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Old 9th January 2014 | 14:09
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FH1100 Pilot
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Joined: Nov 2006
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From: Pensacola, Florida
Gordy, inasmuch as Victorugopcm is from Brazil, he might not be familiar with the FAA's complex (and often incomprehensible) wording of the FAR's. Thus, you can understand if he's confused by your response. In it you say that he needs 30 hours in helicopters, and then quote an FAR that requires 40 hours of total time, but only 19 hours in helicopters.

FAR 61.109...

(c) Does specify 30 hours of total time but does *not* specify that it must be in a helicopter. For that we have to look deeper.

(c)(1) Says that you have to have 3 hours of cross-country in a helicopter
(c)(2) Says that you have to have 3 hours of night flying in a helicopter
(c)(3) Says that you have to have 3 hours of checkride prep in a helicopter
(c)(4) Says that you have to have 10 hours of solo time in a helicopter.

3+3+3+10 equals 19 hours the way they taught me to do math.

The way 61.109 is constructed, parts (a) through (i) all read the same way: 40 hours of total flight time broken down into 20 hours of dual instruction and 10 "solo flight training." Obviously there's a gap of 10 hours of time there...another 10 hours to add up to 40 total.

One would suppose that the "extra" 10 hours could be comprised of additional dual-instruction time or simply "mess-around" solo time. In any case it is not specified that those "extra" 10 hours need be in a helicopter. Presumably they could be acquired in any type of aircraft.

For instance, I have a Commercial Pilot Certificate. Nobody would demand that, if I wanted to add a Gyroplane rating to my existing Rotorcraft rating that I would have to acquire 30 hours in gyroplanes. Alternatively, if I wanted to add a Multi-engine rating to my existing Commercial Fixed-Wing Certificate, I would not be required to have 30 hours of time in a Multi.

Victorugocpm already has an FAA Private Pilot Certificate. As I see it, he does get credit for some of that flight time when he applies for his Rotorcraft Rating and only needs 19 hours in helicopters.

That is...unless there's some other FAA regulation that specifies the 30 hours you referenced - something which would not surprise me in the least given the way the FAR's are constructed and worded.
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