FAA Commercial Requirements…

… 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.

Logging the Flight Time

Logging the flight time can be tricky when you need to meet the requirements for different authorities, for example, FAA and EASA. They have a lot of common points, but they have some essential differences as well, so it’s better to know them to save some money.

First of all, I’d like to explain some terms.

PIC (Pilot In Command). It is the person who assumes the responsibility of the entire flight. He fills the aircraft’s logs ans has the final authority. According to the EASA regulations, you can log PIC time only if you act as a PIC, but FAA rules allow to log PIC time in some other cases – I will explain it later in this post.

PICUS (PIC under supervision). It is the person who acts as a PIC, but under specific circumstances. For example, in the UK the student logs PICUS time during a checkride with the examiner. I haven’t seen PICUS time in the FAA regulations.

SIC (Second In Command). It is a co-pilot (or a first officer) for a multi-pilot aircraft.

Safety pilot. It is not actually a pilot, but a person who monitors the pilot’s actions for some reason. Legally it is a passenger, but sometimes it can be a flight instructor who does not provide flight training (and, correspondingly, does not log his flight time). Sometimes he can log flight time too, when he acts as a required flight crew member (I will also explain later).

Passenger. Just a passenger, does not perform any duties.

VMC (Visual Meteorological Conditions). Meteorological conditions when there are visual references outside the aircraft (for example, the horizon, or some landmarks on the ground). Basically it’s flight conditions outside the clouds.

IMC (Instrument Meteorological Conditions). Basically it’s NOT VMC. Usually it’s when we are in the clouds and cannot navigate using outside references. Legally VMC has necessary minimums, and when we are below these minimums, we can consider the conditions as IMC.

VFR (Visual Flight Rules). Legally we can fly under VFR when we are in VMC and can use outside references for navigation and separation with other aircrafts.

IFR (Instrument Flight Rules). These flight conditions assume that we use instruments for navigation and separation with other aircrafts. It can happen that we don’t see anything outside the aircfart, but it is not necessary. Legally we can fly under IFR in both IMC and VMC. It is mainly relevant for EASA, where we can log IFR time in any meteorologial conditions, but for FAA we cannot log instrument time in VMC regardless of our flight rules. And that is one of the essential differences.

Total time. It is the total flight time regardless of the role when we are acting as a crew member or a student.

Dual time. Dual given time means that we provide flight instruction for someone. Dual received time means that we are receiving flight instruction from a certified instructor.

Night time. Basically it’s time after sunset to sunrise, but there are some nuances. For example, FAA counts night landings only after 1 hours after sunset and not later than 1 hour before sunrise. Some EASA countries allow to log night time not earlier than 30 min after sunset and not later than 30 min before sunrise. ICAO and EASA have the same definition, but there are some local regulations, for example, in the CAP393 UK. So it’s better to check local documents to properly log night time. I log night time from sunset to sunrise, and night landings 1 hour after sunset to be legal for both authorities.

Solo time. Usually it means that you are all alone in the aircraft and don’t take aboard even a passenger’s dog regardless whether it has a license and whether it knows how to fly the airplane. That time seems to be relevant only for students. After getting a license nobody cares, only PIC time matters.

Solo acting. It means that only this person use the flight controls. Nobody else should even touch the yoke, pedals or whatever adjusts the flight parameters. For example, it can be even dual received hours with a flight instructor next to you, but the instructor should not touch flight controls.

Instrument time. It means flight time using only flight instruments, without any reference outside the aircraft. EASA world does not use that term (there is IFR time there instead), but for FAA it’s essential. We does not always have clouds to practise (and initially does not even want to fly in the clouds while learning), so FAA allows both actual (flight time in IMC) and simulated (flight time with a view-limiting device like ‘hood’ or ‘foggles’) time. It is possible to log simulated instrument time even in VMC without view-limiting device (‘I used only flight instruments for flying’), but it does not make sense since a view-limiting device is some kind of guarantee of that. The important point for logging actual instrument time – the conditions should be ‘real’ IMC, it usually means in the clouds, not just below the legal VMC minimums. It’s kind of a very contradictory question, but safer to log simulated instrument time only in a view-limiting device, and actual instrument time in the clouds, just to avoid any misinterpretation.

Cross-country time. Basically it’s when we fly not only above the home airport, but there are additional limitations for meeting different criteria. I will explain a bit later.

Total flight time can be logged in any flight when we perform any flight duties.

Dual received means that we have a training flight with the instructor. This time should be logged when we have a flight instructor who logs his dual given time. Usually he wants to even if he doesn’t talk during the flight at all ๐Ÿ™‚

IFR flight time can be logged with IFR clearance and usually under the IFR flight plan regardless of meteorological conditions. Instrument hours should be logged in IMC or with a view-limiting device regardless or ‘real’ ATC clearance: for example, the flight instructor can give a ‘simulated’ ATC clearance.

As I’ve already said, EASA and FAA have some differences in logging the flight time.

PIC for the EASA and FAA.

For the EASA everything is easy: you log PIC only when you act as a PIC. It means that only one person can log PIC time. Usually during flight training it’s a flight instructor as a person who assumes responsibility. Dual received time cannot be logged as PIC time.

FAA regulations allow to log PIC time in some more cases. A pilot may log PIC time when he/she is the sole occupant of the aircraft; is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges; or is acting as PIC where more than one pilot is required (‘required crewmember’ rule). That is described in FAR 1.1, 61.51 [e].

‘Required crewmember’ usually means flying in a multi-pilot aircraft, but it is not the only case. The most interesting part for a training airplane (for example, small Cessna 152 or 172) is that if a pilot uses a view-limiting device, the second pilot becomes a necessary crewmember in VMC under VFR! The second obvious case is flying with a flight instructor and manipulating the flight controls: in that case both can log PIC time.

The second interesting part is logging cross-country time.

Basically “cross-country” a flight between a point of departure and a point of arrival using standard navigation procedures. FAA gives the definition in 14 CFR 61.1(b)(3)(i). EASA FCL also mentions “following a pre-planned route”.

So for the EASA we can log any flight from the airport A to airport B as a cross-country flight if we plan it and use any navigation (even visual aids).

FAA allows to log as cross-country only flights at least 50 miles from the departure airport for meeting private, instrument or commercial minimums. More details can be found in this great paper from AOPA.

For meeting sport pilot minimums any flight more than 25 miles can be logged.

But the most interesting part is meeting the ATP minimums. It is not even required to have a destination! Any flight further than 50 miles from the departure point can be logged as a cross-country flight regardless whether we landed somewhere else or just returned home.

In all other cases we can use a basic definition. For example, part 135 allows to count as cross-country all flights from A to B, even less than 50 miles.

The nightmare starts if we don’t have an electronic logbook: the paper one just don’t have so many columns to sum up everything. Initially I had only the paper one, so it took some time to properly enter all previous flights to my electronic version and set the parameters (‘cross country more than 50nm’, ‘cross-country less than 50nm’, ‘acting as PIC’ and so on).

Hopefully it will help not to get lost in the documents in regulations. You can ask me for more information ๐Ÿ™‚

Aviation Medical in Florida

One needs a US medical examination to fly legally, so it was my first priority for me after I arrived. Yesterday I was not able to visit the doctor, therefore I could not fly as well. So I was sleeping for almost the entire day. Probably that’s just jet lag?

This morning I came to the doctor. The examination was really quick, less than an hour. I got a second class since it’s cheaper and I don’t need the 1st class until my ATP which is still in the far far future.

Now I know my weight in pounds and my height in feet and inches ๐Ÿ™‚

The second important procedure is a fingerprint take, which is required for all foreign students. Everything was quick and professional too.

I got my syllabus, maps and books. Nothing really new except for the maps. I was really happy that I had started learning the material in Moscow: the schedule is tight here, and it’s better to know what to do at least in theory. Even now and again I am thinking about studying CPL books during my free time so that I can be better prepared before practical lessons.

Flight training in the US

As I probably mentioned, I want to continue my flight training in the US for various reasons: native English ATC, easy CPL written test compared to the EASA one, and, of course, cheap flight hours compared to Europe… The main reason is that I don’t want to stay on the ground while I’m studying my EASA subjects, so I can obtain a FAA IR, and those hours will count towards my total flight time. Moreover, due to less expensive prices I can make it entirely in the airplane, which looks beneficial compared to a simulator.

Today I got a verification letter from the FAA. It is valid for 6 months, so I am applying for the US visa. After than I will be able to do nothing but wait.

At a first glance it looks better to study the EASA theory in Moscow now if I want to obtain the EASA license. But the simplest way is not always the best one: I believe that with a Russian passport I need both EASA and FAA licenses since I don’t want to miss any opportunity. If some door opens for me, I want to be prepared before it will close.

Anyway, it looks like a great adventure, probably the greatest one in my life so far. We should do whatever we want to do. I love flying, so I should go flying again ๐Ÿ™‚

First Class Medical

Today I got my first class medical certificate. For pilots there are two classes in Europe: the first one is the highest, and without it one cannot work as pilot. Before that I had the second one because it is cheaper and totally enough for a private pilot certificate (which one I have now).

Initial first class medical usually should be taken only in a hospital. Then it’s possible to go to aeromedical examiner (some doctor approved by the CAA). I’ve never had that certificate, so the only option was a hospital.

There is only one approved hospital for that in Czech Republic. I made a call, and it turned out that the earliest date when I can do that is August, 14. I supposed to be in Moscow that time, so I started my small research where I else I can get my medical. The closest options were Austria, Poland and Hungary.

I chose Poland. They were ready to make the examination without booking in advance, the price was about 150 euros, and Warsaw is on my way home. For example, in Austria you should pay around 500 euros.

There were no queues, the doctors are nice and professional, and the whole thing took about 4 hours. The result was ready at the same day.

Almost all doctors were not speaking neither English nor Russian. The only doctors who spoke English were the ophthalmologist and the therapist, but anyone else spoke slow and clear in Polish so I could understand them pretty well. For all procedures they also provided instructions in English, so I did not have any problem at all. Now I have an impression that I could learn Polish with a very little effort if I want, it seems very familiar to Russian.

So now I know that I am fit, and it’s really great: I can continue my studies to achieve a higher level!

Visit to the CAA

Today I picked up my freshly-issued license. Everything was OK, except for one small mistake in my home address, and it took some more time because of that. The interior of the building seemed very similar to the Russian Traffic Inspection office (or any other legal department), but there were no queues at the CAA ๐Ÿ™‚

At least I found a proper parking space near the CAA. When I had come to take my exam two months ago, I found only P13 “reserved” places. I did not know whether the spots were reserved for the CAA or not, and whether it was legal to park there. In any case, I decided not to take chances, and found another parking area in a mall, in about a 15-minute walk. Today I came just to finish some paperwork, and that’s why I wanted to park somewhere near the building, and I found it. It is P11, which has a barrier and tickets.

Strictly speaking, I am done here, and I can return home, but I drove more than 2000 km, and I’d like to do more than just obtain my papers. That’s why I decided to stay a bit longer, and fly some additional hours.

EASA PPL Written Exam

Today I passed the rest of my written exam subjects. There is a nice point: retaking is totally free. I supposed that I have to pay for all attempts, but I was wrong, in Czech you pay only once.

This time the exam was easy for me. I was better prepared, I knew what to expect, and I went through all of questions in aeroweb.cz. Nevertheless, I am happy that I read the books. I heard that every pilot should do that not just for passing an exam but for solid knowledge, and I am totally agree with that.

Today I saw some students from Hong Kong with graduation certificates from “Flying Academy”. As I know, they did not pass all subjects from the first attempt. Unfortunately I did not have enough time to ask about that school.

I am happy that now I can study in English! ATPL subjects are approximately the same in all EASA countries, but PPL varies significantly. The exam questions in Czech are perfect, but there is not enough evaluation tools in English before the exam. British resources do not work: you can have 95% result in average there and still fail that subject in Czechia. British books help though. Nevertheless, now I am on the ATPL track in terms of theory. I believe that ATPL books and Question Banks match the questions in all EASA countries. Of course, I am not talking about FAA: English is a first language there. I still did not make a final decision about EASA vs FAA track.

Aviation Medical and ICAO English

A summary of my day: I got my medical certificate, and passed ICAO English. I am happy! =)

So, here are some explanations. Everybody has to be healthy to fly. It means that one should pass a medical. There are three types of certificates. From the most strict to less: the first class (the most strict and expensive) for commercial and airline pilots, the second class for private pilots and the third class for air traffic controllers (and, possibly, light sport airplane pilots, I don’t remember it exactly).

The first class can be obtained only in a special clinic (for example, there is only one in Czech Republic, or about three in Poland). The second and the third one is available from designated doctors with special accreditation. At least in Czech Republic the first class medical requires booking an appointment in advance, at least before two weeks. And the price is pretty high. The second class is faster and way cheaper. So, for now I decided to make the second one.

The inspection is thorough, but relatively fast: about an hour for everything. And now I have the document.

Some time later I discovered that I can do the first class in Poland. It is available just as a walk-in, and somewhat cheaper than in Czech. There are all inspections including spirometry, blood analysis etc., and the whole time is more than two hours. It is a bit strange: every country has its own regulations, procedures and prices, even though it is an EASA…

ICAO English is simple. If you can read, speak and understand English, and don’t have any problems with PPL theory (mainly terminology), everything is easy. I don’t say something new: there are tons of books, videos and offline classes. Possibly it requires some practice for fast understanding ATIS/AWOS, but nothing special. Anyway, I have less upcoming paperwork now ๐Ÿ™‚