61.129 question

[RLCarter]

The question is on the two 2 hour cross-countries and the 300 nm cross-country, are these dual? I read them as dual in which my CFI gets 3 Free meals.....lol

§61.129   Aeronautical experience.

(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.

[smwash02]

Robert,

What's key to note is that two are under (3) "20 hours of training ..." and one is under (4) "Ten hours of solo ..."

Answering your question, the first two are dual and the third is solo.

 

[midlifeflyer]

Same question. Same answer.

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.

OTOH, 91.129(a)(4) describes solo requirements.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.

[RLCarter]

Thanks to all for confirming my suspension, As you'll might have guessed, I'm starting back on my commercial ticket. I'm on my 5th or 6th instructor and actually he was my 2nd choice but he had trouble getting in and out of the Mooney. With the reg change last year and getting his CFI-I reinstated we started back on my training in the 172. Hopefully we can get this knocked out in a couple of months, the long x-country will be done in the Mooney. 

[smwash02]

You may want to check your private pilot training entries. You may have already completed two dual cross country flights. I'd also be surprised if you didn't already have the solo one completed as well.

[midlifeflyer]

52 minutes ago, smwash02 said:

You may want to check your private pilot training entries. You may have already completed two dual cross country flights. I'd also be surprised if you didn't already have the solo one completed as well.

All of these must be post-private certificate. Can't "double dip" the private requirements into the commercial ones.  The key is the phrasing "on the areas of operation listed in §61.127(b)(1)"

The FAA uses the “areas of operation” language to differentiate requirements, and it is used both literally (they read the same in the requirements) and qualitatively (commercial pilot level tasks are presumed to be qualitatively different from student pilot level tasks). The FAA Chief Counsel has gone on record with a pretty strict “no” about student pilot tasks be used later for advanced “areas of operation” requirements See, for example, the 2011 Murphy Letter.

(Yes, there is some wiggle room for double-dipping the instrument rating tasks into the commercial requirement. )

Edited August 5, 2019 by midlifeflyer

[RLCarter]

I had planned on just flying the hours off, that way it’s easier to find in my logbook and there’s no questions 

[Hank]

3 hours ago, RLCarter said:

I had planned on just flying the hours off, that way it’s easier to find in my logbook and there’s no questions 

Review your logbooks, put post-its on pages to discuss with your instructor. Write paragraph numbers on post-its for flights that count, throw away the ones that don't. 

[Browncbr1]

For the two hour cc, if you already have your IR and you did those dual two hour cc Vfr, you can also use those flights toward the commercial requirements.   You can do the 300nm cc solo.  

When I got my commercial, I was able to use a combination of flights from instrument training and all I had to do was the 300nm because it had to be solo.   The only dual I needed was the 4 hours within 90 days prep as required before the checkride   

 

Edited August 13, 2019 by Browncbr1