Building commercial time in the Luscombe

The Luscombe is a genuinely good commercial time-builder, and it is honest to say so, because most of §61.129 is hours in an airplane and this is an airplane you will want to fly.

There is exactly one requirement it can never serve, and one it probably cannot. Both are named below. Everything else it does.

(a)(3)(ii), the 10 hours complex, turbine, or TAA. Verbatim:

10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

A TAA under 61.129(j) needs an electronic PFD, an electronic MFD with a moving map, and a two-axis autopilot integrated with the navigation and heading guidance system, all continuously visible. A 1948 Luscombe is none of the three categories. This requirement is done elsewhere, in another airplane, and no reading of the regulation changes that.

(a)(3)(i), the instrument training, probably not, and for an equipment reason rather than a regulatory one. Verbatim:

Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

Note what this does not say. It does not require all ten hours in a single-engine airplane, only five. And a Luscombe is a single-engine airplane.

What stops it is the equipment. Attitude instrument flying, partial panel work, and intercepting and tracking navigational systems all need instruments and navigation receivers. Whether N1302B has them is an open item below, not something this document assumes either way.

KSNS to KCNO is 252.7nm great-circle, which clears the 250nm threshold in (a)(4)(i) by about 2.7nm, roughly one percent.

One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point.

Three things to get right:

The rule measures from the original departure point. The 252.7nm figure holds only if the flight originates at Salinas. Depart from anywhere else and the number changes.

Three landing points, not two. Salinas out and back is 505.4nm of distance and only two points. Santa Maria is the recommended intermediate on the outbound leg, at roughly 120nm to Santa Maria and 150nm on to Chino, and the student plans the return. Routing via Santa Maria makes the outbound about 270nm against the 252.7nm direct. Other stops are fine, and a diversion for weather, fuel, or anything else is always the pilot's call. These are recommendations, not approved destinations.

Re-run the distance before it goes in a logbook. A one percent margin is thin enough that the person most likely to measure it is a DPE reviewing a commercial applicant's logbook. Compute it in ForeFlight or Garmin Pilot, and record the figure in the student's file alongside the flight.

The 10 hours in (a)(4), including the long cross-country and the night requirement, accept either. Verbatim:

Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section), on the areas of operation listed under § 61.127(b)(1) that include—

Both (a)(4)(i) and (a)(4)(ii) sit under that sentence, so both accept the instructor-aboard alternative. This matters for a pilot who wants the long cross-country flown with someone in the right seat rather than alone.

(a)(4)(ii) needs the ten takeoffs and landings "at an airport with an operating control tower."

KSNS tower operates 0600 to 1900 October through March, and 0500 to 1900 April through September. It closes at 1900 local year-round.

Civil twilight at Salinas ends around 1723 in late December and not until about 2059 at the summer solstice. So towered night pattern work at Salinas is available roughly mid-October through the first week of March, and not at all from mid-March through early October.

Outside that window the nearest options are KMRY, whose tower runs to 2100 and clears the latest twilight of the year by about an hour, and KSJC, which runs to midnight but is Class C with airline traffic. KWVI is non-towered and does not count.

Night flying in N1302B requires the Night Checkout, which is separate from the endorsement.

Named because a commercial applicant will eventually hit them, and a guide that pretends they are settled is worse than one that flags them.

1. Simulator credit against the instrument hours. 61.129(i)(1)(i) permits crediting up to 50 hours "toward the total aeronautical experience requirements." Whether that reaches the itemized 10 hours in (a)(3)(i) or only the 250-hour total is not answered by the text. What is certain is that at least 5 hours cannot be done in a simulator, because they must be in a single engine airplane.
2. The test-preparation window. (a)(3)(v) says "within the preceding 2 calendar months from the month of the test." Whether the month of the test itself counts is not stated. The common industry reading says it does. The regulation does not say so.
3. Whether duties-of-PIC time is loggable PIC time. The (a)(4) parenthetical credits it toward the (a)(2) total by force of that sentence. Whether it is independently loggable as PIC under 61.51 is a separate question this section does not answer.

For any of the three, get an FAA legal interpretation or a written FSDO position. Do not rely on this page.

• N1302B instrument and navigation equipment. Confirm what is installed before this document says anything definite about (a)(3)(i). The aircraft is known to have an electrical system, lighting appropriate for night, a transponder, and ADS-B Out. Whether it carries an attitude indicator, a directional gyro, and a navigation receiver is unconfirmed.
• The definition of complex airplane lives at 61.1 and is not quoted here. Not needed for the conclusion, since the Luscombe is plainly outside all three categories in (a)(3)(ii), but cite it if this document ever needs to argue the point.