FAA Publishes AC 61-65G (cancels 61-65F)

Instructors! The FAA has recently released AC 61-65G. It replaces AC 61-65F. Please take the time to review the changes to this AC prior to your student’s next practical test. You can find it here

Some common issues found when I arrive are reviewed below. Please take the time to ensure your student has the required endorsements for the practical test!

1. Be careful of make and model on solo endorsements required of 61.87. These are make and model specific. If a student initially solos in a PA28-151 but changes to a PA28-181 additional endorsements and training are required.

2. Make sure that the student has all endorsements required for their solo training. This includes 90 day endorsements, each solo cross-country endorsements and any applicable class B endorsements (remember the class B endorsements expire every 90 days!)

3. All required ground and flight training MUST be logged. Whether it is in the back of the logbook or in the remarks for the flight it must be in the logbook and reflect the same language that is in the regulations. Private requirements are found in 61.105 and 61.107. Commercial requirements are found in 61.125 and 61.127.

4. If you are training an applicant for a multiengine commercial (initial commercial) there is relief for the solo requirements found in 61.129(b)(4) for the applicant to perform the duties of pilot in command with an instructor onboard. This cannot count for the 20 hours required for dual time. It is either dual or performing the duties of PIC but not both. Double dipping is not allowed. This is since the performing the duties of pilot in command are in lieu of the applicant soloing the aircraft. Make sure the performing the duties as PIC is not logged as dual and that the remarks reflect that the applicant was performing the duties as pilot in command. See Chief Counsel opinion found here

5. If a student starts the commercial training in a single engine airplane and subsequently changes to a multiengine airplane, most of the training will not count. The regulations state that certain time is required to be conducted in a multiengine airplane. A dual day and night cross-country accomplished in a single engine airplane does not count if the practical is conducted in a multiengine airplane. See 61.129(b)(3). Notice that 61.129(b)(3) i-v all state in a multiengine airplane.

6. Instrument training for a commercial certificate of 61.129(a)(3)i or 61.129(b)(3)i must be completed by an instructor with a CFII. 5 of the 10 hours are required to be in single or multiengine land airplanes. Additionally, the language of the regulations is such that if not properly documented, the training towards an instrument rating will not count. This is because 61.65 just states instrument time required. 61.129 states specific tasks that must be accomplished. While most of these tasks are conducted during instrument training, if they are not documented to meet 61.129(a)(3)i or 61.129(b)(3)i they do not count towards the commercial requirements. See Chief Counsel opinion here and a clarification letter here

7. Verify distances of cross-country flights. A common mistake is to keep the flight at the 2 hour mark for the commercial dual cross-countries, however the airport selected is less than 100nm. Both the time and distance is required, not either or.