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Aeronautical Experience Commercial Pilots License ASEL – Solo Requirements

Asked by: 8229 views Commercial Pilot, FAA Regulations, General Aviation, Student Pilot

Can anyone provide some clarification on the solo requirements for obtaining a commercial pilots license (ASEL) found in CFR 61.129? The quoted text I'm interested in reads:

"(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."


It seems to me that one does not need ANY solo time (niether a 300 nm cross country flight nor night VFR work in the pattern at a controlled field) to meet the experience requirements for a commercial pilot license ASEL.


Does this sound right? Or am I reading this all wrong? 


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7 Answers

  1. John D. Collins on Jan 31, 2012

    You do need the long cross country,the night pattern work, and the 10 hours of solo.  If you are with an instructor, this time may count towards the solo requirement, although you would not log it as solo because it is dual instruction. Assuming you were either qualified to act as PIC or were the sole manipulator of the controls, you would also log it as PIC.  If this doesn’t address your question, please clarify what you are asking.

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  2. Ash on Jan 31, 2012

    Thanks for the quick response. I think you already answered this, but just to clarify my question is do I need to do a solo long cross country and solo night pattern work or can those two tasks be completed with an authorized instructor on board (as long as I am the sole manipulator of the controls)?
    If those two tasks can be completed with an instructor on board, I assume the 10 hours of solo time I need can be accomplished by perfoming any other tasks that fall under the umbrella of “the areas of operation listed under CFR 61.127(b)(1)”?
    Does all this sound about right to you? Anyone else have any comments? I fear I might be over-analyzing this whole thing!

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  3. Wes Beard on Jan 31, 2012

    This is just my opinion so that it as such.
    The first time I read in the FARs “or acting as pilot in command in a single engine airplane with an authorized instructor on board” came last year when the FAA changed the instrument aeronautical experience so the applicant can complete a private pilot instrument course at one shot instead of two separate courses.  The FAA realized that the student pilot needed 50hrs of cross country time as PIC which they could not fulfill under their student pilot certificate.  
    The key to me is this: if you could accomplish the activities you are looking at (ie 300NM XC and night VFR) solo then you should not try to accomplish those while acting as the pilot in command in a single engine airplane with an authorized instructor on board.  If you cannot accomplish this experience solo, then by all means use an instructor.  The only situation that this would come into play is if you are adding an airplane category with a single engine land class onto your commercial certificate.  
    If you already have an ASEL rating, fly solo.  If you do not have an ASEL rating but another airplane category rating (AMEL, ASES, AMES) at the commercial level than you simply need to pass the practical test.  
    I hope this helps and like I said, it is only my opinion. 

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  4. Bill Trussell on Feb 01, 2012

    The original intent of the FAA in establishing these types of experience levels was to accommodate those who do all of their learning in airplanes and those who do not.  To make it fair while still meeting their objectives of recognizing those pilots who are proficient enough to fly from A to B over longer distances, the FAA said you need 10 hours of solo in airplanes.   This can be from your private pilot training.
    The longer cross country is to ensure you are comfortable going longer distances, including all the planning that entails. Such a trip can be accomplished at any point in your career, including such trips as a long IFR dual cross country, flown under IFR  and on an IFR flight plan so long as you can log the time as PIC.  These provisions are good for those who are maybe transitioning from a rotor wing aircraft to an airplane as one example.
    Bottom line is you are correct in one respect that you really do not need any solo time, under certain conditions.  Most fixed wing, airplane pilots will accomplish this requirement early on.
    The longer cross country is the most fun part of this training IMHO.

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  5. John D. Collins on Feb 01, 2012



    I am not so sure that the solo time logged towards your private pilot training can be used to meet the solo requirements in 61.129(a)(4).  There are several recent FAA Chief Counsel interpretations that suggest this isn’t the case.  The prime argument offered by the Chief Counsel is that the solo experience gained while training for a private pilot certificate is at a different level than that required for a Commercial pilot, even though most (but not all) of the areas of training are the same, they have different PTS standards applied for the private pilot and commercial pilot and are embodied in different sections of the FAR’s, that is 61.107 for the private training and 61.127 for the comercial training.  One more point is there is a subtle difference in wording for the solo time required in 61.109 private pilot training and that required in the commercial pilot training; namely that 61.109 says a “a person who applies for a private pilot certificate with an airplane category and single-engine class rating must log at least 40 hours of flight time that includes at least … and 10 hours of solo flight training”; whereas, 61.129 says “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 …”.

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  6. Kris Kortokrax on Feb 07, 2012

    You are absolutely correct.  Time logged towards the private doesn’t count toward the requirements for commercial.
    In the 1997 rewrite of Part 61, John Lynch made a concession to the insurance industry for the multi-engine airplane requirements.  He wrote 61.129 (b)(4) to require “10 hours of flight time performingthe duties of pilot in command in a multiengine airplane with an authorized instructor on the areas of operation listed in § 61.127(b)(2) of this part.”  I called him at that time because he had removed the capability for one to satisfy the training requirements by flying solo, as I had done.  He reinstated the solo language.
    In the 2009 rewrite of Part 61, he extended that language to ASEL, Helicopter, Gyroplane, Powered lift and Airship.
    Sadly, one can now become a commercial pilot in the aforementioned category/class areas with a grand total of 10 hours of solo time.

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  7. Eric on May 11, 2012

    The 300nmcross country need not be vfr correct?

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