2 hours in day VFR?

[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.