Why do we need retractable gear to get our commercial rating?

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JasonM

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I don't understand why this is a requirement. What if I wanted to fly a standard 182, 206, 208 or a Sea plane commercially and never had intentions of flying or owning a retract. Seems like it should be possible with some type of restriction to fixed gear.
 
JasonM said:
What if I wanted to fly a standard 182, 206, 208 or a Sea plane commercially and never had intentions of flying or owning a retract.
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The FAA isn't particularly concerned with your intentions. Their concern, when issuing a pilot certificate, is to verify you have certain experience and have demonstrated a certain baseline skillset.

I can't speak for the FAA as to why they want they want commercial pilots to have complex time, but a complex aircraft does demand more from the pilot. There are more items on the checklists, more dependence on those checklists, more EPs to know, more systems to be familiar with, more decisions to make, and more reliance on advanced planning.

Managing those things, while also performing the maneuvers and meeting PTS standards, requires more from a pilot than, say, doing chandelles in a 172.

The requirement is relatively minor in comparison to the increase in privileges that a commercial certificate earns you.
 
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It's because a Commercial Rating is a broad spectrum rating, not a type rating.
 
Henning said:
Seaplane Commercial (C-SES or MES) requires no retract gear.
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I didn't realize that.. Still doesn't help me much. In reality there is only 1 more thing to deal with on a complex compared to what I already deal with in a 182 fixed gear. I'd just rather be able to do it all in my own airplane than have to rent, train and test in some other airplane just for the purpose of the retractable gear "complex" requirement.
 
It's because someone 40 years ago thought it was a good idea, and nobody really thought it through. Today it exists primarily because it exists and nobody's been able to generate the consensus to change it. It was nearly eliminated a couple of years ago, but ALPA shot it down by raising fears that deletion of that requirement would lead to a rash of major air carrier gear-up landings. The folks in the cognizant FAA HQ office still want to change it, but they're waiting until the hubbub from the last attempt dies down and they can produce appropriate data to show that the introduction of that requirement made no difference in the air carrier gear-up accident rate.
 
Don't most aircraft, flown commercially , have retractable gear? ( now we'll hear the exceptions I'm sure) it seems pretty reasonable to me. Duhhhhh.
 
JasonM said:
I didn't realize that.. Still doesn't help me much. In reality there is only 1 more thing to deal with on a complex compared to what I already deal with in a 182 fixed gear. I'd just rather be able to do it all in my own airplane than have to rent, train and test in some other airplane just for the purpose of the retractable gear "complex" requirement.
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Too bad, that's not an option.
 
Ron Levy said:
It's because someone 40 years ago thought it was a good idea, and nobody really thought it through. Today it exists primarily because it exists and nobody's been able to generate the consensus to change it. It was nearly eliminated a couple of years ago, but ALPA shot it down by raising fears that deletion of that requirement would lead to a rash of major air carrier gear-up landings. The folks in the cognizant FAA HQ office still want to change it, but they're waiting until the hubbub from the last attempt dies down and they can produce appropriate data to show that the introduction of that requirement made no difference in the air carrier gear-up accident rate.
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If they want an option that maintains a switch rig then it's easy to build a mod for wheel pants that flips a door that costs $15 to replace if you forget the switch.
 
Somebody'd have to figure out how to get complex endorsements done in an RJ...
 
Henning said:
Seaplane Commercial (C-SES or MES) requires no retract gear.
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Also no retractable gear training time requirement for commercial helicopter, gyroplane, powered lift(!), glider, airship, or balloon. As far as I can tell by a quick scan of 61.129.
 
It's about how you manage the landing gear and the constant speed prop systems. There are more systems involved and require you to pay more attention to those systems
 
JasonM said:
I didn't realize that.. Still doesn't help me much. In reality there is only 1 more thing to deal with on a complex compared to what I already deal with in a 182 fixed gear. I'd just rather be able to do it all in my own airplane than have to rent, train and test in some other airplane just for the purpose of the retractable gear "complex" requirement.
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Yup, my initial CPL was in a CS prop 172 on straight floats. Any seaplane with flaps and a CS prop is complex... Most all working seaplanes happen to also have flaps and CS props. If you think getting complex time in a arrow or something is expensive wait till you try to build time in a seaplane, if you can even find one for rent.

The Feds want to make sure you can rub your stomic and chew gum at the same time. If you're going to hold the title of a commercial pilot, you should be able to demonstrate confidence in more complex aircraft.

Most CPL students understand and agree with this.
 
Bottom line here is that Ron in his post above was pretty much right on. There is no real good reason to require complex time for the Commercial license. That can all be done as an endorsement anyway.
 
Henning said:
If they want an option that maintains a switch rig then it's easy to build a mod for wheel pants that flips a door that costs $15 to replace if you forget the switch.
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They don't. Peter Mauer at Diamond proposed something like that, and the answer was "no".
 
jordane93 said:
It's about how you manage the landing gear and the constant speed prop systems. There are more systems involved and require you to pay more attention to those systems
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If that were true, they would not have written into the regs an exemption for single power lever FADEC-controlled engines, like those on the DA-42 TwinStar.
 
Theres not much to the Commercial. You have to learn and demonstrate something...
 
Greg Bockelman said:
Bottom line here is that Ron in his post above was pretty much right on. There is no real good reason to require complex time for the Commercial license. That can all be done as an endorsement anyway.
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I might point out that the 61.31 complex endorsement requirement was added over 20 years after the 61.129 complex requirement. I wonder which class of pilots (PP's or CP's) had the higher rate of gear-up accidents before either requirement was added, then in the interim before the 61.31 requirement was added, and whether there's any significant difference now. I also wonder whether there's any difference in the gear-up landing rates for pilots like me who got their CP before the requirement was added to 61.129 versus those who got it later.
 
Ron Levy said:
It's because someone 40 years ago thought it was a good idea, and nobody really thought it through. Today it exists primarily because it exists and nobody's been able to generate the consensus to change it. It was nearly eliminated a couple of years ago, but ALPA shot it down by raising fears that deletion of that requirement would lead to a rash of major air carrier gear-up landings. The folks in the cognizant FAA HQ office still want to change it, but they're waiting until the hubbub from the last attempt dies down and they can produce appropriate data to show that the introduction of that requirement made no difference in the air carrier gear-up accident rate.
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Why should a regulatory agency give two rat's asses about "hubbub" from a union? Sounds like someone needs to check if their testes ever dropped.


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denverpilot said:
Why should a regulatory agency give two rat's asses about "hubbub" from a union? Sounds like someone needs to check if their testes ever dropped.
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The FAA ignores comments, and they're high-handed. They are influenced by them, and they're wimps. Guess they can't win either way.
 
Ron Levy said:
The FAA ignores comments, and they're high-handed. They are influenced by them, and they're wimps. Guess they can't win either way.
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Ignoring comments from a union on a topic already handled by the airline's training standards? Seems fine here. If the airline can't teach a monkey to throw a gear handle they probably shouldn't be allowed to write their own ops specs.




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Sounds like the op wants the regs changed just so he doesn't have to rent a plane. You know what, my life would be easer also if I could get my commercial ticket in the 172 I had been flying; however requiring retractable gear and a constant speed prop seems reasonable so I don't mind renting the more expensive Arrow III. The way I see it, you want to fly people for money, then you need to demonstrate your ability to handle more systems and maneuvers.
 
FlyingTiger said:
Sounds like the op wants the regs changed just so he doesn't have to rent a plane. You know what, my life would be easer also if I could get my commercial ticket in the 172 I had been flying; however requiring retractable gear and a constant speed prop seems reasonable so I don't mind renting the more expensive Arrow III. The way I see it, you want to fly people for money, then you need to demonstrate your ability to handle more systems and maneuvers.
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Absolutely I would love to see the regs changed. I think it would benefit a lot of pilots with similar goals. I am certain there are a bunch of commercial rated pilots flying fixed gear and only intend to do so, such as myself. Also not sure 10 hours retract in the scheme of what a "Real" commercial outfit would require would say or do much. Surely the guys flying Caravans would be out of practice when they move into a type rated aircraft.

As far as costs go, I could rent something with retractable gear for far less than what my own aircraft costs me per hour, but I do own so my cost is an ongoing expense that renting would only add to.
 
By the way, it is possible to do the single engine commercial in a fixed gear aircraft. You just need to do the multi engine commercial first in a complex twin.

I'd guess more than 90% of operations requiring a commercial, single-engine, land certificate are done in fixed gear single engine aircraft. The logical solution is to move the RG requirement to the commercial multi-engine ticket. That way, the folks who do banner towing, dropping jumpers, sightseeing, etc. can do their commercial ticket without having to find a complex single.

Of course then you'd hear from the piper arrow leaseback owners association...
 
Brad Z said:
By the way, it is possible to do the single engine commercial in a fixed gear aircraft. You just need to do the multi engine commercial first in a complex twin.
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Several university aviation programs are doing just that with Diamond DA-40's and -42's for both CP and CFI.

And FWIW, I got my initial CP in a Cessna 150; and got checked out in retractables later on, and in maybe 5000 hours of RG operations have so far managed not to land gear up despite not having complex training as part of my CP training.
 
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