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Can pic time from multi private substitute for solo or pdpic time for multi commercial certificate?

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Commercial Pilot, FAA Regulations

Title says my question.

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6 Answers



  1. Kris Kortokrax on Sep 17, 2017

    I am unfamiliar with the term “PDPIC”. What does that represent?

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  2. honorwings on Sep 17, 2017

    That is \\\’performing duty of pic\\\’ in 61.195

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  3. Mark Kolber on Sep 17, 2017

    There’s no mention of PDPIC in 61.195. I assume you mean the PDPIC which substitutes for solo requirements in 61.129. Let’s make sure I understand your question. It sounds like you have a commercial MEL student who already has a private certificate with an MEL rating. Is that right? If so:

    If you are asking whether his solo multi time as a private pilot. AMEL counts toward his solo multi time time requirements for the commercial AMEL, of course it does.

    I’m not sure where PDPIC time comes into the picture. If he has enough solo multi time, he doesn’t need PDPIC time. And you can’t mix solo and PDPIC time anyway – you have to select one or the other in terms of meeting the “solo” requirements.

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  4. Kris Kortokrax on Sep 17, 2017

    First, you need to read 61.129(b)(4). It specifically requires that the solo/performing duties time address the items in 61.127(b)(2). That would mean that time acquired during training for the private rating could not be used for the commercial.

    The following thoughts are to clarify potential misunderstandings.

    The Kuhn legal interpretation (http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2014/kuhn%20-%20(2014)%20legal%20interpretation.pdf) states that the time acquired while performing the duties of a PIC can only be logged as PIC time if one is already rated for the category/class. As your applicant is already rated at the Private level, he/she can log PIC time. Your applicant, however, cannot log the time as dual instruction.

    The Grannis legal interpretation (http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2016/grannis%20-%20(2016)%20legal%20interpretation.pdf) states that one must choose whether to satisfy the requirements by either logging solo time or by logging time as a pilot performing the duties of a PIC. You could not, for instance, perform the cross country as a solo flight and then elect to perform the night requirement with an instructor on board.

    In looking at your last question, you made the statement “Problem is she doesn’t have any solo or pdpic but has multi private and pic time a lot due to flight safety school policy.” FlightSafety policy cannot contradict FAA policy. I would assume that your applicant acquired the multi-engine rating as an add-on rating at the Private level. As a result, none of her time spent acquiring the add-on Private rating could be logged as PIC, as she was not rated and would not have been the only occupant of the aircraft. Once rated, she could log time spent training for the Commercial as PIC time, as she would have been rated. However, 61.129(b)(4) requires either solo or performing the duties of PIC. PIC time acquired while receiving dual instruction cannot be used to satisfy this requirement.

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  5. honorwings on Sep 17, 2017

    Thank you for you response.
    Yes, you are right. It was my confusing. Part 61.129 is right.

    And my students doesn\’t have any solo or pdpic time but only has pic time with dual given.

    That is the problem making me confuse.

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  6. Mark Kolber on Sep 18, 2017

    This may confuse the issue even more. PDPIC can substitute for some solo requirements but in terms of how it is logged, it is not solo. It is also not PIC (although it might be) and it is not dual received. Technically, it is something different than all of them.

    I don’t think anyone, even someone who knows the ins and outs of PDPIC, can answer the question about the countability of his already logged multi time toward his commercial without reviewing the logbook entries themselves.

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