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Legal Interpretations

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Jiroux-UniversalHelicopters 2014

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Summary

The Question

Can private pilot training count toward the 115 hours of flight training required in a 14 CFR part 141 appendix D commercial helicopter course?

Background

Universal Helicopters asked the FAA to reconsider its September 12, 2013 interpretation, arguing it conflicted with the FAA's stated intent that 14 CFR part 141 let pilots achieve certification in fewer hours than 14 CFR part 61.

The FAA’s Interpretation

No. The FAA affirmed its prior interpretation. Under 14 CFR 141.55, an approved course must meet appendix D's minimum curriculum, which requires 115 hours of flight training for a helicopter rating; because enrollment requires a private pilot certificate, private pilot training hours cannot count. A school may seek approval under 14 CFR 141.55 for a course below the minimums; otherwise changing them requires rulemaking, which may be petitioned under 14 CFR part 11.

Requester
Jiroux
Organization
UniversalHelicopters
Issued
January 14, 2014
Subjects
Pilot Certification & Privileges · Rulemaking & Enforcement · Training Schools & Centers

Regulations Cited

  • 14 CFR Part 11
  • 14 CFR Part 61
  • 14 CFR 141.55

Page 1

U.S. Department
of Transportation
Federal Aviation
Administration
JAN 14 2014
Gordon Jiroux
President
Universal Helicopters
14700 N. Airport Dr.
Suite 100
Scottsdale, AZ 85620
Dear Mr. Jiroux:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591

This letter responds to your request to reconsider the legal interpretation issued "to you on September 12, 2013, regarding curriculum requirements for a training course approved under appendix D to 14 C.F .R. part 141 for a commercial pilot certificate with a rotorcraft category helicopter class rating. In support of your request for reconsideration, you have suggested that the legal interpretation is inconsistent with the FAA' s stated intention with regard to part 141, namely, to permit pilots to accomplish certification in fewer hours than required under part 61.

We have reviewed the information you provided regarding the regulatory requirements in part 141 and affirm our legal interpretation. Section 141.55 states that a training course submitted to the FAA for approval "must meet the minimum curriculum requirements" of the appropriate appendix to part 141 . Appendix D of that part sets forth the minimum curriculum requirements for a commercial pilot certificate and states that an approved course of training for a rotorcraft category helicopter class rating must include 115 hours of flight training. You have suggested that § 141.55 does not require a student to complete the required curriculum hours after enrolling in the commercial pilot course. We disagree. To be eligible to enroll in a commercial pilot course under appendix D, a pilot must hold a private pilot certificate. As such, the hours of training for the private pilot certificate may not be counted toward the 115 flight training hours required under appendix D. As noted in the prior interpretation, appendix D to part 141 does not provide relief to applicants for a commercial pilot certificate with a rotorcraft category helicopter class rating in the same manner that it does to applicants for a commercial pilot certificate with an airplane category rating. We noted under§ 141.55, however, that a pilot school certificated under part 141 could obtain approval for a training course that does not meet the minimum ground and flight training requirements in the appendices to part 141 . Otherwise, any change to the minimum curriculum requirements in appendix D to part 141 would require rulemaking. An individual may submit a petition for rulemaking to the FAA in accordance with 14 C.F .R. part 11.

Page 2

This response was prepared by Anne Moore, an attorney in the International Law, Legislation, and Regulations Division of the Office of the Chief Counsel. If you have any additional questions regarding this matter, please contact my office at (202) 267-3073. I for International Law,

Regulations Referenced

14 CFR Part 14114 CFR Part 6114 CFR 141.5514 CFR Part 141, Appendix D

Snapshot retrieved August 6, 2026.

Summary

The Question

Can private pilot training count toward the 115 hours of flight training required in a 14 CFR part 141 appendix D commercial helicopter course?

Background

Universal Helicopters asked the FAA to reconsider its September 12, 2013 interpretation, arguing it conflicted with the FAA's stated intent that 14 CFR part 141 let pilots achieve certification in fewer hours than 14 CFR part 61.

The FAA’s Interpretation

No. The FAA affirmed its prior interpretation. Under 14 CFR 141.55, an approved course must meet appendix D's minimum curriculum, which requires 115 hours of flight training for a helicopter rating; because enrollment requires a private pilot certificate, private pilot training hours cannot count. A school may seek approval under 14 CFR 141.55 for a course below the minimums; otherwise changing them requires rulemaking, which may be petitioned under 14 CFR part 11.

Requester
Jiroux
Organization
UniversalHelicopters
Issued
January 14, 2014
Subjects
Pilot Certification & Privileges · Rulemaking & Enforcement · Training Schools & Centers

Regulations Cited

  • 14 CFR Part 11
  • 14 CFR Part 61
  • 14 CFR 141.55