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Multi Commercial

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61.129 is Aeronautical Experience - What flight (or simulator) times you must have.

61.127 is Flight Proficiency - What you have to learn how to do in the airplane.

61.125 is Aeronautical Knowledge - What you are required to know (ground school).

I don't think I've seen an applicant go to an examiner with 235 airplane hours and 15 "ground instruction" hours on Preflight preparation and preflight procedures as outlined in 61.127.

I agree with you that 61.129 doesn't specify all of the multi-engine flight time. Some can be done in a single. I don't agree with doing "preflight" preparation on the ground. It should come in an endorsement after a flight "Preflight preparation and procedures, short field takeoff, steep turns..."

-mini
 
61.129(4)(b)(3) (ii) 10 hours of training in a multiengine airplane that has a retractable landing gear, flaps, and controllable pitch propellers, or is turbine-powered

...seems to be specifically referring to the commercial complex-aircraft training requirements, giving you the option to do the rest of the 20 hours of training in a non-complex twin (could happen, you never know!). The single-engine commercial requirements are the same. An initial commercial applicant in a SINGLE ENGINE airplane could technically do their training in a fixed-gear Piper Warrior (for example) plus 10 hours in a retractable (say an Arrow), then split the checkride into 2 flights, doing everything in the Warrior except for one or two turns in the pattern in the complex airplane to demonstrate competency. I've seen that done a couple of times, mostly due to airplane availability issues, etc. But, if the initial commercial is in a single, the minimum times need to be met in a single. Similarly, that 20 hours of training needs to be in a multi if the initial commercial is in a multi, since 61.127 (b) (2)specifically refers to multiengine airplanes.
 
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