Power rating -- looking for regulatory guidance

I have a glider commercial rating, and I'm adding on my power rating. The question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

The question is, does "have received training" mean "have received all of the training?" That seems pretty stiff -- you have to do the instrument and night cross country first. Does it mean "have received any of the training?" That seems (for the FAA) pretty loose, especially compared to the rules for student pilots. Half an hour of take offs and landings and off you go. It seems to mean, whatever it takes to satisfy the instructor that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does anybody know of a letter, FAQ, or other official statement from the FAA -- the type that might convince airplane operator chief instructors, presidents, insurance companies, and examiners -- on this issue?

Thanks

John Cochrane (BB)

On 2/2/2019 11:25 AM, John Cochrane wrote:
I have a glider commercial rating, and I'm adding on my power rating. The
question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization
requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an
aircraft as the pilot in command. To serve as the pilot in command of an
aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the
pilot certification level, aircraft category, class, and type rating (if a
class or type rating is required) for the aircraft to be flown, and have
received an endorsement for solo flight in that aircraft from an authorized
instructor.

The question is, does "have received training" mean "have received all of
the training?" That seems pretty stiff -- you have to do the instrument and
night cross country first. Does it mean "have received any of the
training?" That seems (for the FAA) pretty loose, especially compared to
the rules for student pilots. Half an hour of take offs and landings and
off you go. It seems to mean, whatever it takes to satisfy the instructor
that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does
anybody know of a letter, FAQ, or other official statement from the FAA --
the type that might convince airplane operator chief instructors,
presidents, insurance companies, and examiners -- on this issue?

Ancient info I know, but I'm not betting you'll "like the official answer in
fact."

Ca. 1980 I went so far as to partner in a C-150, for the ostensible purpose of
adding a PP-SEL to my PP-Glider. The applicable, pertinent-to-me, FAR wasn't
training hours/requirements, but *testing* FARs: one explicitly stated (since
changed, I believe/expect) the examiner had the OPTION (word actually used in
the applicable reg.) of examining the applicant on VOR navigation. The VOR in
our 150 being "for all practical purposes" inop, I was unable to find an
examiner (private or FAA) willing to let me take the test in our 150. I never
bothered to obtain my power rating.

In the absence of "hard words supporting your version of common sense," I'll
put my money on your situation today likely "running up against the same sort
of thing"...but more so, since 'Murican society doesn't seem to have gotten
less litigious in the years since.

Additional RAS feedback should be interesting...

Bob W.

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On Saturday, February 2, 2019 at 1:25:06 PM UTC-5, John Cochrane wrote:
I have a glider commercial rating, and I'm adding on my power rating. The question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

The question is, does "have received training" mean "have received all of the training?" That seems pretty stiff -- you have to do the instrument and night cross country first. Does it mean "have received any of the training?" That seems (for the FAA) pretty loose, especially compared to the rules for student pilots. Half an hour of take offs and landings and off you go. It seems to mean, whatever it takes to satisfy the instructor that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does anybody know of a letter, FAQ, or other official statement from the FAA -- the type that might convince airplane operator chief instructors, presidents, insurance companies, and examiners -- on this issue?

Thanks

John Cochrane (BB)

You need to have logged the training required for the certificate you are applying for.
Example-If you are applying for PP, you need satisfy only the requirement for that.
For solo you must have the areas of training specified in the FAR's for solo flight.
Also worth noting- you do not have to have an instrument rating to get a commercial certificate. The rating would however have limitations.
Dive in
UH

John,

You're right it doesn't seem to be exactly clear about when you can fly solo when adding a new category and class to an existing certificate. But being an examiner, I run into this frequently. The short answer is that you must satisfy the instructor that writes the endorsement for PIC privileges in the new aircraft.

The endorsement will be for PIC privileges in a category and class aircraft for which you do not hold a current certificate. It will have limitations regarding carrying passengers and other limitations the endorsing instructor thinks is necessary.

Once you have a pilot certificate, Private or Commercial, you will NEVER be a student pilot again and so do not have to complete the student requirements listed in 61.87 for the various aircraft category and classes. However most instructors will evaluate your knowledge/skill against those requirements prior to issuing an endorsement. No knowledge test is required until you want to actually take the practical test. Then both the computer knowledge test and the practical test must be passed to add the new privileges to the certificate.

Prior to taking the add-on practical test you will need to receive and log the areas listed in the appropriate section of 61.121, or at least show proficiency in those areas.

FAR 6.63 discusses the minimums for getting an Add-on rating.

The commercial certificate MAY be issued without an instrument rating, but it will again have specific limitations.

I hope that helps,

Mike B.

On Saturday, February 2, 2019 at 10:25:06 AM UTC-8, John Cochrane wrote:
I have a glider commercial rating, and I'm adding on my power rating. The question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

The question is, does "have received training" mean "have received all of the training?" That seems pretty stiff -- you have to do the instrument and night cross country first. Does it mean "have received any of the training?" That seems (for the FAA) pretty loose, especially compared to the rules for student pilots. Half an hour of take offs and landings and off you go. It seems to mean, whatever it takes to satisfy the instructor that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does anybody know of a letter, FAQ, or other official statement from the FAA -- the type that might convince airplane operator chief instructors, presidents, insurance companies, and examiners -- on this issue?

Thanks

John Cochrane (BB)

John,

This is not likely an issue for you but just as general info, to legally solo an aircraft, thus being PIC, the pilot needs a current flight review. For an add-on this means a current flight review in the aircraft for which the pilot is already certificated. Several of our add-on folks have sadly bumped into this requirement.

On Saturday, February 2, 2019 at 10:25:06 AM UTC-8, John Cochrane wrote:
I have a glider commercial rating, and I'm adding on my power rating. The question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

The question is, does "have received training" mean "have received all of the training?" That seems pretty stiff -- you have to do the instrument and night cross country first. Does it mean "have received any of the training?" That seems (for the FAA) pretty loose, especially compared to the rules for student pilots. Half an hour of take offs and landings and off you go. It seems to mean, whatever it takes to satisfy the instructor that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does anybody know of a letter, FAQ, or other official statement from the FAA -- the type that might convince airplane operator chief instructors, presidents, insurance companies, and examiners -- on this issue?

Thanks

John Cochrane (BB)

John,

I was far from clear in my last post. The requirement for a current flight review is only for an add-on applicant. We all know that a flight review is not required for an actual student pilot.

On Saturday, February 2, 2019 at 1:25:06 PM UTC-5, John Cochrane wrote:

John,

I am doing the same thing. I am taking power lessons now. I want to get a tailwheel endorsement and become a tow pilot some day. I am going to solo in power soon and wanted to know how to log time. I ended up calling AOPA Pilot info center.

For rated glider pilot learning Airplane SEL, you are NOT a student pilot.
Dual time is NOT PIC because it is a different category that you are not rated for.
Solo time IS PIC because you are NOT a student (and you are sole manipulator of controls). AOPA referred me to AC 61.65H endorsement A.72. this is the endorsement language that the instructor should use instead of what they normally used for a student:

A.72 To act as pilot in command of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: § 61.31(d)(2). I certify that [First name, MI, Last name] has received the training as required by § 61.31(d)(2) to serve as a pilot in command in a [specific category and class] of aircraft. I have determined that [he or she] is prepared to solo that [make and model] aircraft. Limitations: [optional].


also interesting to me:

A.71 To act as pilot in command in a tailwheel airplane: § 61.31(i). This endorsement may be given in a sport pilot aircraft by a sport pilot instructor, or in an airplane by a flight instructor with a rating other than a sport pilot rating. I certify that [First name, MI, Last name], [grade of pilot certificate], [certificate number], has received the required training of § 61.31(i) in a [make and model] of tailwheel airplane. I have determined that [he or she] is proficient in the operation of a tailwheel airplane.


regards
Chris

Huh.

I looked up the dates when all of these endorsements became requirements
and see that I had qualified in those things before it was required to
have endorsements.Â* What was interesting was that the "Complex Airplane"
description matches the Stemme.Â* But the Stemme is a glider.Â* Go
figure.Â* Any old glider pilot can fly an aircraft with a 115 hp
turbocharged engine, controllable pitch propeller, cowl flaps, wing
flaps, and retractable landing gear. All that is needed is to satisfy
the insurance company with an instructor's endorsement.

On 2/2/2019 11:25 AM, John Cochrane wrote:
I have a glider commercial rating, and I'm adding on my power rating. The question is, just what requirements do I need to solo?

Yes, I know the relevant reg --

§61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—...

(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

The question is, does "have received training" mean "have received all of the training?" That seems pretty stiff -- you have to do the instrument and night cross country first. Does it mean "have received any of the training?" That seems (for the FAA) pretty loose, especially compared to the rules for student pilots. Half an hour of take offs and landings and off you go. It seems to mean, whatever it takes to satisfy the instructor that you're competent for solo flight, which seems unusually sensible.

My question here, since many of you may have followed this path, does anybody know of a letter, FAQ, or other official statement from the FAA -- the type that might convince airplane operator chief instructors, presidents, insurance companies, and examiners -- on this issue?

Thanks

John Cochrane (BB)

--
Dan, 5J

Wow, a lot of words to fly solo...
First...get an instructor....since you’re a smart rich guy....you might as well get your Student Medical Certificate from a AME of choice.
Start your lessons and one day the instructor hops out.
The instructor will define your limitations including how often he will fly with you to monitor your proficiency.
Your instructor has the answers to what you want to do. Your question reads to me that you have something out of the ordinary in mind.
That you’re not interested in ‘rating collecting’. If so, explain this to your instructor so he can custom tailor your lessons..
An example would be you want to race a single seat aircraft. Since you have all the skillset of a pilot, this would be an easy transition.
I’m being very basic to answer a basic question.
R