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Confused about CPL rating requirements

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Commercial Pilot

I'm sorry if this has been asked before - I tried searching and came up with partial answers.  I'm trying to make sense of the Commercial Rating requirements and the FARs appear to be not very helpful. I've bolded the requirements about which I have specific questions. http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/FARSBySectLookup/61.129!OpenDocument&ExpandSection=-3 My understanding is that one needs the following in order to take the practical test: 1) 250 hours of flight time - does this include FTD/Simulators done during instrument training? 2) 100 hours in powered aircraft; 50 in airplane (all my flying is in airplanes) 3) 100 hours of PIC time with: a) 50 hours in airplanes and b) 50 hours of cross country time

4) 10 hours of instrument training (I have my instrument rating so I assume that takes care of this requirement?)

5) 10 hours of complex time

6) 5 hour of night VFR time with 10 takeoffs & landings - does the time I spent doing this while getting my private certificate count?

7) one 2 hour cross country trip of 100 nm during the day and one 2 hour trip at night - do these have to be with an instructor on board?

8) The big 300 nm cross country trip with landings at 2 airports, etc, etc...

5 Answers



  1. Kris Kortokrax on Jun 05, 2015

    #1) They want 250 hours of “flight time”. “Flight time” is defined in Part 1 as:

    “Flight time means pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing.”

    Based on this, I would say your FTD time (it is unlikely that you have time in a simulator) does not count toward the 250 hours.

    #4) See the Hartzell interpretation
    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/hartzell%20-%20(2010)%20legal%20interpretation.pdf

    It says essentially that there are specific requirements in 61.129 and that training to meet those requirements needs to have been explicitly documented during your instrument training.

    #6) It has been FAA policy that since 61.129 (a)(4) specifically mentions training on the areas of operation listed under 61.127(b)(1), that training for the private certificate cannot be used to satisfy this requirement.

    #7) These two requirements are listed under 61.129(a)(3) which describes the dual training required. Therefore, they must be done with an instructor on board and logged as such.

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  2. Kevin Wright on Jun 08, 2015

    I very recently went through part 61 training for Commercial and cfi.

    Regarding question 1:

    There is a provision for crediting up to 50 hours of sim or FTD time towards the 250 hours of flight time. Reference 61.129 (i) (1) (i). This has to be logged with an appropriately rated cfi, but your time during instrument training with a cfii should suffice.

    Make sure your FTD time is logged correctly, in a certified device, with cfii sign off. You can get commercial completed with 200 hours in the airplane and 50 hours in the FTD.

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  3. Kris Kortokrax on Jun 08, 2015

    Just a couple of thoughts on 61.129(i).

    It is unlikely that you acquired your time in a simulator (they are very expensive).
    You need to be sure that the device you used is an FTD and not an ATD. There are a lot of Redbird devices out there. They are AATDs. 61.65(i) allows using an ATD. 61.129(i) does not.

    It is important to note that the time must be in the class of airplane for which you are training. If you are working towards multi-engine airplane and your simulated time was done in a single engine airplane FTD, you cannot use it. See the Rossman interpretation:

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/rossman%20-%20(2012)%20legal%20interpretation.pdf

    61.129(i) uses the phrases “training required by this section” and “toward the total aeronautical experience requirements of this section”. To me, that means that the training conducted in the simulator or FTD needs to be on the areas of operation outlined in 61.127. This is my opinion. To really find out what can be used would require an interpretation from the Office of Legal Counsel.

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  4. Mark Melindo on Feb 19, 2017

    Hi there. Does the 300 nm x-country has to be with the school’s aircraft? Or could it be done privately? I’ve been told it’s part of the supervised training. Although an ATPL who owns the aircraft I fly as block time says that’s just one of the BS flight school makes so they get the gains. What’s your opinion on this? Thank you.

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  5. Russ Roslewski on Feb 21, 2017

    Hi Mark. It appears you are asking a separate question from the original in this thread, so we don’t know all your details. But I’ll try to answer your question.

    It depends if you are doing your training under Part 61 or Part 141.

    If Part 141, yes you need to use the school’s airplanes to do all of the training, including the 300 nm XC. Everything you do as part of their approved program has to be done in their airplanes. You can fly all you want outside of the program, and it counts for total hours, but won’t count towards any of the Part 141 requirements.

    If you are Part 61, then this isn’t really a “training” requirement, it’s an “experience” requirement. (Notice it’s under the “aeronautical experience” paragraph.) As long as, by checkride time, you have a 300nm XC (meeting the various requirements in 61.129) somewhere in your logbook, you are fine. It doesn’t matter if it was in a school airplane, one you own, or one you borrow. I did mine years before I even started working on my Commercial through the course of regular flying.

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