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7 Answers

IACRA Solo Time

Asked by: 5749 views FAA Regulations, Flight Instructor, General Aviation

I'm filling out IACRA for my Commercial MEL add-on. In the section where it asks for solo time, I entered 337 hours because that's what I have as of today. My CFI sent it back to me for correction saying that they are only asking about solo time before becoming a private pilot. This doesn't make sense to me but of course the FAA is great at not making sense. Is my CFI right?

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7 Answers

  1. Best Answer


    KDS on Mar 13, 2020

    It would be fascinating to learn where people get such ideas stuck in their head.

    This is a quote from the old FAA IACRA Instruction Manual which is also parroted a couple times in the old John Lynch FAQ\’s:

    The minimum pilot experience required by the appropriate regulation must be entered. It is recommended, however, that ALL pilot time be entered.

    The problem you face is trying to correct someone who may instead of appreciating it take it as an affront. You could ask him to call the IACRA Help Desk 1-844-322-6948 and inquire with them. The problem I\’ve found with the Help Desk is there can be excessively long delays waiting for someone to call you back. However, for all the Help Desk flaws, that may be the solution that lets him save face as much as possible.

    Other possibilities are asking him to show you the guidance for that statement. Another one is to bring another CFI into the discussion. Unfortunately, that is going to embarrass him in front of his peers, or worse yet, the other CFI will be equally ill informed.

    Of course, you could always just act like you believe him and do as he suggests. The only difference it makes is that the 8710-1 serves as a record of flight time if you lose your logbooks. However, you can put the real numbers in on a subsequent application.

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  2. hish747 on Mar 13, 2020

    Thank you very much for your response, KDS. Placating my CFI by putting a number that I believe to be false seems problematic for 2 reasons. First, I’m certifying under penalty of perjury that the my solo hours are 13 when I know they are 337. The second issue is that the IACRA for my instrument and Commercial SEL list solo time in the hundred of hours so it would be strange for them to go down, don’t ya think? 🙂

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  3. Max Trescott on Mar 14, 2020

    Sure, if you have 337 hours of solo time as a student pilot before you got your Private, then enter it under Solo in IACRA. Note that solo is defined as the time that a \”student pilot\” is the sole occupant of the aircraft.
    61.87 Solo requirements for student pilots.
    (a) General. A student pilot may not operate an aircraft in solo flight unless that student has met the requirements of this section. The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft or that flight time during which the student performs the duties of a pilot in command of a gas balloon or an airship requiring more than one pilot flight crewmember.

    All of the time you fly in single engine land aircraft after you get your Private is considered PIC time. The FAA changed the rules a few years ago so that Solo time can now be added to PIC time. But the reverse is not true: you don\’t take all of your time as PIC after you get your Private and call that solo time.

    Your CFI is right on this one….unless you were a student pilot for over 300 hours!

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  4. hish747 on Mar 14, 2020

    Hi Max,
    Thank you very much for your response. I guess the confusing question is this:

    Is IACRA asking for my solo time as logged (61.51d) or solo time as a student pilot (61.87).

    I am completing an IACRA for my Commercial Multi-Engine add-on. I am not and haven’t been a student pilot since 1999. So why is the number of hours (13.7) I had back in 1999 prior to becoming a licensed pilot even relevant? It seems that they would want to know my solo time as logged at the time I’m applying for the Commercial MEL today.

    This is the confusion. LOVE the podcast and listen to every episode.
    Hish

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  5. KDS on Mar 14, 2020

    Hish,

    You’re very wise to take falsification seriously. I’ve seen several falsification cases including an FAA manager and the outcomes were devastating. However, it is not perjury.

    Remember, in the words of the FAA it is RECOMMENDED to put all pilot time, not REQUIRED.

    A whole lot of flight instructors have renewed their flight instructor certificates with no time on the application (or 0.01 hours back when the software had a glitch in it).

    You know the personalities involved and the situation better than anyone, so you are in the best situation to choose the optimal path, but do not worry about the FAA becoming upset for not putting every last hour on your application.

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  6. Russ Roslewski on Mar 15, 2020

    Max, I could not disagree more. While 61.87 may say solo time is only as a student, it also says “The term “solo flight” as used in this subpart…” – “this subpart” is Part 61 Subpart C – Student Pilots. Therefore that definition of solo time is only applicable to Student Pilots.

    The OP is not a student pilot, he is seeking his Commercial AMEL. Therefore 61.51d is applicable as the general case, which says “a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.”

    The 8710-1 does not say anything about “only as a student”, so the general definition is the only reasonable one.

    Also note that if your statement that solo time after your Private checkride doesn’t count as “solo”, then nobody would be able to even get a Commercial rating, which explicitly requires solo time.

    Pre-1997, student solo time specifically did not count as “PIC”. This didn’t really make any sense (since the only one in the airplane would logically be the pilot “in command”, so in 1997 they changed this to allow student solo time to be logged as PIC. However, this has no bearing on the ability of already-rated pilots to log solo time.

    OP – if you have 337 hours of solo time, that’s what goes in IACRA and on the 8710-1. I don’t know where these other interpretations are coming from.

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  7. KDS on Mar 15, 2020

    Russ,

    I know that decisions related to regulations are not done by vote, but I should say that I agree with what you wrote.

    In the process of looking for details related to logging solo flight time, I came across this in the old John Lynch FAQ’s that speaks to the point you noted about PIC time before and after August 4, 1997:

    QUESTION: Can solo flight time, under the old 61/141, logged by the Student Pilot now be considered PIC flight time?

    ANSWER: Ref. § 61.51(d) and § 61.51(e)(4); Yes; All time logged as solo time prior to August 4, 1997 can now be also logged as PIC flight time provided it meets the requirements of § 61.51(e)(4). It can be logged as both solo time and PIC flight time.

    I remember when that happened and I can still hear the FAA saying again and again that two hours of solo time and two hours of PIC time logged for the same two hour flight does not mean you have four hours of flight time. It seemed kind of obvious to me, but I guess when people are desperate for flight time such obvious facts bear noting.

    KDS

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