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FAR 61.109(c) says:

For a helicopter rating. Except as provided in paragraph (k) of this section, a person who applies for a private pilot certificate with rotorcraft category and helicopter class rating must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation listed in §61.107(b)(3) of this part, and the training must include at least...

The question is, does the 40 hours have to be in a helicopter, or can hours in ASEL meet this requirement? All the training centers seem to be saying it has to be 40 hours in helicopter. Can you theoretically fulfill the other requirements inside the 20 hours training and 10 hours solo in heli and be compliant with 61.109(c) with only 30 hours in heli?

Actually, it's not clear to me if the 20 hours of dual has to be in helicopter.

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Considering the difference between legal and smart, you could nonetheless potentially satisfy the training requirements with just a few hours in a helicopter. FAR 61.109 specifically notes that certain requirements must be satisfied in a helicopter:

  • 61.109(c)(1): "3 hours of cross-country flight training in a helicopter;"
  • 61.109(c)(2): "[...] 3 hours of night flight training in a helicopter that includes" a 50nm flight and 10 takeoffs and landings
  • 61.109(c)(3): "3 hours of flight training with an authorized instructor in a helicopter in preparation for the practical test..."
  • 61.109(c)(4): "10 hours of solo flight time in a helicopter..."

Theoretically, the flight training could be all combined, resulting in 3 dual and 10 solo hours in a helicopter, the rest of the requirements being fulfilled in a different category or class of aircraft.

The FAA issued an interpretation (O'Mara, 2012) about these rules in 2012. The discussion was about weight-shift-control aircraft (61.109(j)), but the reasoning is applicable to other sections of 61.109:

In your letter you indicate that an examiner you spoke with stated that all of the aeronautical experience requirements specified in § 61.109(j), to include the 40 hours of flight time, 20 hours of flight training, and 10 hours of solo flight training must be completed in a weight-shift-control aircraft. That statement was incorrect.

[...]

...[T]he requirement for an applicant for a weight-shift-control aircraft to have 40 hours of flight time may be met by obtaining flight time in any category and class of aircraft.

Paragraphs (j)(1) through (j)(5) of § 61.109 specify the flight training that must be received by an applicant to receive a weight-shift-control aircraft rating. Flight training is defined in § 61.1 as "training, other than ground training, received from an authorized instructor in flight in an aircraft." Similar to the definition of flight time, it also does not include a limitation that the training be obtained in any particular category and class of aircraft.

That said, this is somewhat academic: in order to get a solo signoff from a CFI, a student would at least require nontrivial training time in a helicopter. I'll also cite another interpretation (Zomnir, 2010) I came across in my research, which has perhaps the most obvious statement in an FAA legal interpretation:

First, you ask whether your student is required to be proficient to the practical test standards to pass a practical exam. The answer is yes.

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There is a very common misconception about the required hours to complete a rotorcraft add-on. Call any helicopter school (or look it up online) and they will tell you it is 30 hours if you have a PPL.

Here is the breakout:

14 CFR 61.109 in part states:

(c) For a helicopter rating. Except as provided in paragraph (k) of this section, a person who applies for a private pilot certificate with rotorcraft category and helicopter class rating must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation listed in §61.107(b)(3) of this part, and the training must include at least—

The operative section is this one:

...includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in the areas of operation listed in §61.107(b)(3) of this part...

If you read 14 CFR 61.107(b)(3), you will see that you cannot complete the 20 hours with an authorized instructor or the 10 hours solo in anything but a rotorcraft:

(3) For a rotorcraft category rating with a helicopter class rating: (i) Preflight preparation;
(ii) Preflight procedures;
(iii) Airport and heliport operations;
(iv) Hovering maneuvers;
(v) Takeoffs, landings, and go-arounds;
(vi) Performance maneuvers;
(vii) Navigation;
(viii) Emergency operations;
(ix) Night operations, except as provided in § 61.110 of this part; and
(x) Postflight procedures.

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  • $\begingroup$ 14 CFR 61.107(b)(3) "in the areas of operation" logic applied to this requirement could be read to apply just to the 10 solo hours, or include the 20 dual training hours, or to all 40 hours of flight time. It seems like you would either have to support either the 10 or 40 hour answers; 10+20 seems like an inconsistent halfway measure. $\endgroup$ – Pilothead Jul 17 '18 at 20:09
  • $\begingroup$ @pilothead I am not sure why you think it is inconsistent, IMHO 61.109 is very clear. Additionally, I did a rotor addon many years ago and it was 30 hours when I did it. Just a cursory search on Goole here, here, here and here all verify the 30 hour requirement for the addon rating. $\endgroup$ – Richard Jul 18 '18 at 20:54
  • $\begingroup$ 30 hours requires the 69.109(c) wording "includes" to be read differently than "and" as neither has "areas of operation" as a direct modifier. If this were clear there would be no need for this question and of course helicopter flight schools would take the position that 20 hours of dual has to be in a helicopter. $\endgroup$ – Pilothead Jul 18 '18 at 22:21
  • $\begingroup$ I guess I am missing your point....are you are saying that all of the operations in 61.107(b)(3) can be done solo since they used the word "and" and all of the helicopter flight schools have created a conspiracy to force everyone to do 20 hours dual in a helicopter? :-) $\endgroup$ – Richard Jul 20 '18 at 1:47
  • $\begingroup$ Nathan's answer clarifies that the FAA in O'Mara considers the 40hrs flight time and 20hrs flight training acceptable in any aircraft, and the 10hrs specific to helicopters, subject to subparts 1-4. The reference is to 61.109j weight shift rating, but the wording is identical to the 61.109c helicopter rating requirement. $\endgroup$ – Pilothead Aug 3 '18 at 19:33
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Yes it needs to be in a helicopter.

§61.107 Flight proficiency. (a) General. A person who applies for a private pilot certificate must receive and log ground and flight training from an authorized instructor on the areas of operation of this section that apply to the aircraft category and class rating sought.

You should note that the wording in §61.109(c) "must log at least 40 hours of flight time that includes at least 20 hours of flight training from an authorized instructor and 10 hours of solo flight training in" is identical to the wording in §61.109(a) for airplane category.

The interpretation is you need 40 hours total with a minimum 20 hrs dual and a minimum 10 hrs solo. The other 10 hrs can be either dual or solo.

You should note the requirements of §61.63 (b) for additional ratings. Basically, the only thing you're exempted from the private pilot knowledge test.

§61.63 Additional aircraft ratings (other than for ratings at the airline transport pilot certification level). (a) General. For an additional aircraft rating on a pilot certificate, other than for an airline transport pilot certificate, a person must meet the requirements of this section appropriate to the additional aircraft rating sought.

(b) Additional aircraft category rating. A person who applies to add a category rating to a pilot certificate:

(1) Must complete the training and have the applicable aeronautical experience.

(2) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.

(3) Must pass the practical test.

(4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.

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    $\begingroup$ it says "40 hours of flight time". It does not stipulate that it must be in category from what I can see. It only says that some of that time must include the specific training described later. $\endgroup$ – Greg Taylor Jan 18 '17 at 20:02

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