Helicopter Flight Information

Adding a Commercial Helicopter Rating to a Private Airplane Certificate

I continue to receive emails inquiring about this; there are many incompetent instructors and examiners who think that you can not add a commercial helicopter rating to a private airplane certificate! THEY ARE DEAD WRONG!   You can do it, and you should; it is the best spent money in flight training!  See the bottom of this page for a list of flight schools who either are, or may be, ill-advising students on this issue.  Don't let negligent DPE's, schools, and instructors steer you wrong.  Note also that student sign-offs are inappropriate for pilots adding a category.  Read on... 

The number of instructors and Examiners who don't understand adding on a category amazes me since this is suppose to be covered during the application, training, and oral for a CFI certificate.  This demonstrates negligence primarily on the part of the FAA since they have failed to appropriately educate their representatives, the DPE's, who are falsely stating the facts regarding these add-on ratings.  This is a basic and simple issue for which there is no excuse for the confusion. 

An airplane instructor I had employed for a brief time was instructing a helicopter student of mine who had already received his helicopter private pilot's license.  This instructor could never get it through his head how he needed to sign of the rated pilot no mater how much I explained it to him.  In fact, he even called his former instructor who also advised him incorrectly.  I eventually had to let this instructor go because he never did get it right, and he never gave the student not even one correct sign off.

Most importantly of all, YOU CAN ADD A COMMERCIAL HELICOPTER RATING TO A PRIVATE AIRPLANE CERTIFICATE.  Read on, and you will understand this.  YOU DO NOT HAVE TO ADD ON A PRIVATE HELICOPTER BEFORE A COMMERCIAL if you already posses a private airplane certificate!  Another issue of significant importance is the fact that as a flight instructor, you can not solo, a pilot adding a rating to an existing certificate as you would solo a non-rated student, but rather you sign that pilot off to act as PIC in solo operations in an aircraft for which he/she does not hold the appropriate ratings (see AC 61.65E, Appendix1, Page 16, example 62*).  If you as an instructor incorrectly sign-off an applicant who is already rated in one category, then you are as negligent as the examiner who passes the same student, or has ill-advised you in what you can and should do.

Let me say this again:  You can not solo a rated pilot; so to issue any sign off that you would put in the logbook of a student pilot is inappropriate for a rated pilot who is adding a category.  Understand that he/she may be your student, but they are not a 'student pilot'.  A student pilot has no pilot rating; they possess a student pilot certificate which is also their medical.  There are very specific requirements as to the sign-off for a pilot adding a category; anything else is WRONG!  Even if the applicant holds a student pilot medical, if they already possess a pilot certificate, you do not add the additional category aircraft to their medical which was their student pilot certificate prior to the issuance of their pilot certificate.  Once a student receives his/her first rating, they are no longer a 'student pilot'!

There are only three sign-offs for any pilot adding a category at the commercial level to an existing rating at the private level, four if they miss any questions on the written test; only two sign-offs if they are adding a category at the same level i.e. a private to private, or commercial to commercial.

This is completely different than soloing a student pilot.  I can not tell you how many log books I have reviewed that do not have the appropriate sign-offs for add-on ratings.  Many times these have not been caught even by the examiners who have subsequently signed off on incorrect sign-offs.  It is negligent for examiners to lack knowledge on this subject, and it is crooked for flight schools to tell students otherwise.

Now there is of course another reason that a school, or an examiner who is 'on sight' (which raises ethical issues), or a CFI might try to argue this point; or try to convince a prospective student that they must first add on a private rating.  MONEY! You have it, and they want it!  You see, you can add a commercial rating for the same cost as you can add on a private.  Why then would you add on a private?  These facts are true the other way as well (adding a fixed wing commercial rating to a helicopter private).  Dollar for dollar, which is the smarter way to go?  Now if you only want a private, that is fine, but understand that the check ride is the same for either, only the tolerances are different, and I never trained a pilot for a private who couldn't pass a commercial check ride.  The most important issue here is understanding that you have the option.  If you add-on the private first, it will cost you more than twice what it should to get your commercial.

Now there are of course some requirements that must be met, but they are minor.  Note the commentary in Blue

§ 61.129 Aeronautical Experience

(c) For a helicopter rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with a rotorcraft category and helicopter class rating must log at least 150 hours of flight time as a pilot that consists of at least:

(1) 100 hours in powered aircraft, of which 50 hours must be in helicopters.  This is the easiest requirement to be met when adding a commercial helicopter to the airplane private, if someone holds their airplane private, then most likely have at least 60 hours in airplanes.  The training for the commercial will result in not less than 50 more hours.  We have this covered then don't we!

(2) 100 hours of pilot-in-command flight time, which includes at least—  This one is a little harder, but no problem.  Remember that all solo time is PIC time...  Yeah, everyone tends to forget that!!!  Also, ALL time logged after receiving the private in a given category is also PIC time even while receiving training for an additional rating (not category add-on).  All you have to do is add your solo time to your PIC time, and you have your total.  It could be that you might want to build a few more hours in the airplane since you will need a total of 65 hours PIC before commencing your helicopter commercial training, or else you will need to log more solo hours in the helicopter at a much greater rate.

(i) 35 hours in helicopters; and  This is easy, and there are a couple of ways to accomplish it.  I know, I know, many will argue this, even some inspectors.  But solo 35 hours since solo IS PIC, that is one way!  With your dual and solo, you will have over 55 hours in helicopters.  You need the time anyway.  However, it is not necessary since once you are able to control the aircraft yourself, you are PIC even while training.  See the following email from an aviation inspector.  Note that his contact info has been removed to prevent him being inundated with information requests.

Pilots undergoing training for a certificate or rating may log
pilot-in-command (PIC) flight time when:

(1) the pilot is the sole occupant of the aircraft;
(2) when the pilot performs the duties of PIC and is the sole manipulator
of the controls under the supervision of a qualified pilot in command and
is receiving training in an approved PIC training program; or
(3) when the supervising pilot holds a commercial pilot certificate and
flight instructor certificate with appropriate category and class ratings
to the aircraft being flown and the pilot performing duties as PIC is the
sole manipulator of the controls.

If you have any questions concerning PIC flight time please contact me at
425-227-2890.

Sincerely:

Roy H.
Aviation Safety Inspector

(ii) 10 hours in cross-country flight in helicopters.  Easily covered in the solo, just must meet the 25 mile requirement.

(3) 20 hours of training on the areas of operation listed in §61.127(b)(3) of this part that includes at least—  This is dual, and is also easy since every hour of training qualifies, and it will take at least 20 hours just to be ready to solo anyway.

(i) Five hours on the control and maneuvering of a helicopter 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;  This can be done during the 20 hours mentioned above or if pilot skills lack, then perhaps a few more hours to cover.

(ii) One 2-hour cross country flight in a helicopter in daytime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure;  Note that this is a dual requirement, and again easily covered in the 20 hours.

(iii) One 2-hour cross country flight in a helicopter in nighttime conditions that consists of a total straight-line distance of more than 50 nautical miles from the original point of departure; and  Note that this is a dual requirement, and again easily covered in the 20 hours.

(iv) Three hours in a helicopter with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.  This is one that always cracks me up with a new instructor.  If all training is accomplished within 2 calendar months, no further notation is necessary.  BUT, if you are training at one of the large schools where you never get flight time (such a shame), then of course you are not going to get enough flight time to complete the training in 2 months therefore under that condition, you would indeed need to ensure this requirement is met.

(4) Ten hours of solo flight time in a helicopter or 10 hours of flight time performing the duties of pilot in command in a helicopter with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (c)(2) of this section), on the areas of operation listed under §61.127(b)(3) that includes—  This is a really neat, relatively new change.  This is the only 10 hours which you can fly with an instructor and log PIC.  

(i) One cross-country flight with landings at a minimum of three points, with one segment consisting of a straight-line distance of at least 50 nautical miles from the original point of departure; and  In the past, before the permission to do this with an instructor and log it as PIC, I always included this during the 20 hours of training.

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern).  If the pilot has sufficient night experience, he/she could do this solo, but now can be done with the instructor onboard and logged as PIC.

So you see, it is easy to add a commercial helicopter rating to an airplane private pilot certificate.  Anyone telling you otherwise either don't know, or is lying.  Crooked schools are a dime a dozen, just research it good and you will see.

The Federal Aviation Regulation § 61.123 (h) follows:

§ 61.123   Eligibility requirements: General.

To be eligible for a commercial pilot certificate, a person must:

(a) Be at least 18 years of age;

(b) Be able to read, speak, write, and understand the English language. If the applicant is unable to meet one of these requirements due to medical reasons, then the Administrator may place such operating limitations on that applicant's pilot certificate as are necessary for the safe operation of the aircraft.

(c) Receive a logbook endorsement from an authorized instructor who:

(1) Conducted the required ground training or reviewed the person's home study on the aeronautical knowledge areas listed in §61.125 of this part that apply to the aircraft category and class rating sought; and

(2) Certified that the person is prepared for the required knowledge test that applies to the aircraft category and class rating sought.

(d) Pass the required knowledge test on the aeronautical knowledge areas listed in §61.125 of this part;

(e) Receive the required training and a logbook endorsement from an authorized instructor who:

(1) Conducted the training on the areas of operation listed in §61.127(b) of this part that apply to the aircraft category and class rating sought; and

(2) Certified that the person is prepared for the required practical test.

(f) Meet the aeronautical experience requirements of this subpart that apply to the aircraft category and class rating sought before applying for the practical test;

(g) Pass the required practical test on the areas of operation listed in §61.127(b) of this part that apply to the aircraft category and class rating sought;

(h) Hold at least a private pilot certificate issued under this part or meet the requirements of §61.73; and

(i) Comply with the sections of this part that apply to the aircraft category and class rating sought.

Now as you see §61.73 applies only to Military trained pilots so that spec is not relevant to this discussion.

What does ...(h) say?  It says, 'hold at least a private pilot certificate issued under this part'...  What part? Part 61. There is nothing anywhere in the regulations that says the pilot must first obtain a private certificate in the category for which he/she is adding on a rating.  Keep looking, you will not find it because it does not exist.  Therefore, any pilot holding a private pilot certificate in any category may add a category at the current or next level (commercial) which meets the requirements stated in (h) above.  Yes, you will talk to many people who will dispute this, but they are wrong plain and simple; just push the issue to the top, call the FSDO, call many FSDO's.  Most of all, call one in a state where they actually have knowledge and experience; as opposed to a state where there is little flight training volume.

Also Refer to FAR §61.31(d) Additional Aircraft Category, Class and Type Ratings.

Sign-offs - Here we go again; if you are an instructor, thumb through a couple of logbooks and you will find all kinds of errors; however there is no excuse for them since both the CFI, and the Examiner are required to have reviewed them.  Why do the errors exist?  Well, watch how the process works and you will see.

Refer to FAR Part 61 §61.63, and AC 61-65E.  Note that §61.63 is often overlooked by both CFI's, and Examiner's alike.  §61.63 Additional Aircraft Ratings note paragraphs (2) and (4).  Paragraph (2) mentions the sign-off requirements, and paragraph (4) mentions the requirement or lack thereof for a written test; if a written test is required which would indeed be the case if adding a Rotorcraft, Helicopter Commercial rating to an Airplane, Single Engine Land Private; then a sign off for the written test would also be required.  (Is there anything here that states that a pilot must first receive a private add-on?  NO! Nor is there anywhere else in the FAR's).

Per AC 61-65E, Page 17, Paragraph 26:

26. ADDITIONAL AIRCRAFT RATINGS (OTHER THAN ATP). Specific knowledge, flight proficiency, flight experience, and endorsement requirements for additional category, class, or type rating (for other than at the ATP level) are located in section 61.63.

a. Category and Class Ratings. Applicants adding a category and/or class rating to a recreational pilot certificate or higher must have an instructor’s recommendations and appropriate endorsements. An applicant need not take an additional knowledge test, provided the person holds an airplane, powered-lift, rotorcraft, powered parachute, weight-shift-control aircraft, or airship rating at or above the pilot certificate level sought. An applicant must pass the required practical test appropriate to the pilot certificate for the aircraft category and, if applicable, class rating sought. Additionally, applicants must comply with the requirements of section 61.63, as noted below:

(1) Category Ratings. Applicants must receive the training and have the aeronautical experience required by part 61 that applies to the pilot certificate level for the category, and if applicable, class rating sought.

Note in paragraph a above, sentence 2: The applicant does need to take a written test to add on the commercial rating because he/she does not hold an equal or higher lever certificate, but he/she does not need to add on a private in the relative category first!

Per AC 61-65E, Appendix 1, Page 16, Endorsement Example # 62:

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) in solo operations. I have determined that he/she is prepared to serve as PIC in that (make and model of aircraft).

Note in the example above, the reference to FAR 61.31(d)(3) [sic], you can not 'solo' a rated pilot even though the actual FAR makes reference to that (an oversight on the part of the FAA), therefore the sign-off states to serve as PIC in the aircraft for which the pilot (not student pilot since he/she already holds a rating) is not rated.

You can, and should still add restrictions in the sign-off noting wind limitations etc. for which you are still responsible.  As an instructor, you need to know about and understand these events.  I recently had an instructor (fixed wing), who was doing an add-on for a helicopter student of mine.  Even though we had many conversations about this, and he called his former instructor, the pilot involved never received the appropriate sign-offs.  No, not even a single sign-off was correct.

Per AC 61-65E, Appendix1, Page 16, Example 64:  The sign off example for a practical test; quite different from that you would give a student pilot.

I certify that (First name, MI, Last name), (pilot certificate), (certificate number), has received the required training for an additional (name the aircraft category/class rating). I have determined that he/she is prepared for the (name the practical test) for the addition of a (name the aircraft category/class rating)

Note that the two sign off examples above are the only sign offs required with the exception of the sign off necessary to take the commercial written test.  That is right, to add on a commercial helicopter rating to a private pilot airplane certificate, only three sign off are necessary.

Lets review some student pilot sign-offs, and talk about why they DO NOT apply in the category add-on situation.  For a student pilot who holds no previous ratings (note there is a difference between a 'student pilot', and a rated pilot who is seeking to add a category.  Yes, the pilot seeking to add a category is a student of the CFI, and School, but he/she is not a 'student pilot', that is why they have their own relative Subpart C in the FAR's).

For a 'student pilot', there are not less than eight (8) sign offs that must be in the pilot log book in addition to the two sign offs required on the back of the student pilot medical/license to qualify for a practical test.  Knowing that, an examiner can simply count the sign offs, and if there are less than eight, the student does not qualify for the check ride.  Many times, examiners do not review the actual sign offs.  I have worked with countless students who did not have the qualifying sign offs, yet they had received their ratings.  The sign offs are as follows: 

Pre-solo aeronautical knowledge §61.87(b)

Pre-solo flight training §61.87(c)

Solo take-offs and landings at another airport within 25 nm miles §61.93(b)(1)

Initial solo cross-country flight §61.87(c)(1)

Repeated solo-cross country flights to an airport within 50 nm from the point of departure §61.93(b)(2)

Private pilot aeronautical knowledge test §61.35(a)(1), §61.103(d), §61.105

Flight proficiency/practical test §61.103(f), §61.107(b)(3), §61.109(c)

§61.39(a)(6) See detail on this immediately below This is an interesting one since you will not find an example of it in AC 61-65E.

Pre-solo flight training at night §61.87(c) and (o) - There is no requirement for night solo, and I don't solo students at night for liability reasons, so therefore this is not one of the eight noted above.

Solo flight (each additional 90 day period) - Also not one of the eight, because most serious students will complete their rating in less than 90-days.

Number 7 Detail: I have had significant discussion about this with a few instructors who have inadequate knowledge of the part.  I also testified at an FAA trial involving this part of the FAR's, the trial was not involving the facts of the sign off, or any lack thereof, but rather to something entirely unrelated, but this FAR was the subject.  When looking at this FAR, note words 4 through 8, (if required by this part).  Here are the facts related to the sign offs required by §61.39(a)(6)

(6) Have an endorsement, if required by this part, in the applicant's logbook or training record that has been signed by an authorized instructor who certifies that the applicant—

(i) Has received and logged training time within 2 calendar months preceding the month of application in preparation for the practical test;

(ii) Is prepared for the required practical test; and

(iii) Has demonstrated satisfactory knowledge of the subject areas in which the applicant was deficient on the airman knowledge test

• §61.39(a)(6)(i)  I never had a student that required this sign off because I never had a student that took longer than two months to complete any given rating therefore all flight training falls under this by default thereby omitting the requirement for any such sign off.  Now of course if you work at, or are attending a school where you never get to fly, and it does indeed take longer than the time noted, then a sign off stating that training had been given within the specified time would be required.

• §61.39(a)(6)(ii)  This applies if (i) above applies, and can be made all in the same statement.

• §61.39(a)(6)(iii)  This applies to most students since I have never seen but one student get a perfect score on the written test.  If any student gets less than a perfect score, then the instructor must give a sign off according to this part.  Note that this requires that the instructor involved has reviewed the material missed on the knowledge test with the student.  This can take a good bit of research on the part of the instructor.

Why the numbered sign offs above don't apply to the addition of a category: Numbers 1-5 and 7 apply only to non-rated pilots, this is a category add on for the rated pilot undergoing training therefore there is no requirement for these sign offs and placing such sign off in the logbook demonstrates ignorance on the part of the instructor.  Numbers 6 and 8 - Required only if the pilot undergoing training for the addition of a category is seeking the next level certificate i.e. commercial Rotorcraft Helicopter to private Airplane Single Engine Land and scores less than a perfect score on the written test which would again require the §61.39(a)(6)(iii) sign off.  Numbers 8-9 apply only to non-rated pilots, this is a category add on for the rated pilot undergoing training therefore there is no requirement for these sign offs. 

I certify that (First name, MI, Last name) has received training within the preceding 2 calendar months in preparation for the practical test as required by § 61.39(a)(6)(i) and is prepared for the required practical test in a (category and class of aircraft).

I certify that (First name, MI, Last name) has demonstrated satisfactory knowledge of the subject areas in he/she was deficient on the airman (level) knowledge test.

An important note regarding sign offs it the fact that a CFI can and should include any specific restrictions and details which they feel are necessary to control the flight of any pilot they are teaching in an effort to keep the flight safe, and limit liability.  I hope this helps all of you out there with questions in this regard.  FLY SAFE!!  

After much research, I found the following flight schools with correct and accurate information on their web sites regarding the Commercial Helicopter Category Add-on rating to an Airplane Private Certificate.  Therefore, I believe these schools deserve your consideration as the flight school of choice (if they tell you otherwise, please notify me so that I can remove them from this list, conversely, I will also add a school who confirms the commercial add-on to a Private Airplane).  If a school is not on this list, or the list at the bottom of the page, I could not decipher their stand on the issue based on their advertised information.  Other good information can be found here:

Freedom Helicopters   Helicopter Flight Training Inc.   Helicopter Flight Services   Los Angeles Helicopters   Helicopters Northwest   Palm Beach Helicopters   Heliventures   Heli-Xpress   Heliflight  

Note the information downloaded from the flight school Web sites below:  One of two things is occurring here; they either don't know that you can add a commercial helicopter to the private airplane or they simply don't offer it.  If it is the later, then one must wonder why?

Upper Limit Aviation:  This is the most false that I found,  Their brochure ON PAGE 14, clearly states the false FAA requirement of a Private Rating in Helicopters to qualify for the commercial add-on - Nothing could be farther from the truth.  There is no place in the regulations which state this.

Bristow Academy:  Note in their FAA Price Schedule, the commercial add-on requirement notation. 

Northeast Helicopters:  Note in their add-on page, similar to Bristow.

Midwest Helicopter:  Midwest really doesn't make it clear on their page, and may offer the correct add-on options.

Celebrity Helicopters:  Note that on this page, they only advertise the Private Add-on option which indicates that they don't know that they have an option.

Universal Air Academy:  Note that on their page, the incorrect requirements stated for the commercial add-on.

Wings Air:  Note that their add-on, only shows private hours, but states that the commercial written test is not required which means that they expect that you already possess a commercial which is not required for the commercial add-on to a private airplane certificate, however a written test would indeed be required.

Air Shasta:  Per their web site, they only offer the private which indicates that they are unaware that the commercial can be added on to the Private Airplane Certificate.

Quantum Helicopters:  Per their web site, they also state incorrect FAA requirements.  Nowhere in the FAR's does it state that you must hold a commercial pilot certificate to qualify for the commercial helicopter add-on, to say you do is absolutely FALSE.

Epic Helicopters:  Per their web site, the commercial add-on can only be to existing commercial certificates.  Cleary false!

Ace Pilot Training:  This brochure from their web site indicates the same pre-existing commercial requirements, again false.

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Last modified: 12/31/2011