FAA Commercial Requirements…

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… or how to waste some money.

Firstly I’d like to tell about the FAA check-ride situation in Florida: there are a lot of flight schools, there are a lot of students, and there are only 5 DPEs. In practice it means that usually one have to wait for a checkride more than a month. We are a little bit lucky, because one of our instructors is also a DPE, and if somebody cancels, we have a priority. Of course one can apply for a FAA examiner, but waiting time is even longer. Usually much longer.

So, I met my commercial requirements according to FAR 61.129 about a week and a half ago, and scheduled a checkride. I was lucky, somebody had a cancellation, and I was expecting a checkride at July 16. And on Tuesday somebody canceled a checkride on 12th of July, and I took that slot. That is I expected my commercial checkride today. It did not happen. It has stopped even before we started an oral part, during a logbook analysis.

So, what happened? We can see the following in FAR 61.129:

(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

During my instrument training I got 38 instrument hours, and I considered that I’m done with that. But the examiner used this and this FAA letters. In the first one we can see that 61.65 training hours (i. e. towards instrument rating) do not qualify towards 61.129 requirements (commercial). The opposite works. The letter is for helicopter rating, but nevermind, for airplanes we have the same. The second letter says that the training can qualify, but it should meet 61.129 requirements. I. e. if the CFII explicitly states that in the logbook during your instrument training, you are safe. But the problem is that I was on a part 141 during my instrument. It is a structured training with an approved syllabus. Nobody mentioned anything about 61.129. Actually standards are the same, and training is the same. But legally it does not work without explicit mention of 61.129 in the remarks section. And the DPE’s position is that I need 10 hours more instrument time (dual) after 141 instrument program.

Possibly it was naive, but I supposed to have almost exactly 250h TT before my checkride. It will not happen, I should fly 10 additional hours. I hope I will have a long cross-country tomorrow (the concern is the weather…). Later I will just plan ahead more carefully. During my commercial training I had a small doubt about this requirement, but I did not pay attention on it, and neither my CFI did.

So, I need more hours, my checkride shifts by some days, and I cannot even imagine when I can have my multi checkride. Flight hours are OK, they always matter, especially instrument hours, but I am disappointed about longer waiting time.

P. S. when I already realized that I would not fly today, I figured out that the airplane for our checkride had only 1 hour before 100h inspection: somebody flew a cross-country yesterday night, so the practical checkride part would probably be cancelled anyway during the preflight inspection.

2 thoughts on “FAA Commercial Requirements…”

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