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5 Answers

Aeronautical experience CPL

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Commercial Pilot

Does a bfr count towards the aeronautical experience required by

part 61.129 (a) 3 (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;?

Thanks,

Chris

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5 Answers



  1. John D Collins on Oct 12, 2014

    FAR 61.56 states “a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training.”

    If the review was conducted in an aircraft that met the requirements of 61.129(a)(3.)(ii) and elements of 61.127(b)(1) were part of the flight review, as they undoubtedly would be, then I don’t see a reason why this flight training time would not qualify towards the commercial rating experience requirements.

    61.127(b) Areas of operation.
    (1) For an airplane category rating with a single-engine class rating: (i) Preflight preparation;
    (ii) Preflight procedures;
    (iii) Airport and seaplane base operations;
    (iv) Takeoffs, landings, and go-arounds;
    (v) Performance maneuvers;
    (vi) Ground reference maneuvers;
    (vii) Navigation;
    (viii) Slow flight and stalls;
    (ix) Emergency operations;
    (x) High-altitude operations; and
    (xi) Postflight procedures.

    Mark is the expert in this area, so I would defer to any of his comments.

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  2. Mark Kolber on Oct 12, 2014

    I agree with John. A flight review is, by definition “training.” So I can’t think of any reason something done during a flight review would not count toward certificate or rating requirements.

    Not sure what Chris is thinking of but if, for example, a private pilot with no complex endorsement has a flight review in a complex airplane, I can’t think of any reason why the training during a flight review would not count as part of the 10 hours of training required by 61.129 (a)3(ii).

    I’m curious what prompted the question.

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  3. Chris on Oct 13, 2014

    @Mark
    I hold a German PPL SEP (the class rating in Europe is “singe engine piston”, not “land”) as well as a FAA PPL SEL MEL. I got a German complex endorsement done with a German examiner, which complies with German regulations, but does not count toward training time in the meaning of FAA-regs, as the examiner has not been CFI. I also own a Piper Arrow and have logged some 100h in her. So I had my FAA-complex endorsement done with almost no training according to FAA-regs.
    Now I want to start training for my CPL/IR SEL MEL at the end of October. Checking all the requirements I realized the missing complex-training. As the CPL/IR is already going to cost some money, I try to avoid any minute of training which is not absolutely necessary.
    Thanks John&Mark, for your prompt answers on my question.

    Chris.

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  4. Kris Kortokrax on Oct 13, 2014

    Chris,

    I would think that in order to get the German complex endorsement, you would have received some instruction from a German instructor in the complex airplane.

    According to 14 CFR 61.41, you can credit that instruction toward the requirements for a U.S. pilot certificate.

    If you will be training for the Commercial MEL, you will likely get more complex training. Since 61.129 (a)(3)(ii) specifies that you must receive training in a complex airplane, not a complex single engine airplane, you will probably not be short of complex time.

    Mit freundlichen Grüssen

    Kris

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  5. Mark Kolber on Oct 13, 2014

    Thanks for the clarification, Chris. Not knowing anything about the German regulations, I can’t be certain if you received “countable” training. But Kris is absolutely right that =if= you received complex training from “A flight instructor who is authorized to give such training” by the Luftfahrt-Bundesamt, that would be countable as training under FAR 61.41(a)(2). (Not the German complex endorsement itself, but the training for it).

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