Commercial Helicopter Add-on to Airplane Private Pilot

Airplane Private to Commercial Helicopter? Yes, you can!!

Note that AC 61.65E CHG 1 was issued on 1/6/2014. The most significant changes are with regard to ATP.

I continue to receive frequent emails regarding this article and instructors that don't know the regulations. If your instructor is telling you something different than what you read here, you are wasting your money not only with the wrong instructor, but with the wrong school as well. But, as they say, it is your money! I suggest you find a different instructor!

This is one of the most negligent areas of the FAA. Many of their own inspectors don't know that you can do this simple thing, and as a result, they incorrectly advise their Designated Pilot Examiners (DPEs). What makes matters worse, is that the majority of DPEs and Flight Instructors are completely ignorant of the proper procedures. What happens in the end is that pilots waste thousands of dollars (which they should sue to recover) as a result of this misguidance. This is partially due to the belief of some that the FARs have so called, "Gray Areas'. They do not; they mean exactly what they say, nothing more and nothing less. You nor anyone else can "read into" the FARs, not even the FAA.

I continue to receive countless emails inquiring about this issue. There are many incompetent instructors, DPEs and even FAA inspectors who think that you cannot add a commercial helicopter rating to a private airplane certificate or vice versa! 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 incompetent DPE's, schools, and instructors mislead you.

Another issue of important note is that flight instructors who give rated pilots, student solo sign-offs, are being negligent in their procedures and they should know better than that. Once a pilot receives a rating regardless of the aircraft category, they are never a "student pilot" again. From that time forward, they are a pilot undergoing instruction, or a pilot receiving training, or any other way you want to correctly state it. The point is, they are not a student; therefore student sign-offs of any kind are inappropriate. A "student" as far as the FARs are concerned is a person who does not hold any ratings.

If someone gives you information contrary to what you read here, contact me at and I will help you get it corrected at your local FSDO.

PIC - Here is where many people get confused. Any and all solo time even when you are truly a student, is also logged as PIC. If the aircraft is flying, there is someone acting as PIC, and in the case of a student who is solo, he/she is PIC during that time. For the purpose of furtherance of certificates in a different category, such as in the case of progression to the commercial, all time after the 61.31 sign-off including 10-hrs with the instructor onboard is PIC time, but only 10-hrs with the instructor, which is limited by 61.51 (definition of solo) and 61.129 (limits time with an instructor to 10-hrs).

61.51 (d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.

61.129(c)(4) 10-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—

Note that the 10-hour requirement for solo time under 61.129 is a minimum and can be exceeded; however the 10-hours with the instructor on board can not be exceeded since it is a limitation.

It usually takes 20 or so hours to become safe enough to fly a helicopter for the first time by yourself anyway, and in a Robinson helicopter you cannot serve as PIC with less than 20-hrs. This 20-hrs is usually plenty of time to get most pilots proficient enough to act as PIC in solo operations and to cover all emergency training to a safe level. After the 61.31 sign-off, the pilot undergoing furtherance training must not waste valuable time joy riding cross-country. This time needs to be spent doing what seems boring, but what makes you a good pilot; hover, patterns, departures and approaches, those things that improve accuracy and profile. The 10-hrs with the instructor onboard needs to be the last 10-hrs before the checkride honing your skills in emergency procedures and final preparations for the checkride.

Applying eligibility for the addition of Commercial Helicopter to Private ASEL:

As previously stated, the applicant has a Private ASEL rating and is applying for a Commercial Helicopter. The first step is complying with FAR 61.123, which he/she does. Where we run into trouble is the apparent misunderstanding of some in that the FARs are Federal Law which means that we must comply to the letter; we can neither add to it, delete from it, nor interpret it. However people keep construing 61.123(d)(h) which simply states, "hold a private pilot certificate..." It does not state in category therefore we cannot insert that information; it wouldn’t matter if it were in a balloon.

Since the applicant meets this requirement, but does not hold the category rating, the lawmakers saw this potential and created FAR 61.63 which addresses category add-on. Please pay particular attention to 61.63 (b)(4), which speaks on this very subject. There is no disqualifying factor in this part or any other for this aforementioned applicant. Therefore he/she qualifies.

Furthering the above mentioned lack of knowledge, is the practice of issuing inappropriate sign-offs for this applicant and similar pilot applicants and the fact that neither DPEs nor the FAA is catching it. You cannot solo a pilot who already holds a certificate therefore our lawmakers saw the need for 61.31 which addresses this issue as well as AC 61.65E CHG 1, Appendix 1, Page 16, Example 66, which demonstrates an appropriate sign-off for an individual whom will be acting as PIC (since he/she is a rated pilot and NOT a student) in solo operations in an aircraft for which he/she does not hold the appropriate rating. An FAA inspector advising an instructor or DPE that this pilot applicant cannot log PIC unless they hold a private in category is incorrect. Once this rated pilot qualifies for the 61.31 sign-off, he/she is acting PIC, including 10-hrs with the instructor onboard the aircraft.

The above mentioned Federal Regulations provide a clear path for a pilot with this need. Certificates that have been issued without following these proper procedures could ultimately be called into question, which has occurred in the past.

The number of instructors and Examiners who don't understand this process amazes me since this is suppose to be covered during the application, training, and oral for a CFI certificate; it was during mine. 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 this process. 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.

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 negligent or 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.

The only sign-off for a pilot adding this category is demonstrated in AC 61.65E CHG 1, Appendix 1, Page 16, Endorsement Example # 66 as follows:

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)(2).

I certify that (First name, MI, Last name) has received the training as required by section 61.31(d)(2) 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). /s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05

An important note regarding sign offs is 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. 

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.

These schools are trying to do it right, they deserve your consideration:

702 Helicopers in Las Vegas. These guys came with excellent remarks from students. If you're in their area, give them a call.

Epic HelicoptersFreedom HelicoptersHelicopter Flight ServicesLos Angeles HelicoptersHelicopters NorthwestPalm Beach HelicoptersHeliventuresHeliflight

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?

These schools have erroneous or incorrect information on their sites; this will waste your money:

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. There is other erroneous information on their web site, so read it carefully.

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.

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