Complex Aircraft Question

"Chris" wrote in message ...
I've recently obtained my multi-eingine rating in a seneca can this complex
aircraft time be used toward the FAR requirement of 10 hours of training in
a complex aircraft for a COMMERCIAL SINGLE ENGINE RATING (NOT MULTI). I have
about 11.5 complex between the seneca and an Arrow?

Thanks in Advance
Chris

I'd like to take a shot at this one :-)

in short, my answer is YES which I justify as follows:

disclaimer: I am not a lawyer, but I am trying to become a CFI and
would like to see if I understand some of the finer points of
interpreting
our beloved 14 CFR scriptures... so here it goes:

I reckon that you are referring to 61.129(a)(3)(ii) which stipulates
the aeronautical experience required for the commercial certificate
for
an airplane single engine (and I would assume that you do not already
hold a commercial certificate in another class of the same category,
i.e., that 61.63(c) does not apply);

....so it reads: ''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;''

It says explicitely ''in an airplane'' without specifying whether said
airplane is a single engine or not, unlike, for instance, the
requirement
on 61.129(a)(3)(i) which specifies that at least 5 hours of the
required
10 hours of instrument training must be done in a single engine
airplane.

So, I contend that if the FAA had meant for the complex aircraft to
be
a single, they would have said so explicitely.

voila voila.

what do you guys think?

--Sylvain

ps I got my commercial single engine using the 61.63(c), i.e., as an
additional class rating;