Question on Multi-Commercial Student

[PanJet]

I am training my first student for multi who doesn't already have a CSEL. In fact, I believe he's the first person to elect to do the CMEL before the CSEL at our flight school. My question is regarding the "solo" requirements.

I have trained him to the point where I would be comfortable signing him off to solo should the insurance allow it, so I feel that I have accomplished the intended nature of the supervised solo, however, I have a question.

Does endorsement #62 from AC61-65E need to be signed for the student if they're not actually going to be soloing but rather "performing the duties of PIC" with an instructor on board?

From AC61-65E:

To act as PIC of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: section 61.31(d)(3).
I certify that (First name, MI, Last name) has received the training as required by section 61.31(d)(3) to serve as a PIC in a (category and class of aircraft). I have determined that he/she is prepared to serve as PIC in that (make and model of aircraft).

From 61.31:

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—

(3) Have received training required by this part that is appropriate to the aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received the required endorsements from an instructor who is authorized to provide the required endorsements for solo flight in that aircraft.

From 61.31 I get that the student only needs this endorsement if they're actually going to be acting PIC, but I wanted you guys' opinions on this.

[tgrayson]

Originally Posted by PanJet

Does endorsement #62 from AC61-65E need to be signed for the student if they're not actually going to be soloing but rather "performing the duties of PIC" with an instructor on board?

No. As you say, they're not really acting as PIC (nor logging it as such), so the situation doesn't change legally from a normal training flight.

The whole thing is a bit of a fraud, IMO.

[Maurus]

I would imagine it would be the same endorsements as soloing a single engine student. I am not an MEI but it would make sense. Then again, when does the FAA make sense.

[tgrayson]

Originally Posted by Maurus

I would imagine it would be the same endorsements as soloing a single engine student.

You're only a student pilot once in your life. Once you acquire some other pilot certificate, you never again need student pilot endorsements.

[nosehair]

Everyone will agree that the solo endorsement is not required.

That's because, in the history of checkrides, the multi-engine is normally an add-on to an initial single-engine rating, and as far as I know, no examiner has required the multi-engine applicant to have a solo endorsement - but they should.

You probably know 61.47 relieves the examiner of being PIC on a checkride, therefore, the applicant is the acting PIC. This would require a solo endorsement to be legal as PIC of a multi on any multi checkride.

But, no one asks to see that, so... you can follow the crowd and do as they do and probably be ok.

Just thought I'd throw that in.

[tgrayson]

Originally Posted by nosehair

no examiner has required the multi-engine applicant to have a solo endorsement - but they should.

No, they shouldn't. You don't need an "acting PIC" endorsement to take a checkride in a twin, per 61.31(k)(2)(i).

(Haven't we been through this before?)

[nosehair]

Originally Posted by tgrayson

You don't need an "acting PIC" endorsement to take a checkride in a twin, per 61.31(k)(2)(i).

(Haven't we been through this before?)

OK, forgot about that one, and yeah, we prolly have, but that must have been day before yesterday.

[Sidious]

Originally Posted by PanJet

To act as PIC of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: section 61.31(d)(3).
I certify that (First name, MI, Last name) has received the training as required by section 61.31(d)(3) to serve as a PIC in a (category and class of aircraft). I have determined that he/she is prepared to serve as PIC in that (make and model of aircraft).

However this would be needed for a student to solo if they were doing their initial commercial in the multi correct?

Also why would a student elect to take this route? My school will promote this next semester and to me it seems a waste for the student since they cannot even count the multi time as PIC (except in solo flight). Thoughts?

[tgrayson]

Originally Posted by Sidious

However this would be needed for a student to solo if they were doing their initial commercial in the multi correct?

Yes.

Also why would a student elect to take this route?

Some people think it's a better way to build ME time. If an Arrow is $130/hour and the twin is $200, then you're kinda getting ME time for only $70/hour.

I've had a couple of students go that way. Their choice, I didn't encourage it.

[cencal83406]

Not if they already had the ME rating..... ? why would you need a solo endorsement for comm/me if your pvt/me?

[Sidious]

Originally Posted by cencal83406

Not if they already had the ME rating..... ? why would you need a solo endorsement for comm/me if your pvt/me?

You wouldn't - My scenario was Pvt/SE and Comm/ME

[Maurus]

Originally Posted by tgrayson

You're only a student pilot once in your life. Once you acquire some other pilot certificate, you never again need student pilot endorsements.

Eh, I see what I did there. Some odd reason I was thinking he was getting his private to commercial in the ME first and didn't have his private SEL.