Commercial XC: Solo or Dual?

4 Answers

1. 
   

   
   

   Russ Roslewski on Apr 30, 2017

   Note the sub paragraph that they fall under:

   “(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least -”

   They are “training”, therefore they need to be with an instructor.

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2. 
   

   
   

   HardLandings on May 01, 2017

   This was the same conclusion I came to back when I was doing my Commercial work, I have since heard more arguments that the night x/c can be done solo, but I don’t agree with it. The argument is usually that ‘training’ is not necessarily the same as ‘dual instruction’, and I think that proponents point to simulated instrument time for the instrument rating with a safety pilot counts as training…

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3. 
   

   
   

   Mark Kolber on May 05, 2017

   They can point to whatever they want and make up whatever they want. But there is a correct answer and it is the one Russ gave. The FAR even defines it three times in 61.1:

   Training time means training received –
   (i) In flight from an authorized instructor;
   (ii) On the ground from an authorized instructor; or
   (iii) In a flight simulator or flight training device from an authorized instructor.

   Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft.

   Ground training means that training, other than flight training, received from an authorized instructor.

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4. 
   

   
   

   Russ Roslewski on May 05, 2017

   HardLandings,
   I’m not sure who is making those arguments, but these requirements are some of the most clearly spelled out paragraphs in all of Part 61. There really shouldn’t be any question about it, unless of course people are just looking to try to justify what they think are loopholes to save money.

   To comment on the simulated instrument issue, the reason that simulated instrument time is allowed with a safety pilot is specifically because the 40 hours of instrument time you need for the rating is NOT training – it is identified in 61.65 as “Forty hours of actual or simulated instrument time”. Note – “time”, not “training”. 15 of that needs to be training from an instructor, as mentioned later in that same sentence.

   I don’t see any connection between this and the Commercial dual night XC. That is clearly a training requirement, which due to the reference Mark provides, has to be with an instructor.

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