Instrument Dual and TAA Dual Training Hours not Eligible for Commercial?
I was hoping to save some time using the training I got in a TAA during Instrument traning for Commercial.  Apparently, Commercial training has to be logged in accordance with 61.129(a)(3)(i) for the 10 hours of instrument, 61.129(a)(3)(ii) for the 10 hours of complex or TAA, 61.129(a)(3)(iii) for the 2 hour day cross country and 61.129(a)(3)(iv) for the night cross country.  At least that is what I am getting from the DPEs around here.  Seems a little redundant to me.
3 Replies
Ronald Levy
1516 Posts
You don't have to specify 61.129 in the log entry for instrument or TAA training to count toward the 61.129 requirements for Commercial.  The instructor need only put the correct words in Remarks for the log entry.  For the 61.129(a)(3)(i) requirement, that means using the phrases "attitude instrument flying", "partial panel", "unusual attitude recovery", and/or "intercepting/tracking".  For the 61.129(a)(3)(II) requirement, that means noting the aircraft used for that training was a TAA.  Any DPE who says that is not enough should be asked to consult with his/her POI at the FSDO for the correct guidance from AFS-600/800.
Michael, as a DPE, I will say that you are not alone in this dilemma. Flight instructors are not being taught how to properly endorse when it comes to 61.129(a)(3)(i). The instructor must clearly notate, whether it's with a regulation number or verbiage from the regulation, this training was conducted. The FAA is clear that the time flown on the instrument rating can count towards the commercial requirements if said time is correctly logged (https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Theriault%20-%20(2010)%20Legal%20Interpretation.pdf and https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Hartzell%20-%20(2010)%20Legal%20Interpretation.pdf). As far as the TAA training, the DPE should look for the training to have been completed. It's that simple. Now, the two cross-country's must be done under 61.129(a)(3)(iii) and (iv). You would be surprised how many people have shown up to a checkride and one of the two cross country's were not completed. I hope your commercial checkride is a success.
Ronald Levy
1516 Posts

Anthony Walker:
The instructor must clearly notate, whether it's with a regulation number or verbiage from the regulation, this training was conducted.

I would like to emphasize the "or" part of that statement.  As I said above, unlike Anthony, some DPE's seem unaware of that "or" and need to be guided by their POI at the FSDO.