Commercial license

Vance

Gyroplane CFI
Or is this still correct?
The most recent information (June of 2019) from a DPE I use based on what his boss said is; flight by reference to instruments needs to be in a gyroplane.

The DPE I used for my rating (Terry Brandt) read it to mean any type of airplane and accepted my log book entry.

It appears the current interpretation has diverged.
 

Ramjet555

Newbie
USING GYRO HOURS FOR A COMMERCIAL HELICOPTER?
There is one operator who promotes the idea of doing a gyroplane rating in order to lower the hour requirements for a helicopter.
I fell for this crazy idea and drove 2000 miles, and found the operator did not know the FARS but alluded a knowledge that did not
exist.

Having a Fixed Wing commercial will lower your hours required in a helicopter but you are not going to achieve that in reality.
Having a Gyroplane commercial will lower your hours required but again, you need helicopter not gyro hours.

SFAR 73 means you need 20 before you go solo for 10 hours, OR, repeat OR, do 10 hours PIC, both
solo and PIC are strictly for the private Helicopter licence.

Now, you need 40 hours before you can take a passenger, so, allowing 30 duel and 10 solo, you will reach that when you
get your private helicopter.

At the end of the day, if you wish to move on, you cannot instruct until you have 200 hours in a Robinson
unless of course you want to and can teach or fly something else other than a Robinson and odds are
that will require specific type training and experience.


NOW, if you get your Helicopter commercial first, you only need 3 hours in the last two months for a recommend
for a Gyro commercial,
and 15 hours PIC in a gyro if you wish to add an instructor.

Again, in reality it will take more than 3 hours / 15 hours, but thats how the regs read.

Bottom line, if your goal is helicopters and Gyro's then do Helicopter first because you will need
those hours before you can instruct etc.
That does not preclude doing a fixed wing commercial first to bring your
commercial requirements down to 70 hours total with 35 PIC.

If you are starting out on this route or considering these ideas, drop me a PM
and I will be happy to show you how to save a lot of money in the process.
Again, most people do not understand these requirements and get them wrong.
 

WaspAir

Supreme Allied Gyro CFI
The most recent information (June of 2019) from a DPE I use based on what his boss said is; flight by reference to instruments needs to be in a gyroplane.

The DPE I used for my rating (Terry Brandt) read it to mean any type of airplane and accepted my log book entry.

It appears the current interpretation has diverged.
I have never seen a gyroplane with an adequate gyroscopic instrument panel (including a turn coordinator, attitude indicator, and heading indicator, all gyroscopic). There is little reason to build such a panel because there are no gyroplanes certified for IFR flight (30+ years ago, there was an ATP-Gyroplane rating listed in the regs, but it was removed, partly in recognition of the lack of approved aircraft). Perhaps some out there have it, but it would use up lots of panel space and electrical power (I can't imagine anybody actually plumbing vacuum-driven instruments in a gyroplane) for little apparent benefit, and I at least haven't seen it. I have flown A&S18As with a partial panel, but never a heading indicator/directional gyro.

If I am correct that there are essentially no suitable aircraft to be found, that would make "needs to be in a gyroplane" a pretty stupid interpretation, imposing a requirement almost impossible to satisfy. A basic long-standing principle of legal interpretation is that any reading that makes compliance impossible is not the right reading. Since the plain text of FAR 61.l129(d)(3)(i) says an aviation training device will do, I think the suggested interpretation is obviously flat wrong on its face. Even a DPE's boss doesn't get to delete bits of the FAR to suit his personal preference or uniniformed understanding; he needs to stick to the text and actually read all of it, including the simulator, FTD, ATD provisions.

Unfortunately for you Vance, you still have to deal with that FSDO. Telling anyone at the FAA that they don't know the regs is always a touchy uphill battle.

I wonder if that same FAA boss thinks the corresponding helicopter requirement has to be done in a helicopter; the reg wording is essentially identical.
 
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WaspAir

Supreme Allied Gyro CFI
USING GYRO HOURS FOR A COMMERCIAL HELICOPTER?
There is one operator who promotes the idea of doing a gyroplane rating in order to lower the hour requirements for a helicopter.
I fell for this crazy idea and drove 2000 miles, and found the operator did not know the FARS but alluded a knowledge that did not
exist.

Having a Fixed Wing commercial will lower your hours required in a helicopter but you are not going to achieve that in reality.
Having a Gyroplane commercial will lower your hours required but again, you need helicopter not gyro hours.

SFAR 73 means you need 20 before you go solo for 10 hours, OR, repeat OR, do 10 hours PIC, both
solo and PIC are strictly for the private Helicopter licence.
In general, if you already have a commercial gyroplane rating, that qualifies you in the Rotorcraft category, and the addition of helicopter privileges is only a class add-on. That means you train to proficiency, with no specific hour requirement.

FAR 61.63 says in part:
(c)Additional aircraft class rating. A person who applies for an additional class rating on a pilot certificate:

(1) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.

(2) Must pass the practical test.

(3) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought ...

(4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.


If you choose to train in a Robinson, you must also satisfy SFAR 73, but there are other training aircraft out there. If you learned in something else, you need 10 hours dual before taking a Robbie solo,

Now, you need 40 hours before you can take a passenger...
I don't remember that from SFAR 73, only that your currency needs to be model-specific, not just category and class. Where is it?
 

Vance

Gyroplane CFI
I have never seen a gyroplane with an adequate gyroscopic instrument panel (including a turn coordinator, attitude indicator, and heading indicator, all gyroscopic). There is little reason to build such a panel because there are no gyroplanes certified for IFR flight (30+ years ago, there was an ATP-Gyroplane rating listed in the regs, but it was removed, partly in recognition of the lack of approved aircraft). Perhaps some out there have it, but it would use up lots of panel space and electrical power (I can't imagine anybody actually plumbing vacuum-driven instruments in a gyroplane) for little apparent benefit, and I at least haven't seen it. I have flown A&S18As with a partial panel, but never a heading indicator/directional gyro.

If I am correct that there are essentially no suitable aircraft to be found, that would make "needs to be in a gyroplane" a pretty stupid interpretation, imposing a requirement almost impossible to satisfy. A basic long-standing principle of legal interpretation is that any reading that makes compliance impossible is not the right reading. Since the plain text of FAR 61.l129(d)(3)(i) says an aviation training device will do, I think the suggested interpretation is obviously flat wrong on its face. Even a DPE's boss doesn't get to delete bits of the FAR to suit his personal preference or uniniformed understanding; he needs to stick to the text and actually read all of it, including the simulator, FTD, ATD provisions.

Unfortunately for you Vance, you still have to deal with that FSDO. Telling anyone at the FAA that they don't know the regs is always a touchy uphill battle.

I wonder if that same FAA boss thinks the corresponding helicopter requirement has to be done in a helicopter; the reg wording is essentially identical.
I feel my role as a flight instructor is to prepare my clients to pass the practical test for whatever rating they are after.

The DPE I use needs to create paperwork that satisfies their boss.

At the risk of pretending I can understand the why of the FAA and their relationship with the Federal Aviation Regulations; inadvertent VFR flight into instrument meteorological conditions (IMC) is an ongoing safety issue. Knowing how to deal with inadvertent flight into IMC in a Cessna 172 is not going to be much help to me or my passengers if I find myself in IMC in a gyroplane.

“61.129 this part that includes at least— (i) 2.5 hours on the control and maneuvering of a gyroplane solely by reference to instruments using a view limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device.”

In my opinion I could fly for two and a half hours solely by reference to instruments in The Predator even though she is not legal for instrument flight. With her Garmin 496 I can recognize and recover from unusual flight attitudes, intercept and track navigational systems and develop partial panel skills.

I have no desire to stir things up so I will work with a DPE to have my client meet the aeronautical experience required by 61.129 as it is being interpreted.

The client I am working with is an airline transport pilot and has hundreds of hours in actual IMC and countless practice approaches.

My commercial pilot, rotorcraft-gyroplane practical test with Terry Brandt was discontinued (failed) because I did not know how to use the Garmin 696 that was on board to intercept a radial outbound. I learned how to intercept a radial; I was signed off by my flight instructor and finished up the practical test with Terry.
 

Ramjet555

Newbie
Sorry, you are correct, SFAR 73 does not state any minimum of pilot in command time but the FARS do.
If you combine the SFAR and FARs requirements, you can deduce the practical solo requirements in a Robinson that are not exempted
by prior Gyro time.

FAR 61.63 at first sounds great, (c) (3) need not meet specified training time...
Then you go back to the solo requirements to get a licence.
SFAR 73 trumps 61.63, you therefore need 20 duel , if you do that in a Robinson,
the you will end up with 20-40 duel before 10 solo to reach private standard.

61.63 is practically useless for going from a gyro to a helicopter.
It does however allow a private or commercial helicopter to gain a Gyro
on a bare minimum of 3 hours in the last two months which
practically is unlikely to occur.

There is a significant credit from going from Fixed Wing to gyro or helicopter
and the most practical route for the least hours would be fixed wing, helicopter then gryo.

Practically, I think people are better off learning in a helicopter first if that is the end goal.
If you learn fixed wing or gyro first you will have to relearn ideas and muscle memory
that will take hours to rectify.




In general, if you already have a commercial gyroplane rating, that qualifies you in the Rotorcraft category, and the addition of helicopter privileges is only a class add-on. That means you train to proficiency, with no specific hour requirement.

FAR 61.63 says in part:
(c)Additional aircraft class rating. A person who applies for an additional class rating on a pilot certificate:

(1) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.

(2) Must pass the practical test.

(3) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought ...

(4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.


If you choose to train in a Robinson, you must also satisfy SFAR 73, but there are other training aircraft out there. If you learned in something else, you need 10 hours dual before taking a Robbie solo,


I don't remember that from SFAR 73, only that your currency needs to be model-specific, not just category and class. Where is it?
 

WaspAir

Supreme Allied Gyro CFI
I feel my role as a flight instructor is to prepare my clients to pass the practical test for whatever rating they are after.

The DPE I use needs to create paperwork that satisfies their boss.

At the risk of pretending I can understand the why of the FAA and their relationship with the Federal Aviation Regulations; inadvertent VFR flight into instrument meteorological conditions (IMC) is an ongoing safety issue. Knowing how to deal with inadvertent flight into IMC in a Cessna 172 is not going to be much help to me or my passengers if I find myself in IMC in a gyroplane.

“61.129 this part that includes at least— (i) 2.5 hours on the control and maneuvering of a gyroplane solely by reference to instruments using a view limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, flight simulator, flight training device, or an aviation training device.”

In my opinion I could fly for two and a half hours solely by reference to instruments in The Predator even though she is not legal for instrument flight. With her Garmin 496 I can recognize and recover from unusual flight attitudes, intercept and track navigational systems and develop partial panel skills.

I have no desire to stir things up so I will work with a DPE to have my client meet the aeronautical experience required by 61.129 as it is being interpreted.

The client I am working with is an airline transport pilot and has hundreds of hours in actual IMC and countless practice approaches.

My commercial pilot, rotorcraft-gyroplane practical test with Terry Brandt was discontinued (failed) because I did not know how to use the Garmin 696 that was on board to intercept a radial outbound. I learned how to intercept a radial; I was signed off by my flight instructor and finished up the practical test with Terry.
I, too, have always thought the purpose of the instrument training was to enable a pilot to complete a controlled 180 degree turn and escape inadvertent flight into IMC. Whether training in a Cessna is meaningful for that purpose can certainly be debated, but it would definitely be more useful if gyroplanes had panels that carried some of the same gyroscopic instruments as a Cessna. Most don't.

I also agree that there is no requirement that the aircraft used for the training actually be legal for IFR flight. For many years, Robinson sold R-22 Instrument trainers that were not approved for flight in IMC (no vacuum pump, no back-up for electric-only instruments, no stability augmentation system, etc.) but you could train all you wanted and even file IFR so long as you flew only in VMC. The issue is what instrumentation is required to cover the particular topics specified in the regs.

I don't know anything about the Garmin 696, so I won't dispute its value for attitude recovery. Is it possible to get just turn coordinator and heading indicator information from it, with attitude information suppressed? That's what I would expect for steam-guage partial panel equivalency, or perhaps there is a way to emulate air data computer/AHRS failure for a glass panel-PFD situation. I don't know what you can selectively fail, or how you do it to the student from a different seat. Are you effectively partial panel all the time when you view-limit to that device?
 

WaspAir

Supreme Allied Gyro CFI
Sorry, you are correct, SFAR 73 does not state any minimum of pilot in command time but the FARS do.
If you combine the SFAR and FARs requirements, you can deduce the practical solo requirements in a Robinson that are not exempted
by prior Gyro time.

FAR 61.63 at first sounds great, (c) (3) need not meet specified training time...
Then you go back to the solo requirements to get a licence.
SFAR 73 trumps 61.63, you therefore need 20 duel , if you do that in a Robinson,
the you will end up with 20-40 duel before 10 solo to reach private standard.

61.63 is practically useless for going from a gyro to a helicopter.
It does however allow a private or commercial helicopter to gain a Gyro
on a bare minimum of 3 hours in the last two months which
practically is unlikely to occur.

There is a significant credit from going from Fixed Wing to gyro or helicopter
and the most practical route for the least hours would be fixed wing, helicopter then gryo.

Practically, I think people are better off learning in a helicopter first if that is the end goal.
If you learn fixed wing or gyro first you will have to relearn ideas and muscle memory
that will take hours to rectify.
The answer, if you want piston economy, is to train in a Hughes/Schweizer/Sikorsky 269-300 series, or an Enstrom, or a Hiller, or a Bell 47, or a Cabri, or something else. 61.63 is still perfectly useful to go from gyro to helicopter so long as you complete your rating in something other than a Robinson. When you've got the rating in your pocket, getting legal in a Robinson takes only 10 hours.

Re-learning is going to be necessary for any order of ratings, assuming you won't stick to just one forever. I started in gliders, then went to airplanes, seaplanes, helicopters, gyroplanes, and balloons, and there is always a new mindset to take on, new responses to pick up, and old habits and expectations to lose. Each makes you better at all the others, if you keep an open mind about the experiences.

I don't bother trying to keep up with continuous Robinson SFAR 73 qualification anymore, finding the model-specific flight review and currency requirements to be a big nuisance.
 

Vance

Gyroplane CFI
I, too, have always thought the purpose of the instrument training was to enable a pilot to complete a controlled 180 degree turn and escape inadvertent flight into IMC. Whether training in a Cessna is meaningful for that purpose can certainly be debated, but it would definitely be more useful if gyroplanes had panels that carried some of the same gyroscopic instruments as a Cessna. Most don't.

I also agree that there is no requirement that the aircraft used for the training actually be legal for IFR flight. For many years, Robinson sold R-22 Instrument trainers that were not approved for flight in IMC (no vacuum pump, no back-up for electric-only instruments, no stability augmentation system, etc.) but you could train all you wanted and even file IFR so long as you flew only in VMC. The issue is what instrumentation is required to cover the particular topics specified in the regs.

I don't know anything about the Garmin 696, so I won't dispute its value for attitude recovery. Is it possible to get just turn coordinator and heading indicator information from it, with attitude information suppressed? That's what I would expect for steam-guage partial panel equivalency, or perhaps there is a way to emulate air data computer/AHRS failure for a glass panel-PFD situation. I don't know what you can selectively fail, or how you do it to the student from a different seat. Are you effectively partial panel all the time when you view-limit to that device?
That is how I would log it.
I will just be following the lead of the designated pilot examiner.
It may be the blind following the blind following the misunderstood.
I continue to learn.
The Predator has a 496 that is smaller than a 696 with similar features.
 

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bryancobb

Junior Member
In my opinion, one role of a flight instructor is to NOT PERPETUATE fake FAR's or hearsay interpretations that are simply not there. Many people in aviation, including DPE's, ASI's, A&P/I.A.'s, and highly experienced folks like airline pilots just make-up rules that don't exist.

Two personal examples:
ONE -The Delta 737 Captain that bought my Brantly B-2b brought his "buddy" (Retired Delta 767 Capt., A&P/I.A., and know-it-all R-44 Owner) to scrutinize the logbooks. They spent about 6 hours at my dining room table with me and "buddy" has a punch-list of 8 or ten serious (according to him) infractions in my maintenance logs that were deal breakers and pretty serious FAR violations. I said "Let's call the MIDO and ask them your questions. "buddy" said Oh Gosh! "I would never do that. With the entries you have in these logs and the things that have been done to this helicopter, they will probably condemn it." Well, we called...and on the speaker phone, the ASI politely told "buddy" that his interpretation of the reg's was wrong and the fact that FAA Form 337's were squeaky clean for all items he had issues with.
TWO - I condemned the Brantly 305 tail rotor blades on a customer's B-2b. Harold Jenkins used to put 305 blades on customers' ships to do an "end-run" around the recurring A.D.'s on B-2b blades. They required 100hr Eddy Current NDT. Well, the 305 blades were NOT airworthy on a B-2. The customer bought a used set of B-2b blades and I installed and balanced them. I got new bearings and other parts from the Brantly factory in Vernon, TX. The certified Timken bearings' box were printed inside with the following..."THIS BEARING SHALL NOT BE USED ON HELICOPTERS." No I am not an A&P. My shop is 10 miles from the local airport. One "know-it-all" that visited my shop with my customer and listened as I explained the bearings were certified by the O.E.M.. The visitor called and reported me to the FAA for illegal maintenance and installing automotive parts store grade bearings. The complaint also claimed I had "fabricated suspected illegal" parts and installed those too. I did! I had! These parts was on the helicopter. It was a "non-flying" bracket that mounted the accelerometer for tail rotor dynamic balancing. The I.A. that was adequately "overseeing" my work called me and said the ASI wanted to come to MY SHOP for an investigation. They came. I was confident and welcomed the ASI in and acted PROUD to show him everything I was doing to the customer's B-2b. After they spent about 6 hours with me, the ASI ended then visit by telling me I was doing an exceptional job in both my meticulous wrenching and my record keeping. Then he told me that before he came, he pulled up the Airman Records of the complainant and me, and went through them closely. He said "I saw you have zero problems, zero accidents, and have participated inn the Wings program for almost 20 years. The complainant has been "violated" by the agency several times and has been in a few accidents. It was pretty clear to me, even before I entered your shop, that I wasn't going to find any issues here, but I had to come look."

The moral of this story...I love the FAA. I find them reasonable and enjoy having them involved in my aviation endeavors. I TRUST them and tell them everything. I don't blow smoke. I don't play dumb. I believe pilots can be safe when they "barely" comply with the FAR's. I don't create imaginary standards that I make up. If the FAR's were to say you need a minimum of 8 hours in flight and 32 hours in simulators to get a Private License, then I'm gonna fight like hell to cram everything into those 8 hours and get your checkride at 40 hours. If decades of data proves that a new 80 hour pilot is safer that a new 40 hour pilot, I'd advocate for changing the FAR's. I wouldn't arbitrarily add 40 more hours of taking the student's money, just because my DPE told me he thinks 40 hours is too early.
 

PW_Plack

Active Member
One local DAR, a retired FAA employee, would not pass experimental gyros receiving their initial airworthiness inspections unless they had a magnetic compass. When confronted about the fact that the requirement in the FAR applied only to aircraft with standard airworthiness certificates, he would turn and say, "the FAA wants every aircraft to have a compass." We joked in our PRA chapter about buying a cheap whiskey compass with a velcro base just for inspections.

The "requirement" for emergency locator transmitters in gyros was another fave years ago.
 
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