Task I.A
Pilot Qualifications
To determine the applicant exhibits satisfactory knowledge, risk management, and skills associated with airman and medical certificates including privileges, limitations, currency, and operating as pilot-in-command as a commercial pilot.
References: 14 CFR parts 61, 68, 91, 119.1(e); AC 68-1; FAA-H-8083-2, FAA-H-8083-3, FAA-H-8083-25
Quick Review
Conversational Q&A — quiz yourself before the oral.
This is the task where the commercial checkride stops looking like the private. You already know 61.113 and what a private pilot may not do. Now the question flips: you may be paid — so the examiner wants to know exactly which operations you may be paid for, and where the line into Part 119 sits.
- At least 18 years old
- Read, speak, write, and understand English
- Ground-training endorsement for the knowledge test, and pass it (61.125 knowledge areas)
- Training and a practical-test endorsement on the 61.127(b) areas of operation
- Meet the aeronautical experience requirements (61.129)
- Pass the practical test
- Hold at least a private pilot certificate issued under Part 61, or meet 61.73 (61.123)
250 hours of flight time as a pilot, including at least:
- 100 hours in powered aircraft, of which 50 must be in airplanes
- 100 hours PIC, including 50 in airplanes and 50 in cross-country flight — of which at least 10 must be in airplanes
- 20 hours of training on the 61.127(b)(1) areas of operation
- 10 hours of solo (or of performing PIC duties with an authorized instructor aboard) in a single-engine airplane (61.129(a))
- 10 hours of instrument training with a view-limiting device — attitude instrument flying, partial panel, unusual attitude recovery, intercepting and tracking navigation systems. 5 of the 10 must be in a single-engine airplane.
- 10 hours in a complex, turbine-powered, or technically advanced airplane (TAA) — or any combination of the three
- One 2-hour day cross-country in a single-engine airplane, straight-line distance more than 100 NM from departure
- One 2-hour night cross-country, same 100 NM straight-line criterion
- 3 hours of test prep in a single-engine airplane within the preceding 2 calendar months (61.129(a)(3))
- One cross-country of not less than 300 NM total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 NM from the original departure point (in Hawaii the longest segment need only be 150 NM)
- 5 hours in night VFR conditions with 10 takeoffs and 10 landings, each landing involving a flight in the traffic pattern, at an airport with an operating control tower (61.129(a)(4))
Either the solo option or the "PIC duties with an authorized instructor on board" option counts, and the time may also be credited toward the 100-hour PIC requirement.
An airplane with an electronically advanced avionics system that includes all of:
- An electronic PFD with at minimum airspeed, turn coordinator, attitude, heading, altimeter, and vertical speed
- An electronic MFD with at minimum a moving map using GPS navigation showing aircraft position
- A two-axis autopilot integrated with the navigation and heading guidance system
- Those display elements must be continuously visible (61.129(j))
Miss any one element and it isn't a TAA for the 10-hour requirement.
You may act as PIC of an aircraft carrying persons or property for compensation or hire, and you may act as PIC for compensation or hire — in each case provided you are qualified under Part 61 and under the applicable parts of the chapter that apply to that operation (61.133(a)(1)).
That trailing clause is the whole exam. The certificate makes you legal to be paid; it does not make the operation legal. Most revenue passenger-carrying operations also need an operator certificated under Part 119 (121/135).
"The carriage of passengers for hire in airplanes on cross-country flights in excess of 50 nautical miles or at night is prohibited."
The limitation is removed when you satisfactorily complete the 61.65 requirements for an instrument rating in the same category and class shown on the certificate (61.133(b)(1)).
No. Part 119 applies to anyone operating civil aircraft as an air carrier or commercial operator in air commerce, and to noncommon and private carriage for compensation or hire within the seat and payload thresholds in 119.1(a). Carrying paying passengers point to point is an operation that requires a certificated operator under Part 119 with Part 121 or 135 operations specifications.
Your commercial certificate qualifies you to be one of that operator's pilots. On its own it authorizes only the operations Part 119 doesn't reach — the 119.1(e) list.
Part 119 does not apply to (119.1(e)):
- Student instruction
- Nonstop Commercial Air Tours — standard airworthiness certificate, 30 seats or fewer, 7,500 lb maximum payload or less, begin and end at the same airport, within a 25-statute-mile radius, under a Letter of Authorization issued per 91.147
- Ferry or training flights
- Aerial work — crop dusting, seeding, spraying, bird chasing; banner towing; aerial photography or survey; firefighting; powered-lift/rotorcraft construction or repair work; powerline or pipeline patrol
- Sightseeing in hot air balloons or gliders
- Nonstop parachute-operation flights within a 25-statute-mile radius of the takeoff airport
Read the preamble carefully — the size test is narrower than it looks. 119.1(e) excepts these operations except for operations when common carriage is not involved conducted with an airplane or powered-lift having 20 or more passenger seats (excluding required crewmember seats) or a payload capacity of 6,000 lb or more. So the seat/payload threshold bites only on non-common-carriage operations; when the operation is common carriage, the (e) exceptions apply without any size test (119.1(e)).
- Flights begin and end at the same airport and stay within a 25-statute-mile radius
- The operator must apply for and receive a Letter of Authorization from the responsible Flight Standards office
- The operator must register and implement drug and alcohol testing programs under Part 120 (91.147)
That last item catches applicants off guard: the 119.1(e)(2) exception is only good while the 91.147 LOA and Part 120 testing program are in place.
A second-class medical is required to exercise the privileges of a commercial pilot certificate in an aircraft other than a balloon (61.23(a)(2)).
Duration: second-class privileges expire at the end of the 12th month after the month of examination — at any age. After that the same certificate keeps serving third-class privileges: through the 60th month if you were under 40 at the exam, the 24th month if you were 40 or older — so a lapsed second-class doesn't ground you, it just demotes you to private privileges until you re-examine (61.23(d)).
BasicMed: does not substitute here — Part 68 only stands in for a medical certificate where 61.113 private-pilot privileges are exercised, and it carries the "no compensation or hire" character of the private certificate with it, plus the 7 occupants or fewer, 12,500 lb or less, 18,000 ft MSL, and 250 kt limits (61.113(i), Part 68 — the occupant and weight limits expanded from 6/6,000 lb in November 2024).
Carry: pilot certificate, the current second-class medical, and government photo ID (61.3, 61.23) — plus the logbook or training records whenever the operation depends on a 61.31 endorsement or on recent experience you would have to prove (61.51).
Currency is the regulatory floor: a flight review every 24 calendar months (61.56) and three takeoffs and landings in 90 days to carry passengers, full stop at night (61.57). Proficiency is whether you can fly the airplane to commercial ACS tolerances with a paying passenger in back and schedule pressure on you.
The commercial delta is that the consequences of the gap change. A private pilot who is current-but-rusty risks himself and his friends; a commercial pilot does it on someone else's money, on someone else's schedule, and the external pressure to go is exactly what erodes the margin.
Deep Dive
The three questions that decide any "can I get paid for this?" scenario
Examiners build this task as a scenario chain: a neighbor asks you to fly his cargo to Reno; a photographer wants aerials; a charity wants to sell rides. Work all of them through the same three gates, in order.
- Am I qualified? Commercial certificate, category/class rating, second-class medical, 61.31 endorsements for the airplane, flight review and passenger currency (61.133(a)(1), 61.31, 61.56, 61.57).
- Is the operation excepted from Part 119? Run the 119.1(e) list — instruction, ferry, training, aerial work, air tours under 91.147, parachute ops. If it lands on that list you may fly it as a commercial pilot without an air-carrier certificate.
- If it isn't excepted, who holds the certificate? Then someone must operate under Part 119 with 121 or 135 opspecs, and I fly as their pilot under their operations specifications — not on my own.
The exception covers the work, not the transportation to it. 119.1(e)(4)(v) says so explicitly for construction and repair operations: Part 119 does apply to transportation to and from the site of operations. The pattern generalizes — the moment the flight's purpose becomes moving people or freight from A to B for hire, you are back inside Part 119 no matter what the job at the other end is.
Also note the air-tour exception is nonstop and begins and ends at the same airport. A "tour" that drops passengers at a different field is transportation.
Commercial pilot versus commercial operator
A commercial pilot is an airman certificate under Part 61 — it says the FAA has tested your skill and knowledge to a higher standard and will let you be compensated.
A commercial operator is an entity under Part 119 — it holds an operating certificate and operations specifications and carries the responsibility for the operation: maintenance program, training program, drug and alcohol testing, duty limits.
119.1(a) sorts operations into common carriage, noncommon carriage, and private carriage for compensation or hire, each with its own thresholds. Nothing about holding a commercial pilot certificate makes you a commercial operator.
Not as a freelancer. This is carriage of persons for compensation or hire, point to point, and it is not on the 119.1(e) list. My commercial certificate makes me eligible to be paid; it does not authorize the operation.
Real answers that do work: fly it as his employee with the aircraft operated under Part 91 in a structure his counsel has vetted, or fly it for an operator certificated under Part 135. The wrong answer — and the one the examiner is fishing for — is "sure, I have a commercial certificate."
Charitable flights — 91.146 at commercial level
You already met 91.146 as a private pilot exception. As a commercial pilot the useful detail is the operational box the section draws, because it is nearly identical to the 91.147 air-tour box.
Not subject to Part 119 certification or Part 120 drug and alcohol testing, provided (91.146(b)):
- Nonstop, begins and ends at the same airport, within a 25-statute-mile radius
- Flown from a public airport adequate for the aircraft, or an FAA-approved location
- Aircraft has a maximum of 30 seats excluding crew seats and 7,500 lb maximum payload
- Not aerobatic and not formation
- Standard airworthiness certificate, airworthy, operated per subpart E
- Day VFR only
- Reimbursement limited to the pro-rata cost of owning, operating, and maintaining the aircraft — fuel, oil, airport expenditures, rental fees
- The beneficiary is not in the business of transportation by air
- A private pilot PIC needs at least 500 hours
Limits: four charitable or non-profit events per year, one community event per year, none longer than three consecutive days; pilots and sponsors are capped at 4 events per calendar year; the sponsor notifies the responsible Flight Standards office at least 7 days before (91.146(c), (d), (e)).
The 61.31 endorsements — sharpened
At the commercial level these stop being trivia. The 10 hours of 61.129(a)(3)(ii) training will usually be flown in a complex airplane, and the examiner will want the definitions exactly.
| Endorsement | Trigger | Reg |
|---|---|---|
| Complex | Retractable gear, flaps, and a controllable-pitch propeller (including FADEC-equipped); for a seaplane, flaps and a controllable-pitch propeller | 61.1, 61.31(e) |
| High performance | Engine of more than 200 horsepower | 61.31(f) |
| Pressurized / high altitude | Service ceiling or maximum operating altitude, whichever is lower, above 25,000 ft MSL | 61.31(g) |
| Tailwheel | Any tailwheel airplane | 61.31(i) |
It is the only one of the four with a mandated ground-training syllabus (61.31(g)).
Logged ground training must cover (61.31(g)(1)):
- High-altitude aerodynamics and meteorology
- Respiration, and the effects, symptoms, and causes of hypoxia and other high-altitude sickness
- Duration of consciousness without supplemental oxygen
- Effects of prolonged oxygen use
- Causes and effects of gas expansion and gas bubble formation, and how to prevent them
- The physical phenomena of decompression
Flight training must include (61.31(g)(2)):
- Normal cruise above 25,000 ft MSL
- Simulated rapid decompression procedures (without actually depressurizing)
- Emergency descent procedures, with a separate proficiency endorsement
Complex, high performance, and tailwheel are all one-time endorsements with no expiration; none of them requires a checkride.
Grandfather clauses examiners like to probe: complex and high performance are not required if you logged PIC time in one before August 4, 1997, or completed an approved training program plus a 135.293 competency check documented in your logbook or training record (61.31(e)(2), (f)(2)). Pressurized is not required if you served as PIC before April 15, 1991, completed a proficiency check for a certificate or rating before that date, completed a U.S. military PIC check, or completed a Part 121/125/135 PIC proficiency check (61.31(g)(3)). Tailwheel is not required if you logged PIC time in a tailwheel airplane before April 15, 1991 (61.31(i)(2)).
Shortening the 250 hours
Yes, three separate allowances:
- Outside an approved course: a maximum of 50 hours toward the total may be obtained from an authorized instructor in a full flight simulator or FTD representing the class of airplane appropriate to the rating sought (61.129(i)(1)(i)).
- Part 142 training center: a maximum of 100 hours in an FFS/FTD may be credited (61.129(i)(2)(i)).
- Part 142 approved commercial course: an applicant who has completed 190 hours of aeronautical experience is considered to have met the total-time requirement, provided the approved course was appropriate to the certificate and rating sought (61.129(i)(3)).
The 190-hour path is why Part 141/142 academy graduates finish well short of 250 hours.
Risk: unfamiliar aircraft and unfamiliar avionics (CA.I.A.R2)
- Treat every new type as requiring more than the legal minimum: the 61.31 endorsement is a floor, not a checkout.
- Fly the avionics before the airplane. A TAA panel (61.129(j)) puts a two-axis autopilot and a moving map between you and the airplane; not knowing what mode it is in is a loss-of-control risk, not a convenience problem.
- Pre-brief the failure modes you have never seen: gear extension backup, prop governor loss, autopilot disconnect, PFD reversion to standby.
- Set a hard personal rule on when you decline. External pressure — the customer is waiting, the airplane is on the ramp — is the mechanism that turns unfamiliarity into an accident.
This risk element is in the commercial ACS for a reason — commercial flying means being handed airplanes you did not train in.
Official ACS elementsreference
Knowledge5 elements
The applicant demonstrates understanding of:
CA.I.A.K1Certification requirements, recent flight experience, and recordkeeping.CA.I.A.K2Privileges and limitations.CA.I.A.K3Medical certificates: class, expiration, privileges, temporary disqualifications.CA.I.A.K4Documents required to exercise commercial pilot privileges.CA.I.A.K5Part 68 BasicMed privileges and limitations.
Risk Management2 elements
The applicant is able to identify, assess, and mitigate risk associated with:
CA.I.A.R1Proficiency versus currency.CA.I.A.R2Flying unfamiliar aircraft or operating with unfamiliar flight display systems and avionics.
Skills1 element
The applicant exhibits the skill to:
CA.I.A.S1Apply requirements to act as pilot-in-command (PIC) under Visual Flight Rules (VFR) in a scenario given by the evaluator.