2 hours in day VFR?

[klubic]

I plan on asking my local FSDO about this, but they're closed so until then...

I'm working on a part 61 multi-engine commercial license. In regard to 61.129(b)(3)(iii): "One cross country flight of at least 2 hours in a multiengine airplane in day VFR conditions..."

Would a 2.1 hour, day VFR flight with .1 actual (to fly through a layer, etc.) satisfy this requirement?

 

[PropsForward]

A DPE or Inspector will most likely not accept this since the 0.1 makes the flight operating under Instrument Flight Rules. You would be hard pressed to prove you were flying VFR, then switched to IFR, went IMC, then VMC, then went back VFR all in 6 minutes. Thats all assuming that you were in class G airspace. If you were in controlled airspace you needed to be on an IFR flight plan and that would really be pushing the envelope for getting that 0.1 of actual.

The good news is that this does not have to be in a multi-engine airplane. You can make this flight in a single-engine airplane and save a buck or two.

The even better news is that if you check your logbook, you may have already satisfied this requirement back when you were working on your private pilot. I know I fly my students day and night dual VFR to meet the commercial regs for this very reason, your instructor may have as well.

 

[johnpeace]

I'm working on a part 61 multi-engine commercial license. In regard to 61.129(b)(3)(iii): "One cross country flight of at least 2 hours in a multiengine airplane in day VFR conditions..."

Uh...
Am I missing something?

 

[klubic]

Well, to put it another way...

Does the entire flight need to be VFR, or only the 2 hours that is required? For example, you could have more than 2 hours of VFR, with only a moment of IFR required to break through some IMC. Would that mommentary IFR invalidate the entire flight as being VFR?

 

[wheelsup]

One cross country flight of at least 2 hours in a multiengine airplane in day VFR conditions

I bolded for effect. By my reading, it seems that the entire flight must be done in day VFR conditions, and that it must be atleast 2 hours in duration. So even if you go over 2 hours, the flight must be completed VFR. Thoughts?

~wheelsup

 

[Lead Sled]

Just to play the devil's advocate...

First of all, I'm assuming that you guys can make a legally file IFR - right? If it's going to be an issue, why even bother logging the ".1" as IFR? You are only legally required to log flight time to show currency. Just depart with an IFR to VFR conditions clearance, blast up through the deck, cancel the IFR portion of the clearance and boogey. Hell's bells, there are a lot of days here in SOCAL when it's legal VFR, but the vis is so bad that you'd never dare actually fly VFR. Another question, just how thick is the layer you're going to be flying through? 500' to 1000' maybe? At 500 fpm that's a couple of minutes at the most. Are you really going to log .03 IFR? How about a Special VFR departure? I'm not suggesting that you do anything untoward, but a little bit of "practicality" can go a long way here. You are compling with the "spirit" of the regulation (2+ hours VFR), if not the "letter" of it (2 minutes or less in IFR conditions).

Now for other opinions...

 

[IP076]

Actually this flight could be conducted on an IFR flight plan, you would just have to remain in Day VFR Conditions the whole flight.

And I'm pretty sure this has to be done in a Multi Engine airplane for the Commercial Multi, and again in a single for the single commercial.

 

[Ralgha]

Actually this flight could be conducted on an IFR flight plan, you would just have to remain in Day VFR Conditions the whole flight.

No it can't. The reg says "VFR", not "VMC". If you are on an instrument flight plan/clearance, you are not operating VFR, even if you are in VMC.

 

[Ralgha]

And I'm pretty sure this has to be done in a Multi Engine airplane for the Commercial Multi, and again in a single for the single commercial.

Nope. I did it in a single for my single commercial (initial). The multi addon didn't require another X/C.

 

[PropsForward]

Ralgha is right, just once. Most people get their commercial in a single (because it is cheaper), then do the multi-add-on. Since your already a commercial pilot, training for the multi add-on is to proficiency, and at the checkride you only have the do the multi-engine stuff. (Ref §61.63).

Second, as mentioned before, do not confuse VFR with VMC. The feds want you to plan, preflight, and execute a flight under Visual Flight Rules. Most people at this point are instrument rated, but for some god unknow reason the feds want to see this VFR flight.

Note to CFI's: Be nice to your private pilot students and have them plan one of the day VFR and the night VFR flight to meet this reg. That way they don't have to do it again later. The nut of this topic is that a commercial pilot is going to have to go up with an instructor and fly 2 hrs for a sandwich and come back to cross this item off the to-do list.

Now, if you're looking to be creative, note the reg say 2 hrs, and 100nm, in most airplanes this is only 40 min each way (even less in a twin). That is fine, use the extra 40 min you need (for a total of 2 hrs) working on lazy 8's and steep spirals while enroute. This way you can at least have some productive benefit from this flight while complying with the letter of the law.

 

[prpjt]

(Second, as mentioned before, do not confuse VFR with VMC)

(No it can't. The reg says "VFR", not "VMC".)


61.129(b)(3)(iii): "One cross country flight of at least 2 hours in a multiengine airplane in
day VFR conditions..."

 

[minitour]

Lead:
I'm with you on this one...don't log the actual. You don't have to anyway, so why bother logging .1 when its really (as you said) more like .04 or .05.

Propsforward:
Could a CFI have a student pilot plan and fly this XC and meet both the PP XC requirements (50nm) AND the Comm XC requirements (100nm) on the same flight?

IOW:
If I fly with my CFI as a student pilot from here to Kentuckyhucky and back both Day VFR and Night VFR. And it is 120nm one way...does that satisfy the PPL and CPL requirements? So I don't have to do them again? Or are you just saying to do the extra flight with the student pilot so its done?

-mini

 

[wmuflyguy]

deleted

 

[IP076]

61.129 pretty clearly states that you need a 2 hr Day VFR Conditions and 2 hr Night VFR conditions for a commercial pilot cert. It also pretty clearly divides it up so that it applies for Single or Multi. The way it reads, you need the cross country in a multi engine airplane for the multi.

Also the reg clearly states "in Day VFR Conditions" it does not say "Visual Flight Rules". Doesn't matter what kind of flight plan you are on, as long as you are "in day VFR conditions".

From 61.123:

(f) Meet the aeronautical experience requirements of this subpart that apply to the aircraft category and class rating sought before applying for the practical test;

 

[PropsForward]

Lead:
Could a CFI have a student pilot plan and fly this XC and meet both the PP XC requirements (50nm) AND the Comm XC requirements (100nm) on the same flight?

IOW:
If I fly with my CFI as a student pilot from here to Kentuckyhucky and back both Day VFR and Night VFR. And it is 120nm one way...does that satisfy the PPL and CPL requirements? So I don't have to do them again? Or are you just saying to do the extra flight with the student pilot so its done?

-mini

Yes, the example you described will satisfy both the PPL and CPL regs. Don't fly an extra flight, just plan a longer flight. For PPL You need 3hrs of x-country dual time. If you plan smartly, you can plan a 2hr day VFR flight and a 2hr night VFR flight (each 100+nm one way)that will satisfy both the PPL and CPL requirements, then you will be effectively be killing 2 birds with one stone and only be 1hr over the min requirements for PPL. You got 10hrs of time to play with anyways (20hrs dual + 10hrs solo = 30 hrs, 40hr needed for PPL = 10hrs to play with).



My day VFR flights tend to focus on pilotage and dead reckoning. While the night VFR flight is focused on radio navigation. This worked very well with all of my students. If later they decided to move on to their commercial, then this was not a step they would have to revisit.

 

[PropsForward]

Also the reg clearly states "in Day VFR Conditions" it does not say "Visual Flight Rules". Doesn't matter what kind of flight plan you are on, as long as you are "in day VFR conditions".

What part of flying through a cloud meets "Day VFR conditions".



This is not too tough. Flying through a cloud or next to a cloud (less than 500/1000/2000, or whatever applies to the airspace you're in at the time). Does not come close to meeting "VFR Conditions". This becomes a composite flight and is really flexing the letter of the regs pretty far.



If it is already in your log book it is going to look weird that the .1 of IMC logged was unjustified and scratched out from the column. This is getting dangerously close to falsifying records and the DPE or Inspector may not want to play along.



You best option is to contact the DPE or Inspector and talk to them about it. You have enough information on this thread to come up with a good reason that justifies the .1 IMC and the 2.0 VMC meeting the regs for the Cert. If he buys in on it then you're home free, nobody will ever look that that line in your logbook again.

If he does not buy in on it, try another DPE.

 

[IP076]

Hey Man, read my posts...no where did I say flying thru a cloud was Day VFR conditions...

I'm on the argument of whether or not you can file IFR (and fly in VFR conditions) and meet the intent of this regulation. I say you can.

Now, about logging that one way or the other, thats up for him, the PIC, to decide. I'd say he kind of blew it cause the whole flight has to be in day VFR conditions.

I usually take a student to LAS and back, more than 100 nm, about a 1.7 or so, easily streched into a 2.0 with a few manuevers. Go there during daylight, get some grub, fly back at night. I think thats pretty standard at my school for this. At least it gets the two single engine requirements out of the way.

 

[minitour]

Yes, the example you described will satisfy both the PPL and CPL regs. Don't fly an extra flight, just plan a longer flight....If later they decided to move on to their commercial, then this was not a step they would have to revisit.

Thanks!

I'm sure I'll have a student some day that will appreciate it...or maybe not...all I hear from most of the "students" at school is:

"My daddy works for ___ airline and after my Commercial Multi checkride, I'm getting a B737 type so I can go straight to work for ___ airline...My daddy says these instructors are stupid...My daddy says that the way ___ teaches landings isn't the REAL way you land...My daddy...My daddy...this is wrong...that is wrong."

Puhleeze...These guys are trying to teach you how to fly a friggin airplane. If you fail, they have to find (what is it 8?) other people to pass just to save their ass!

Okay...vent over...thanks!

-mini

 

[PropsForward]

I'm on the argument of whether or not you can file IFR (and fly in VFR conditions) and meet the intent of this regulation. I say you can.

IP076, You are correct, you can file IFR and then make the flight in VMC that would be legal. I didn't intend to upset you on this. You are correct.

The only caution here is that if your on an IFR flight plan, and it is not an absolute beautiful Sunday afternoon, the odds are if some weather pops up that you will most likely punch on through. This defeats the purpose of the reg. and the temptation may be too hard to resist. At best, you're going to have to write the IMC time off anyways to get the needed compliant logbook entry.

There is also no argument that this is one of them "stupid" regs, because if you meet the commercial mins. (50hr X-ctry), then odds are you have the experience to go someplace new and not get lost. To be sitting in the 250hr neighborhood and having to go fly a dual x-ctry really hits me as a waste of time.

Peace.

 

[minitour]

...
There is also no argument that this is one of them "stupid" regs, because if you meet the commercial mins. (50hr X-ctry), then odds are you have the experience to go someplace new and not get lost. To be sitting in the 250hr neighborhood and having to go fly a dual x-ctry really hits me as a waste of time.

Peace.

Amen to that!

 

[nosehair]

Wow! What a crowd we have here tonight!...I couldn't resist jumping into the middle of this one.

This is how I see it: "Day VFR conditions"--the VFR means Visual Flight Rules, not VMC. If they meant you could do it in VMC conditions on Instrument Flight Rules, the reg would have said "Day VMC conditions". Reason: Not everyone goes immediately from Private to Instrument to Commercial in a flight school factory. There are Commercial Applicants who need training and review on X/C procedures. And the flight school factory student can be furthur challenged on this VFR X/C.
You won't have any trouble fiding lots of stuff a private pilot does not know about "VFR", yes VFR, sectionals, rules, weather, navigation, emergency procedures, etc.

And, no, you cannot use the X/C training you recieved as a student pilot preparing for the Private to meet the commercial requirement of 61.129.
61.129(a)(3)"20 hours of training on the areas of operation listed in 61.129(b)(1)that includes at least - (iii) One cross-country flight of at least two hours in day VFR conditions in a single engine airplane..."

And, I think the spirit of the law is to plan the entire flight as a VFR flight, to revisit those VFR rules and specific pilotage and dead reckoning procedures, not a combination of vfr/ifr to comply with the letter.

It seems everyone is only trying to cut the corners to provide the minimum training that could comply with the letter if they can get a popular opinion that agrees with their interpretation.

...and, yes, I agree that sometimes, with some individuals, this particular regulation is extraneous, and not necessary, but that is not the norm.
All of the training required under 61.129(a)(3) can be made to fit the student - don't cut it short because he meets minimum proficiency. We are killing ourselves doing that.

 

[midlifeflyer]

nosehair, I agree with the rationale, but "VFR conditions" really is a weather term. While "VFR conditions" is not specifically defined, take a look at the FAR Part 1 definition for "IFR conditions"

==============================
IFR conditions means weather conditions below the minimum for flight under visual flight rules.
==============================

There are a number of other places where the word "conditions" is pretty clearly used with VFR or IFR to signify clouds and visibility rather than the flight rules under which a flight is flown. When the FAR wants to say "rules" it almost always uses the phrase "under IFR" or "under VFR" with no modifiers.

If 61.129 wanted to make it clear, it would say something like

==============================
One cross-country flight under VFR of at least 2 hours in a single-engine airplane, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure;
==============================

Buy I agree completely with you that the spirit of the rule is, "to plan the entire flight as a VFR flight, to revisit those VFR rules and specific pilotage and dead reckoning procedures" and, absent unusual conditions (which I suspect, unless the verbiage is simply an error) is the reason the rule was written the way it was) a CFI who does these dual flights under IFR is doing her student a disservice.

 

[prpjt]

This is how I see it: "Day VFR conditions"--the VFR means Visual Flight Rules, not VMC


I agree. And the word 'conditions' in that phrase makes it mean:
CONDITIONS that allow flight under visual flight rules.

Notwithstanding what the reg says, I also agree that it's prudent to have the applicant do the flight under VFR, so they can revisit VFR flight planning. It seems as though many pilots put that knowledge on a shelf somewhere immediately after their Private checkride.

 

[IP076]

I personally agree that you can use the flight to get re-orientated with VFR navigation.

The school syllabus I go by actually does the cross country when the student starts a multi instrument training segment. We usually use it to get back in the swing of flying the twin, but I've had a student who was a really decent pilot and we used it as an intro to IFR flight planning....all in VFR Conditions....

 

[PropsForward]

And, no, you cannot use the X/C training you recieved as a student pilot preparing for the Private to meet the commercial requirement of 61.129.
61.129(a)(3)"20 hours of training on the areas of operation listed in 61.129(b)(1)that includes at least - (iii) One cross-country flight of at least two hours in day VFR conditions in a single engine airplane..."

Sorry but there is no regulation saying you can not kill two birds with one stone. Hence, you most certainly can double up on the training. I have sent several students to checkrides with both DPE's and Inspectors. Where they relied on training used during other certificates. Some additional examples:
1. Instrument rated helicopter pilot need 15hrs IFR for the instrument airplane addon. I used the 3 hrs he got with his private toward the 15.
2. Another instrument student knew commercial was his next step. He had got his complex in 3hrs, had 100hrs+ complex on his own. But commercial required 10hr complex "training". We did 4hrs in a complex during his instrument ride, then 3hrs in pratical prep for his commercial.
3. 3-4 students got their commercial using the current topic of utilizing training done during their private to satisfy the requirments of the commercial. Worked some other requirments such as the night requirements in as well if memory servered.

Yes, you can double up on the training. Any day of the week.

We are killing ourselves doing that.

This statement really bothers me. While I agree the pay is low, and we need the hours to move on in our aviation carrer. We must also provide an honest service. Teaching the long way or beating a pesky detail to death to milk a few extra hours into our own logbook is wrong as well.

 

[midlifeflyer]

Sorry but there is no regulation saying you can not kill two birds with one stone.

True. But for better or worse, that's the position John Lynch has consistently taken in the Part 61 FAQ - pre-private "area of operation" training and solo requirements may not be used to meet "area of operation" training and solo requirements for advanced certificates or ratings.

I think nosehair mentioned the instrument examples. Another is a specific FAQ saying that a student pilot who does a long cross country that also meets the commercial long cross country distance requirements can't use it. It's one of the "better" answers since it's short and describes the overall philosophy succinctly.

==============================
QUESTION: Apart from § 61.129(a)(3)(v), is there anything in § 61.129 that implies that I cannot count any "aeronautical experience" obtained during my pre-Private training? I believe the old regulations stated this, but it has been removed from the new regulations.

Simple question: If I flew a student solo XC (pre-Private) from Seattle to LAX and back in a C172, could I count that towards my Commercial requirements?

ANSWER: Ref. § 61.129(a)(2)(ii); YES. The pre-Private solo cross-country does "count" toward the § 61.129(a)(2)(ii) [i.e., the requirement for 50 hours of PIC cross-country time].

HOWEVER, the answer is NO, if your question is asking: "Can this be used to meet the § 61.129(a)(4) "long cross-country solo flight" commercial preparation?"

Section 61.129(a)(4) specifies that the reason for such flight (commercial preparation) must relate to § 61.127(b)(1). This was not the training (certificate preparation) requirement being met for the "pre-Private solo cross-country."
==============================

While not regulatory nor technically binding, the FAQ is part of the FAA's effort to have DPEs and FSDOs apply Part 61 consistently.

 

[nosehair]

I have sent several students to checkrides with both DPE's and Inspectors. Where they relied on training used during other certificates.

You cannot use an example of DPE's and Inspectors allowing this practice, because they get it wrong, too. Yes, they do. Reference John Lynch's FAQ site and Common Sense. In reference to common sense, I did say that *some* people may not need some of the training that some of the regs require, and judicious use of creative interpretation can be a good thing. I did say that. I am saying we shouldn't be braggin' about cuttin' the training on everyone as if it is a hotshot thing. Kinda like braggin' about solo'ing someone in less that 8 hours....That just perpetuates the whole "git that ticket in the minimum time".
I would bet a dollar to a do-nut that your Commercial Applicant with 3 hours *training for checkride* was NOT keeeping the ball centered during Chandelles & Lazy-8's. Yeah, he "got his ticket", but could he fly?

We must also provide an honest service. Teaching the long way or beating a pesky detail to death to milk a few extra hours into our own logbook is wrong as well.

I don't get paid by the hour, and I've got more hours than I can remember. I'm doing it for the quality of life that I enjoy, seeing people learn to become master of the flying machine, and more importantly, their own destiny.

Did you ever read Jonathon Livingston Seagull?...or anything by Richard Bach?

 

[PropsForward]

Hmmmm.

Ok, I certainly get the gist of your reply; Legal vs. Safe.



It is important to understand that just because it is within the letter of the regulation that it may not necessarily be the safest approach to take (or teach).



My personal opinion on this varies somewhat. I am a big advocate of understanding safety in the world of aviation and understanding the difference between such things as being “FAA current” to carry passengers vs. being “Proficient” to carry passengers. Instrument flying is another big one. This list goes on and on. And I am on board with you on this. It is very important.



When it comes to the certificates, I do feel that they are a cumulative representation of your experience and qualifications. This is why I feel so strongly about making the most of a students time during his/her training. A student is not deprived when flying to a higher standard (to satisfy the requirements of a future certificate); in fact I find it to be educational and enlightening, making the student a better pilot.



I let an instrument student get some complex training. On the surface this was an economic benefit for the student as it only added a few bucks per hour to the cost of his current training, and satisfied the requirements for his future commercial ticket. This opened a whole new set of procedures and checks that the student had to study, prepare, and include in his operation of the aircraft. I certainly feel that this “real world” training was far more valuable than spending an extra few hours beating a lazy 8 to perfection when it was already to PTS proficiency.



It is equally important for the CFI to recognize if a student is not flying to PTS standards and provide additional training as necessary. But to say the FAA regulations are to “easy” and set a higher bar is imposing unnecessary burden on the student with minimal benefits. It is important to understand that when we instruct for the purpose for a rating that we should stay on task. Comply with the regs, teach to PTS standards, and save the rest for recurrent training.



If I take one of my commercial students that I spent 1hr getting to PTS standard for Lazy 8’s, and you take one of your commercial students you spent 5hrs getting to better than PTS standards. And we reevaluate each of their ability to fly the Lazy 8 1 year after they got their commercial ticket, I would bet a dollar that (1) they would barely remember (if at all) the details of the maneuver, (2) not be able to fly it to PTS standards. I am a check pilot and run into this repeatedly.



Now getting super way off topic (but is where the gist of this is all going) is recurrent training. A Flight Review only requires 1 hr of ground, 1 hr of flight. This is clearly not enough. The Wings program is a great help, it put the pilot in proficiency training mode 6hrs to the flight review 1hr. The IPC is even a sorer spot with me. I am amazed at how many pilots have minimal instrument experience, even less approaches, and have IPC endorsements in their logbook with only a hour or two of flight time. While this person is certainly better off that before the IPC, I would not go as far to say I would recommend this person fly anything less than enroute IMC. You just need more time than this. This in my opinion is the weak area of Instructing.



Anyways……..

 

[nosehair]

.





If I take one of my commercial students that I spent 1hr getting to PTS standard for Lazy 8’s, and you take one of your commercial students you spent 5hrs getting to better than PTS standards. And we reevaluate each of their ability to fly the Lazy 8 1 year after they got their commercial ticket, I would bet a dollar that (1) they would barely remember (if at all) the details of the maneuver, (2) not be able to fly it to PTS standards. I am a check pilot and run into this repeatedly.



……..

Props, Thanks for youe insightful reply. I think we're both talking the same thing, just in different ways.

Now, let me take the pleasure of a continued conversation regading the above quote.
Yes, the details of the maneuver are not so important as the underlying skill that results from the ability to perform it.
I repeatedly see Flight Instructor Applicants who do not make a conscious attempt at keeping the ball centered during the lazy 8, or other maneuvers.
They have not been taught from Day 1 how to properly coordinate turns. It is very easy to fly around driving the wheel like a car and getting away with it because it dosn't really matter in the air. It only matters during landings. And examiners have come to accept landings with side-loads due to "driving" the nose down the runway, which does not work.
Anyway, the objective of the chandelle and lazy 8 is to improve coordination. Also orientation, planning, and pilot feel for varying control forces. These words are right out of the Airplane Flying Handbook.
But most pilot applicants are only concerned with the PTS standards with very little emphasis on coordination and control feel. They are focused in on th planning and orientation - keeping within PTS standards.
I start training these maneuvers with total emphasis on coordination. "Let's do some of this (making wing-over motions with my hand) while keeping the ball centered". Keeping the ball centered is the only focus at first. Then when the student can do some "wing-overs" while continually changing rudder pressures, I introduce the concept of specific degrees of turn, bank angles, altitude/airspeed control, etc., and make it look like a "Lazy-8".
The purpose of maneuver training is to teach a person to have control of the airplane, and the purpose of PTS standards is to "Standardize" some maneuvers that can be evaluated by a first-time observer - a check pilot.
Teaching a rote PTS maneuver doesn't always do the job. Unless each element is properly addressed. And I blame the Examiners mostly for that. They allow maneuvers with the ball out of center to pass. They allow landings way off of centerline, and sideways. Otherwise, we wouldn't have this problem. Flight Instructors teach what gets passed. It's a human thing.

But, anyway, your student of 1 year ago may not remember the details of a lazy-8, but the coordinated skill he will develop will last a lifetime. Hopefully, a long, enjoyable flying one.

 

[PropsForward]

I couldn't agree more. The cat's-meow is to teach the required items and teach the student the coorilation and application of the essence of the task to real world everyday flying and safety.

If an instructor sees a task as meaningless, then it is the instructors responsibilty to look under the skin and find the meaning to the task and teach with a purpose.