10 hour solo training requirement for commercial?

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James Darren

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James Darren
What is the 10 hour solo training requirement when doing your commercial certificate? Is this solo training after an instructor signs you off? (similar to when you do your PPL training?)
 
61.129 A (4)


(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.


Sent from my iPad using Tapatalk Pro
 
If you're asking: "Does my Commercial CFI need to sign off on post-PPL solo time, to count towards these requirements?" then the answer is no. You're a PPL, fly solo however you please. Note all your solo flights as such in your logbook so they can be found easily.
 
Not instrument rated (just a few sim hours) and not a commercial student. I've wanted to complete some of the 10 solo hours for commercial, but how would I prove that one of these flights (the 300NM XC or night solos) cover the "areas of operation listed under §61.127(b)(1)"?
Or am I overthinking it, since almost all of 61.127(b)(1) is also listed for the PPL (61.107(b)(1))?
 
Michael Kelly said:
Not instrument rated (just a few sim hours) and not a commercial student. I've wanted to complete some of the 10 solo hours for commercial, but how would I prove that one of these flights (the 300NM XC or night solos) cover the "areas of operation listed under §61.127(b)(1)"?
Or am I overthinking it, since almost all of 61.127(b)(1) is also listed for the PPL (61.107(b)(1))?
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You just need to make appropriate entries in the logbook. No need to “prove” it further than that. I would also perhaps add a note that this is for the Commercial requirement, whatever it is. Also keep a list of the dates of the flights for each requirement to make it easier to find them when the examiner asks.
 
You list the airports you visited on the trip (which you probably would do anyhow). Same as with any XC you need to log for a certificate (even for your private).
 
Nsconductor said:
61.129 A (4)


(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.


Sent from my iPad using Tapatalk Pro
Click to expand...

this is what I really get mixed up on for some reason-
So the 300 mile XC is solo by yourself, or solo with a CFI on board? Or can it be either way?
 
There is no such thing as "solo with a CFI on board." Solo means "sole occupant of the aircraft" with the exception of aircraft that are certificated to require more than one pilot.

But for the commercial says either solo OR "performing the duties of pilot in command ... with an authorized instructor on board." (I.e., the CFI ballast or dummy as it's often called). So yes, either one or a mixture of both can be used.

The "cfi dummy" provision was added a while back because it was getting harder to find schools who could rent (especially multiengine) aircraft for solo flight.
 
flyingron said:
So yes, either one or a mixture of both can be used.
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No, a mixture of both cannot be used. It’s either one or the other. If you look at the position of the word “or” in the regulation this becomes clearer, and it is the subject of a chief counsel letter as well.

And this is reasonable to me. If insurance requires a CFI along, then you need to do the whole solo-ish time with a CFI. If insurance doesn’t require a CFI along, then you “should” (my opinion) do it solo. But you don’t get to pick and choose.

https://www.faa.gov/about/office_or...016/Grannis - (2016) Legal Interpretation.pdf
 
RussR said:
No, a mixture of both cannot be used. It’s either one or the other. If you look at the position of the word “or” in the regulation this becomes clearer, and it is the subject of a chief counsel letter as well.

And this is reasonable to me. If insurance requires a CFI along, then you need to do the whole solo-ish time with a CFI. If insurance doesn’t require a CFI along, then you “should” (my opinion) do it solo. But you don’t get to pick and choose.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2016/Grannis - (2016) Legal Interpretation.pdf
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Yup, that’s where ‘or’ is so that’s the way it is. Don’t pass the logic with me though. The you may need a CFI along for insurance thing I get and it’s nice the FAR accommodates this. But say you are flying airplane A that needs the CFI along. You get 5 hours in and then it becomes unavailable for some reason. So you find an airplane B that doesn’t need the CFI along. You have to reset the clock and start the 10 hours over from scratch or needlessly hire a CFI? This borders on absurd. @Ryan F. , what would you do about an applicant who showed up with 5 hours PIC time with ‘ballast’ CFI along, and 5 hours solo time?
 
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Michael Kelly said:
Not instrument rated (just a few sim hours) and not a commercial student. I've wanted to complete some of the 10 solo hours for commercial, but how would I prove that one of these flights (the 300NM XC or night solos) cover the "areas of operation listed under §61.127(b)(1)"?
Or am I overthinking it, since almost all of 61.127(b)(1) is also listed for the PPL (61.107(b)(1))?
Click to expand...
What you're discovering is that 61.129 is among the worst written FARs. There are missing words and extra words. And considering the number of fakakte chief counsel opinions and it, I'm amazed the faa hasn't fixed it, but it's the faa. You can't have a solo flight "on" training requirements. It's gibberish.
 
James Darren said:
What is the 10 hour solo training requirement when doing your commercial certificate? Is this solo training after an instructor signs you off? (similar to when you do your PPL training?)
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No. No signoff is required.

The commercial solo requirement is not a "training" requirement, just a requirement you fly a solo cross country with a certain length.

If one wants to be super-technical, it has to cover the "areas of operation listed under §61.127(b)(1)," but it would be difficult to find a post-private loggable cross country flight of any kind which does not meet that standard. That's actually what the "areas of operation" language is for. The FAR uses it to distinguish qualitative, as opposed to quantitative, differences in certificates and ratings. IOW, while both the student solo cross country and the commercial solo cross country have "navigation" as an area of operation (duh), the commercial version, at least in theory, should be qualitatively better than the navigation skills you exhibited as a student pilot. In the case of the commercial certificate, it's only real function is to say, "stuff you did as a student pilot does not fulfill any 61.127 task."
 
flyingron said:
There is no such thing as "solo with a CFI on board." Solo means "sole occupant of the aircraft" with the exception of aircraft that are certificated to require more than one pilot.

But for the commercial says either solo OR "performing the duties of pilot in command ... with an authorized instructor on board." (I.e., the CFI ballast or dummy as it's often called). So yes, either one or a mixture of both can be used.

The "cfi dummy" provision was added a while back because it was getting harder to find schools who could rent (especially multiengine) aircraft for solo flight.
Click to expand...
Thanks. I guess that’s what was confusing for me about it- that is has to be solo of with CFi ballast. I only recently learned of this term and that makes more sense. I was always searching in past for an answer that was more precise in that it was with or with out. Not either. So it solo. And if a CFI is on board it’s not really for instruction- just for insurance perhaps.
 
Lindberg said:
What you're discovering is that 61.129 is among the worst written FARs. There are missing words and extra words. And considering the number of fakakte chief counsel opinions and it, I'm amazed the faa hasn't fixed it, but it's the faa. You can't have a solo flight "on" training requirements. It's gibberish.
Click to expand...

I was thinking fakakte was a typo for fake, but had to look it up.
https://jel.jewish-languages.org/words/162
 
One thing to consider if you ever think you want to get an instrument or commercial rating is that the experience never expires. I started my instrument training in 2000 and did the cross-country and all the other requirements and all of that counted when I actually got it in 2019. The only thing I had to do was have the 3 hours in 60 days prep for the test.

So after you get your PPL, when it gets dark at a reasonable hour, do the 10 night takeoffs and landings with a control tower. If you are going on a trip over 300 miles, make it a point to stop a couple of times on the way to meet the long cross-country requirement. As a new pilot it’s probably not a good idea to fly at night with only 3 hours of night flying, so plan a day flight and night return to a destination a few hours away to get some night training with an instructor.

I’d also suggest getting hood time when you fly with another pilot. First get a few hours with an instructor to fully understand how to scan and then practice whenever you can.
 
JScarry said:
One thing to consider if you ever think you want to get an instrument or commercial rating is that the experience never expires. I started my instrument training in 2000 and did the cross-country and all the other requirements and all of that counted when I actually got it in 2019. The only thing I had to do was have the 3 hours in 60 days prep for the test.

So after you get your PPL, when it gets dark at a reasonable hour, do the 10 night takeoffs and landings with a control tower. If you are going on a trip over 300 miles, make it a point to stop a couple of times on the way to meet the long cross-country requirement. As a new pilot it’s probably not a good idea to fly at night with only 3 hours of night flying, so plan a day flight and night return to a destination a few hours away to get some night training with an instructor.

I’d also suggest getting hood time when you fly with another pilot. First get a few hours with an instructor to fully understand how to scan and then practice whenever you can.
Click to expand...

Thanks. I'd actually got a few hours into the instrument training (sim time only & ground school) and stopped.
Trying to knock out smaller requirements in the mean time, till I can go full speed ahead on the instrument and so on.
 
Lindberg said:
If it meets the requirements, it meets the requirements.
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"Regardless of whether the applicant previously completed a night cross-country flight that meets the requirements under §61.129(c)(3)(iii), the applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see §61.127), not while training for a different certificate." (emphasis added)

That's from the 2010 Theriault Chief Counsel Letter talking about applying the student night dual cross country to the commercial night dual cross country. The FAA's anti-double-dip philosophy has been applied in other situations, most notably (and stupidly) saying having an instrument rating doesn't automatically waive the need for the 10 hours instrument training for the commercial certificate. I guess one could argue that all of these are positions on specific tasks and not a position of general applicability and, since the Chief Counsel didn't specifically talk about the solo cross country it's fair game. I wouldn't, but one could.
 
midlifeflyer said:
That's from the 2010 Theriault Chief Counsel Letter talking about applying the student night dual cross country to the commercial night dual cross country.
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Which has no basis in the reg, and is wrong. Fortunately, the FAA "clarified" this opinion somewhat in the 2018 Oord letter.
 

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Lindberg said:
Which has no basis in the reg, and is wrong. Fortunately, the FAA "clarified" this opinion somewhat in the 2018 Oord letter.
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True - the "clarification" part. That's why I said "automatically." But Theriault and the others still stand. I'm wondering what a CFI statement that his student pilot meets commercial requirements on his solo xc would look like. And whether it woul hold water.
 
midlifeflyer said:
That's why I said "automatically."
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Ok.
midlifeflyer said:
"stuff you did as a student pilot does not [automatically] fulfill any 61.127 task."
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This is a correct statement. But you could replace "student pilot" with almost anything, or nothing, and it would still be true.

The aeronautical experience you use to qualify for your commercial rating must be properly documented and you must be able to prove it covers the required subject matter. No more, no less.
 
midlifeflyer said:
I'm wondering what a CFI statement that his student pilot meets commercial requirements on his solo xc would look like.
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What does a CFI statement on any pilot's
solo cross country look like? I've never had a CFI sign off on a solo cross country, before or after I earned my private. He wasn't there, what would he be signing off on? Sure, students need an endorsement, but it says nothing about what occurs on the flight.
 
Lindberg said:
What does a CFI statement on any pilot's
solo cross country look like? I've never had a CFI sign off on a solo cross country, before or after I earned my private. He wasn't there, what would he be signing off on? Sure, students need an endorsement, but it says nothing about what occurs on the flight.
Click to expand...
I agree. I said that because I doubt the FAA would accept, "l fulfilled commercial requirements in my solo" from a student pilot. Just following the discussion, not parsing each post in a vacuum.
 
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midlifeflyer said:
I agree. I said that because I doubt the FAA would accept, "l fulfilled commercial requirements in my solo" from a student pilot. Just following the discussion, not parsing each post in a vacuum.
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You've lost me.

Let's say a student pilot performs a cross-country flight of 301 nautical miles total distance, with landings at three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point, and one segment of the flight is a straight-line distance of 51 nautical miles. He's fulfilled the requirement of 61.109(a)(5)(ii). When he later decides he wants to get a commercial rating, what else would he have to do in order to satisfy 61.129(a)(4)(i)?
 
Lindberg said:
You've lost me.

Let's say a student pilot performs a cross-country flight of 301 nautical miles total distance, with landings at three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point, and one segment of the flight is a straight-line distance of 51 nautical miles. He's fulfilled the requirement of 61.109(a)(5)(ii). When he later decides he wants to get a commercial rating, what else would he have to do in order to satisfy 61.129(a)(4)(i)?
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Another cross country that meets the requirements after earning his private certificate. The FAA has not addressed this specific scenario and I'm obviously not an infallible soothsayer, but based on others it has addressed I think it more likely than not the FAA position on it would be, to modify an existing statement,

"Regardless of whether the applicant previously completed a [deleted] cross-country flight that meets the requirements under §61.129(a)(4)(i) (changed reference] they applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see §61.127), not while training for a different certificate."
(We're talking about an commercial "certificate" not a commercial "rating." I'm not being picky. It makes a difference.)

Obviously you disagree. That's fine. You could be right.
 
One thing that always puzzled me was why this 10 hours has to be solo. I mean, what's special about solo as compared to flying with passengers, especially since a CFI is allowed to ride along for insurance purposes?
 
sarangan said:
One thing that always puzzled me was why this 10 hours has to be solo. I mean, what's special about solo as compared to flying with passengers, especially since a CFI is allowed to ride along for insurance purposes?
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Many pilots have their non-pilot passengers assist them in various ways. Apparently the FAA wants this to be a true single-pilot operation for ten hours.

given the “How to ease nerves flying solo” thread, maybe it’s a good idea.
 
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"takeoff and landings at a towered airport"...............does the tower have to be open? :)
 
SOLOING isn't "training." All it says is you need a certain hours and you need to visit airports at a certain distance.

Now the "training" experience requirements do need to show that they cover the areas that the regs require for the rating being sought (the gist of the Oord letter).
 
midlifeflyer said:
"Regardless of whether the applicant previously completed a night cross-country flight that meets the requirements under §61.129(c)(3)(iii), the applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see §61.127), not while training for a different certificate." (emphasis added)

That's from the 2010 Theriault Chief Counsel Letter talking about applying the student night dual cross country to the commercial night dual cross country. The FAA's anti-double-dip philosophy has been applied in other situations, most notably (and stupidly) saying having an instrument rating doesn't automatically waive the need for the 10 hours instrument training for the commercial certificate. I guess one could argue that all of these are positions on specific tasks and not a position of general applicability and, since the Chief Counsel didn't specifically talk about the solo cross country it's fair game. I wouldn't, but one could.
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It's too bad they didn't spell that out explicitly in the regs, instead of making people hunt for a needle in a haystack in the Chief Counsel opinions (without knowing in advance that there is something to hunt for).
 
flyingron said:
There is no such thing as "solo with a CFI on board." Solo means "sole occupant of the aircraft" with the exception of aircraft that are certificated to require more than one pilot.

But for the commercial says either solo OR "performing the duties of pilot in command ... with an authorized instructor on board." (I.e., the CFI ballast or dummy as it's often called). So yes, either one or a mixture of both can be used.

The "cfi dummy" provision was added a while back because it was getting harder to find schools who could rent (especially multiengine) aircraft for solo flight.
Click to expand...

^^ this.

If you’re doing single engine commercial the whole carve out for a silent deaf mute CFI in the other seat really is just an insurance company forced thing for multiengine applicants.

Just fly your solo hours and log them. The reg having the carve out just confuses people.
 
sarangan said:
One thing that always puzzled me was why this 10 hours has to be solo. I mean, what's special about solo as compared to flying with passengers, especially since a CFI is allowed to ride along for insurance purposes?
Click to expand...

MauleSkinner said:
Many pilots have their non-pilot passengers assist them in various ways. Apparently the FAA wants this to be a true single-pilot operation for ten hours.

given the “How to ease nerves flying solo” thread, maybe it’s a good idea.
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Again ^^^ this ^^^. Besides non pilot passengers many fly with experienced pilots like family and such, especially pro pilot’s kids flying the family airplane.

FAA wants you to do a little flying all by your lonesome with nobody there other than the ATC voices in your head to ask for help with anything.

People found all sorts of crazy ways to cram multiple people in airplanes and pretend to get XC experience that kinda matched the old rules long long ago, so FAA keeps adding word salad to get their point across as to what they’re really wanting as experience before a pilot applies to carry the unsuspecting general public around for dollars.

It’s made a mess of the wording of the regs over a long period of time, but most of us also cringe at what oddities we’d get from a complete re-written version, too. LOL

We are talking about the same writers who removed slow flight from the standard, then put it back, kinda... and with some of the weirdest wording possible in every revision... ;)

Wurds is hard and Pile-Its don’t read so gud. LOL
 
Palmpilot said:
It's too bad they didn't spell that out explicitly in the regs, instead of making people hunt for a needle in a haystack in the Chief Counsel opinions (without knowing in advance that there is something to hunt for).
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It's just one of those things that make America great. That's tongue in cheek but it's also reflective of the truth. In the US, laws and regulations get interpreted. Sometimes by letter opinions (like the Chief Counsel, IRS, and financial regulatory agencies do). Sometimes by guidance documents like the AIM or the Federal Reserve Compliance Guide). Sometimes by administrative enforcement.

We may not like it but it's not going to change. As the saying goes, it's not our fault but it is our problem.
 
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midlifeflyer said:
It's just one of those things that make America great. That's tongue in cheek but it's also reflective of the truth. In the US, laws and regulations get interpreted. Sometimes by letter opinions (like the Chief Counsel, IRS, and financial regulatory agencies do). Sometimes by guidance documents like the AIM or the Federal Reserve Compliance Guide). Sometimes by administrative enforcement.

We may not like it but it's not going to change. As the saying goes, it's not our fault but it is our problem.
Click to expand...
People complaining about it online is also not going to change! ;)
 
midlifeflyer said:
Another cross country that meets the requirements after earning his private certificate. The FAA has not addressed this specific scenario and I'm obviously not an infallible soothsayer, but based on others it has addressed I think it more likely than not the FAA position on it would be, to modify an existing statement,

"Regardless of whether the applicant previously completed a [deleted] cross-country flight that meets the requirements under §61.129(a)(4)(i) (changed reference] they applicant must satisfy that requirement while training for a Commercial Pilot Certificate (see §61.127), not while training for a different certificate."
(We're talking about an commercial "certificate" not a commercial "rating." I'm not being picky. It makes a difference.)

Obviously you disagree. That's fine. You could be right.
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I don't know why you're ignoring Oord, but let's assume I care more about what the regs say than what an incompetent bureaucrat thought and had to be corrected on by another bureaucrat. Can you support the above statement in the regs?
 
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