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Commercial Experience (61.129) Requirements – with or without instructor?

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Commercial Pilot

Hello. I have two questions about the Commercial Experience required to obtain a SEL Commercial license. 

My questions regard part 61.129(a):

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

     (1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.

     (2) 100 hours of pilot-in-command flight time, which includes at least—

          (i) 50 hours in airplanes; and

          (ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.

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

          (i) 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;

          (ii) 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;

          (iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

          (iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

          (v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

     (4) 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—

          (i) 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. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

          (ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

 

QUESTION 1
My first question regards 61.129 (3) (iii) and (iv). Am I correct that these must be flown with a CFI? I have heard conflicting info.

QUESTION 2
My second question regards 61.129 (4). There is a very key "or" in (4). Am I correct that if one has "ten hours of solo flight time in a single engine airplane" that anything following that in (4) is not required? It reads to me as if to state "you can have this OR that". Again, I've heard conflicting viewpoints on this. For example, I've been told that even if you have "ten hours of solo flight time" you still need to have accomplished the sub parts (4) (i) and (ii). But grammatically it doesn't make sense (lol! as if!), it would read like this if the item after "or" did not apply yet the sub points do:

(4) Ten hours of solo flight time in a single engine airplane, on the areas of operation listed under §61.127(b)(1) that include—

          (i) 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. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

          (ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

 

 

4 Answers



  1. Mark Kolber on Aug 04, 2019

    Question 1. Yes. As you quoted, 91.129(a)(3) starts with, “20 hours of **training** on the areas of operation listed in §61.127(b)(1) of this part that includes at least—”

    “Training” = flight training = with a CFI.

    Question 2. Yes you must accomplish (4)(i) and (ii). The “or” gives the option of doing them solo or via “solo substitute” (“performing the duties of pilot in command in a single engine airplane with an authorized instructor on board”).

    Solo substitute was originally created by the FAA for the commercial multi because insurance companies would not cover solos by commercial multi students who were not already multi-rated. It was latter added to the commercial single as well.

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  2. Gary S. on Aug 06, 2019

    Training may also include solo work. It’s all training. That said, if the training involves a view-limiting device, it’s got to be dual training. Even then, you may not need a cfi as with a QUALIFIED safety pilot. Of course some training with a cfi must be noted in your log. You need to get with your friendly neighborhood cfi for the details.

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  3. Mark Kolber on Aug 06, 2019

    FAR 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.

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  4. Mark Kolber on Aug 07, 2019

    BTW, Gary makes a good point about solo. Although not consistently, the FAA does talk about “solo flight training.” Example is the 61.109 requirements for the private certificate. I guess we can think of that one as special because solo flights by a student pilot require CFI authorization, but I think it’s just a simple case of modifying the general definition by adding a word to the phrase.

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