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3 Answers

61.129(b)(4) interpretation

Asked by: 1177 views Commercial Pilot, FAA Regulations

I have a CP-ASEL, PP-AMEL, IA, and a type rating for the Eclipse (EA500S, a twin jet).  I have about 200 hours multi total.  Am adding a CP-AMEL (additional class rating) with the intent of doing CFI down the road.  I beleive that 61.63 means that the training hours of 61.129 don't apply (i.e. 61.129(b)(3)), but 61.129(b)(4) still does.   I have a question about how to interpret this however:

10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in § 61.127(b)(2) of this part that includes at least -..[x-country and night VFR]

My question is about the first "or".  Does it mean:

(10 hours solo) or (10 hours PIC duties including all the night stuff)

or

(10 hours solo or 10 hours PIC duties) including all the night stuff

It seems to me the latter interpretation would be rational (they want everyone to have done the night operations) but if they're done solo, how does the wording  "on the areas of operation listed in § 61.127(b)(2) of this part " make any sense?

I ask because I have a total number of night operations that meet the requirements, but they're a mix of solo and dual, and I want to know if I need to go and bang out a bunch of solo night VFR landings or not.

 

 

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3 Answers

  1. Best Answer


    Russ Roslewski on Feb 19, 2023

    It’s 10 hours of solo, or tens hours of PDPIC. In either case, doing those various things.

    But that doesn’t matter, because you’re misinterpreting 61.63c. Since you already have a Commercial Pilot certificate with ASEL rating, then you are just adding a class (AMEL) to your Commercial certificate. As such, there are no training time requirements. You train to proficiency and take the checkride.

    Also, since you already have a PP-AMEL with IA, you do not need to demonstrate a single-engine approach for your Comm-AMEL checkride.

    Really, adding on AMEL to your existing Comm certificate, given you already have PP-AMEL, should be almost a non-event. The maneuvers are all the same, some with slightly tighter tolerances but pretty inconsequential.

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  2. Adam Broun on Feb 19, 2023

    Thanks, helpful. I guess I was reading the word “training” in 61.63(c) too narrowly, meaning only the bits of 61.129(b) that explicitly say “training” (i.e. (b)(3)).

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  3. Mark Kolber on Feb 23, 2023

    “Performing the duties…” is not a “training” requirement. It’s a solo substitute the FAA originally added due to the inability to obtain insurance for multi solo. It’s not even logged as dual.

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