet the 10 hour complex requirement. I currently hold PPL-single/multi and instrument-SEL. My multi is VFR only.

I am part owner of a 182 straight leg and would prefer to only rent a retract for an hour or two of practice and the checkride. Renting the retract will run me 2x the cost. Thanks in advance for your answers.
Click to expand...

One other thing that maybe you didn't think of: most of the requirements of the commercial PTS do not require a complex airplane and you are allowed to furnish multiple aircraft for the practical. You may want to consider doing the bulk of the items in your Sky Lane and finishing the check ride in a complex.
 
FlyingJ said:
Finished my commercial recently. Instructor said i couldn't log complex time as PIC until I had the complex endorsement since i would be unable to legally fly the aircraft without him onboard.
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Your instructor is an idiot. This is about one of the easiest of the "how do I log tbis" questions and your CFI should know better.

You can't act as PIC, but you can log it as the sole manipulator.
 
FlyingJ said:
Finished my commercial recently. Instructor said i couldn't log complex time as PIC until I had the complex endorsement since i would be unable to legally fly the aircraft without him onboard.
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Your instructor is wrong, this is a common misconception. You may log PIC time in anything you are rated for (while sole manipulator of the controls). Endorsements do not matter.

Say you flew two hours with your instructor before he signed you off for the complex endorsement. You would log 2 hours dual and 2 hours PIC for those training flights.

Go back in your logbook and pencil in your PIC time.
 
dell30rb said:
Your instructor is wrong, this is a common misconception. You may log PIC time in anything you are rated for (while sole manipulator of the controls). Endorsements do not matter.

Say you flew two hours with your instructor before he signed you off for the complex endorsement. You would log 2 hours dual and 2 hours PIC for those training flights.

Go back in your logbook and pencil in your PIC time.
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Heck, put it in pen! If the instructor ******* about it, have him google "faa.gov:herman", read the letter then tell you that it's not allowed.

Your letter presents a scenario in which a pilot, who holds a private pilot certificate with an aircraft single engine land rating but does not have endorsements for high-performance or complex airplanes required by 14 CFR §§ 61.31(e)-(f) to act as PIC, is flying in a high-performance and complex airplane. Another pilot, who has those endorsements, is acting as PIC for the flight. Your letter asks whether the pilot lacking the endorsements may log PIC time for the time that pilot is the sole manipulator of the controls....

Accordingly, in your examples, the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as PIC.
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hook_dupin said:
One other thing that maybe you didn't think of: most of the requirements of the commercial PTS do not require a complex airplane and you are allowed to furnish multiple aircraft for the practical. You may want to consider doing the bulk of the items in your Sky Lane and finishing the check ride in a complex.
Click to expand...

The examiner had me complete the short and soft field takeoff and landing, and the power-off 180 in the complex. Although i had not really practiced those tasks in it (expecting a quick trip or two around the pattern for complex operation), the aircraft (182RG vs 182) were similar enough that i completed them successfully. Everything else was in my 182.

To the OP: not sure if this is common among examiners, but don't be surprised.
 
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SkyHog said:
Your instructor is an idiot. This is about one of the easiest of the "how do I log tbis" questions and your CFI should know better.

You can't act as PIC, but you can log it as the sole manipulator.
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No, he is not an idiot. A simple explanation of why he is wrong would have served you better.
 
dell30rb said:
Your instructor is wrong, this is a common misconception. You may log PIC time in anything you are rated for (while sole manipulator of the controls). Endorsements do not matter.

Say you flew two hours with your instructor before he signed you off for the complex endorsement. You would log 2 hours dual and 2 hours PIC for those training flights.

Go back in your logbook and pencil in your PIC time.
Click to expand...

Thanks.
 
JeffDG said:
Heck, put it in pen! If the instructor ******* about it, have him google "faa.gov:herman", read the letter then tell you that it's not allowed.
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Thanks for the reference, Jeff.
 
FlyingJ said:
No, he is not an idiot. A simple explanation of why he is wrong would have served you better.
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I disagree. This is basic stuff for a CFI to know - even without the Herman letter, the reg is pretty straightforward - "complex" is neither a category nor a class, and therefore, isn't limited by the ability to log PIC time.
 
FlyingJ said:
Finished my commercial recently. Instructor said i couldn't log complex time as PIC until I had the complex endorsement since i would be unable to legally fly the aircraft without him onboard.
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Ask your instructor to show you where that's written. Then show your instructor this FAA letter which says you can as long as you have the necessary rating (i.e., ASEL) on your pilot certificate.
 
hook_dupin said:
One other thing that maybe you didn't think of: most of the requirements of the commercial PTS do not require a complex airplane and you are allowed to furnish multiple aircraft for the practical. You may want to consider doing the bulk of the items in your Sky Lane and finishing the check ride in a complex.
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That's a can of worms, since the examiner can a) ask you questions about both aircraft (including any equipment or systems installed in either) and b) ask you to perform any required task in either aircraft. There's also the issue of getting two planes to the test location. It's certainly possible, and many have done it, but there are pitfalls of which you must be aware when making that choice.
 
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