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Complex time for Commercial ASEL..

Asked by: 1741 views Commercial Pilot

In pursuing a commercial rating for ASEL can the 10 hours complex time requirement be satisfied by flying a complex multi-engine plane? 14 CFR 61.129 (a)(3)(ii) says the "...airplane must be appropriate to land or sea for the rating sought." It does not indicate that it has to be appropriate for the class of the rating sought.

My thought was that I could put in 10 hours dual in a multi-engine complex aircraft, test for Commercial ASEL, then spend a couple more hours in the multi and test for Multi Add-On. Kinda kill 2 birds with 1 stone. I know the multi time will be more expensive, but it would need to be done anyway for the multi add-on. This way would prevent me having the cost of 10 hours in a SE complex or TAA aircraft...and then still needing the multi time.

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2 Answers



  1. Bryan on Apr 07, 2022

    I believe your interpretation is correct. I actually did mine the other way around–Commercial AMEL and then the ASEL add-on. Just over 26 hours of total multi time to do it that way.

    But for the regulation, the fact that they will accept “any combination” of 10 training hours in complex, turbine, or technically advanced means that they just want you to get a little bit of experience flying something more complicated than the Cherokee or 172 you might have been using to keep costs down. 10 hours isn’t enough to make you proficient in any of those areas, especially if you split it up. So as long as it is a land based plane for a land based rating, you’re good.

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  2. Russ Roslewski on Apr 08, 2022

    You are correct and I have done exactly this before. Don’t read more into the regulations than is already there. It just requires a Complex “Airplane” (and land or sea as appropriate). It could be a single, twin, turboprop or jet even. (Although those last two options are already covered by the next clause in the regulation about “turbine” airplanes, so they wouldn’t have to be “complex” – for example a Caravan or Twin Otter would be acceptable.)

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