Flight experience [Archive]

January 28th 20, 12:45 AM

I've searched the FAA Legal Interpretation website for an answer but haven't found one I understand.

My question is:

Can any of the flight experiences that were used to qualify for a private pilot certificate be subsequently used in part or whole to satisfy the flight experience requirements for a commercial pilot certificate.

Or, must the flight experience requirements for a commercial pilot certificate occur after the applicant has acquired a private pilot certificate.

Thank you.

John Foster

January 28th 20, 01:13 AM

On Monday, January 27, 2020 at 5:45:54 PM UTC-7, jp wrote:
> I've searched the FAA Legal Interpretation website for an answer but haven't found one I understand.
>
> My question is:
>
> Can any of the flight experiences that were used to qualify for a private pilot certificate be subsequently used in part or whole to satisfy the flight experience requirements for a commercial pilot certificate.
>
> Or, must the flight experience requirements for a commercial pilot certificate occur after the applicant has acquired a private pilot certificate.
>
> Thank you.

I believe it includes the total flight hours experience you have as a pilot, including all your training for private pilot's licence. Others would know more though.

[email protected]

January 28th 20, 01:17 AM

On Monday, January 27, 2020 at 7:45:54 PM UTC-5, jp wrote:
> I've searched the FAA Legal Interpretation website for an answer but haven't found one I understand.
>
> My question is:
>
> Can any of the flight experiences that were used to qualify for a private pilot certificate be subsequently used in part or whole to satisfy the flight experience requirements for a commercial pilot certificate.
>
> Or, must the flight experience requirements for a commercial pilot certificate occur after the applicant has acquired a private pilot certificate.
>
> Thank you.

FAR's are written through exceptions.
If you do not see anything in the Commercial experience description that says the experience can't be used, you can use it.
I've never heard the question asked before.

January 28th 20, 01:23 AM

January 28th 20, 01:40 AM

On Monday, January 27, 2020 at 4:45:54 PM UTC-8, jp wrote:
> I've searched the FAA Legal Interpretation website for an answer but haven't found one I understand.
>
> My question is:
>
> Can any of the flight experiences that were used to qualify for a private pilot certificate be subsequently used in part or whole to satisfy the flight experience requirements for a commercial pilot certificate.
>
> Or, must the flight experience requirements for a commercial pilot certificate occur after the applicant has acquired a private pilot certificate.
>
> Thank you.

Yet another data point. I just found this 2011 FAA Legal Interpretation that may address this question.
This is a reply from the FAA Office of the Chief Counsel to a question from Daniel Murphy:

"The FAA recently issued an interpretation addressing a situation in which a pilot wanted to use the experience he obtained while training for a private pilot certificate to satisfy the night cross country experience required for a commercial pilot certificate. See Oct. 8,2010, Letter to Richard Theriault from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations. The FAA's interpretation did not permit the pilot to use experience that he acquired while training for a private pilot certificate to satisfy the commercial pilot requirements. Id.
Because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards, the type oftraining contemplated by
§ 61. 129(a)(3)(iii) is not interchangeable with the kind required for a private pilot certificate. See id.; 60 Fed. Reg. at 41181-82. Accordingly, any cross-country training experienced by a student pilot would not be credited toward the requirements of § 61.129(a)(3)(iii)."

I'll keep looking for more info.

IADPE

January 28th 20, 10:52 AM

Keep in mind that any flight time acquired before being rated in the aircraft is either Dual Received or Solo Time- NOT PIC. To log PIC, you must be at least a Light Sport, Recreational, or Private Pilot in that Category and Class. Flight Time in any Category and Class counts toward the Aeronautical Experience Total Flight Time requirement.

January 28th 20, 05:47 PM

On Tuesday, January 28, 2020 at 2:52:30 AM UTC-8, IADPE wrote:
> Keep in mind that any flight time acquired before being rated in the aircraft is either Dual Received or Solo Time- NOT PIC. To log PIC, you must be at least a Light Sport, Recreational, or Private Pilot in that Category and Class. Flight Time in any Category and Class counts toward the Aeronautical Experience Total Flight Time requirement.

This may just be angels dancing on the head of a pin but a student may log PIC when flying solo with a current solo endorsement. The student is the only one in the airplane after all. The student is not yet certificated and is not yet rated for the aircraft yet can log the time as PIC.

That "PIC" has two operational meaning is a source of confusion for many of us. "PIC" as in the sole operator of the controls and "PIC" as in the one responsible for the safety of the flight - whether using the controls or not. I gather this is one of the reasons a CFI can log a student training flight as PIC even when the student is the only one on the controls for the entire lesson flight.

And, even though a student pilot with a current solo endorsement can log PIC when flying solo that flight time can be used only to fulfill the flight experience requirements for the private pilot certificate, not for any subsequent certificates the pilot might go on to acquire - according to the FAA Chief Counsel anyway.

January 28th 20, 05:56 PM

On Tuesday, January 28, 2020 at 9:47:49 AM UTC-8, jp wrote:
> On Tuesday, January 28, 2020 at 2:52:30 AM UTC-8, IADPE wrote:
> > Keep in mind that any flight time acquired before being rated in the aircraft is either Dual Received or Solo Time- NOT PIC. To log PIC, you must be at least a Light Sport, Recreational, or Private Pilot in that Category and Class. Flight Time in any Category and Class counts toward the Aeronautical Experience Total Flight Time requirement.
>
> This may just be angels dancing on the head of a pin but a student may log PIC when flying solo with a current solo endorsement. The student is the only one in the airplane after all. The student is not yet certificated and is not yet rated for the aircraft yet can log the time as PIC.
>
> That "PIC" has two operational meaning is a source of confusion for many of us. "PIC" as in the sole operator of the controls and "PIC" as in the one responsible for the safety of the flight - whether using the controls or not. I gather this is one of the reasons a CFI can log a student training flight as PIC even when the student is the only one on the controls for the entire lesson flight.
>
> And, even though a student pilot with a current solo endorsement can log PIC when flying solo that flight time can be used only to fulfill the flight experience requirements for the private pilot certificate, not for any subsequent certificates the pilot might go on to acquire - according to the FAA Chief Counsel anyway.

Here is a segment from an FAA comment on this:

"A student pilot can now log PIC. That’s new, and since there is no restriction, your logbook can be updated so that all student solo time prior to August 4, 1997 may be logged as PIC. When an instructor is aboard, since the student is not rated in the aircraft, flight instruction is still logged as dual not PIC."

January 28th 20, 06:06 PM

On Tuesday, January 28, 2020 at 9:56:52 AM UTC-8, jp wrote:
> On Tuesday, January 28, 2020 at 9:47:49 AM UTC-8, jp wrote:
> > On Tuesday, January 28, 2020 at 2:52:30 AM UTC-8, IADPE wrote:
> > > Keep in mind that any flight time acquired before being rated in the aircraft is either Dual Received or Solo Time- NOT PIC. To log PIC, you must be at least a Light Sport, Recreational, or Private Pilot in that Category and Class. Flight Time in any Category and Class counts toward the Aeronautical Experience Total Flight Time requirement.
> >
> > This may just be angels dancing on the head of a pin but a student may log PIC when flying solo with a current solo endorsement. The student is the only one in the airplane after all. The student is not yet certificated and is not yet rated for the aircraft yet can log the time as PIC.
> >
> > That "PIC" has two operational meaning is a source of confusion for many of us. "PIC" as in the sole operator of the controls and "PIC" as in the one responsible for the safety of the flight - whether using the controls or not. I gather this is one of the reasons a CFI can log a student training flight as PIC even when the student is the only one on the controls for the entire lesson flight.
> >
> > And, even though a student pilot with a current solo endorsement can log PIC when flying solo that flight time can be used only to fulfill the flight experience requirements for the private pilot certificate, not for any subsequent certificates the pilot might go on to acquire - according to the FAA Chief Counsel anyway.
>
> Here is a segment from an FAA comment on this:
>
> "A student pilot can now log PIC. That’s new, and since there is no restriction, your logbook can be updated so that all student solo time prior to August 4, 1997 may be logged as PIC. When an instructor is aboard, since the student is not rated in the aircraft, flight instruction is still logged as dual not PIC."

And just to try to cover this complicated subject a little more fully, a student pilot can log the check ride as PIC - unless the DPE agrees to be the PIC for the check ride flight(s). The confusion never ends.

Charlie M. (UH & 002 owner/pilot)

January 28th 20, 06:16 PM

My comment....the basic FAR's in the US are succinct, it's the exceptions that are a PITA..... I will assume other countries are similar....
The exceptions are what trip peeps up....
Sorta a...."thou shall ALWAYS do this/thou shall NEVER do this....UNLESS...the moon is full, you scratched your left butt but not the right,, etc., etc., etc.,........"
Sigh.....

January 28th 20, 06:50 PM

On Tuesday, January 28, 2020 at 10:17:02 AM UTC-8, Charlie M. (UH & 002 owner/pilot) wrote:
> My comment....the basic FAR's in the US are succinct, it's the exceptions that are a PITA..... I will assume other countries are similar....
> The exceptions are what trip peeps up....
> Sorta a...."thou shall ALWAYS do this/thou shall NEVER do this....UNLESS....the moon is full, you scratched your left butt but not the right,, etc., etc., etc.,........"
> Sigh.....

So very true. It seems like every student is in the "not quite this and not quite that" category. I am very glad we can see the FAA Chief Counsel's legal interpretations of the FAR's. I hope that if the FAA invites me in for a chat I remember to bring along the FAA's interpretations I (hope) I followed. I'll probably forget.

Piet Barber

January 28th 20, 10:27 PM

On Tuesday, January 28, 2020 at 5:52:30 AM UTC-5, IADPE wrote:
> Keep in mind that any flight time acquired before being rated in the aircraft is either Dual Received or Solo Time- NOT PIC. To log PIC, you must be at least a Light Sport, Recreational, or Private Pilot in that Category and Class. Flight Time in any Category and Class counts toward the Aeronautical Experience Total Flight Time requirement.

***FALSE***

Solo student pilot time ABSOLUTELY counts as PIC time, just as much as it would if he had a rating.

I believe that your interpretation of 61.51 is incomplete. You think that 61.51(e)(1) restricts PIC time to rated pilots. Yes, 61.51(e)(1) lists circumstances where those pilots with a recreational, sport, private, commercial rating can log pilot in command time. However, that is not the whole list of pilot in command logging circumstances.

You need to read all of 61.51. Read on to 61.51(e)(4). You'll find 61.51 (e)(4)(i). It reads:

(4) A student pilot may log pilot-in-command time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

In the case of a glider pilot, he is the sole occupant of the aircraft. He's the sole occupant of the glider. He gets to log it as PIC if he's got a current sign-off 61.51(e)(4)(ii), and is undergoing training for a rating. 61.51(e)(4)(iii)

As far as I can tell, this regulation has been written this way at least since 1978.
If you are remembering it another way, it's probably a good demonstration of the Mandela effect.
https://www.goodhousekeeping.com/life/entertainment/g28438966/mandela-effect-examples/