Shea 1990

Page 1

November 5, 1990
Michael P. Shea
Dear Mr. Shea:

This is in response to your letter of September 26, 1990, concerning the crediting of military pilot flight experience toward the flight experience requirements for an Instmment Rating under FAR Section 61.65 and for a Commercial Pilot Airnlane certificate under FAR 61. All of the militruy flight experience in question was acquired while you held an FAA Commercial Pilot Helicopter certificate.

Specifically, you ask whether you may credit several military flights of more than 50 nautical miles which you have made in a Bell UH-1 helicopter toward the flight experience requirements ofFAR 61.65(e)(l) which requires: "A total of 125 hours of pilot flight time, of which 50 homs are as pilot-in-command in cross-countty flight in a powered aircraft with other than a student pilot certificate. Each cross-countty flight must have a landing at a point more than 50 nautical miles from the original deprutme point." You also ask whether you may credit 3 hours actual instrument time and at least 23 hours of instnunent hood time on militruy flights in a Bell UH-1 helicopter, and at least 20 homs in a UH-1 simulator (full motion), toward the flight experience requirements of FAR 61.65(e)(2) which requires: "40 homs of simulated or actual instrument time, of which not more than 20 hours may be iusttument instr11ction by an authorized instt11ctor in an insttument ground trainer acceptable to the Administrator."

Finally, you ask whether you may credit the cross-country flight experience detailed above to the Commercial Pilot airplane certificate flight requirements of FAR 61.129(G)(3)(ii) which requires in part, "100 homs pilot-in-command time including at least (ii) 50 hours of cross-country flight each flight with a landing at a point more than 50 nautical miles from the original depruime point. .. " In my opinion, for Instt11ment Rating pmposes, assmning that the particulars of the flight have in all other respects satisfied the requirements of the regulations, you may credit such time since it was acquired when you held an FAA pilot certificate higher than a Student Pilot certificate, and was in a "powered aircraft". I am not in a position to address whether or not the instmment grom1d tt"ainer in question is acceptable to the Administrator; your local FAA Flight Staudru·ds District Office can provide that infonnation to you directly. However, we would constme the tenn "authorized instt11ctor" as "FAA authorized."

For Commercial Pilot Allplane certificate pmposes, you may also credit such time, assuming again, that the particulars of the flight time in all other respects satisfied the requirements of the regulations. I should point out that while the regulations do not require that such experience be acquired while you hold an Airplane rating, at the time you actually apply for the Airplane rating to your Commercial Pilot certificate, you must satisfy the requirements of FAR 61.129(a).

Sincerely,

George L. Thompson

Assistant Chief Counsel