Help discerning reg 61.129

[Probablyflying]

Hey y’all!
I’m new here so apologies if this is the wrong form to post this question in.
I’ve gotten conflicting information from multiple MEI’s and curious if anyone has insight (from a DPE etc)
I’m getting my Initial multi engine commercial. I hold a PPL and IR. I am not getting a commercial single at this time as I don’t need it for the job I have lined up. I have about 100 hours of multi Dual Received which is why I’m doing it this way.
My question is concerning 61.129 Multi Engine Requirements. It says I need 5 Hours in night VFR conditions with 10 take offs and landings. I have multiple xc flights that took place at night where we were on an IFR plan but in VMC. I was “sole manipulator of the controls” and it got signed off as supervised solo. Would this count towards that? Or do I need to not be on a flight plan? Like I said we were completely Vmc the entire time. Thanks in advance!

 

[WannFly]

it says VFR conditions, doesnt say you have to be on a VFR flight plan or cannot be on IFR flight plan. I think that should suffice. more experienced people will chime in shortly as well

 

[RyanB]

Type of flight plan doesn’t matter. It wants those activities to be conducted in VFR (VMC) conditions and in your case, it sounds like they were, so yes it will count!

Oh, and if your MEI’s don’t understand this reg, fire them.

 

[RussR]

I've never understood why people (especially CFIs), want to read more into the regulations than is there. It says "VFR conditions".

So, ask yourself, "were we in VFR conditions".
If yes, then it counts.
If no, then it doesn't count.

That's pretty much all you need to ask.

And of course, assuming you were in VFR conditions the entire flight (and therefore didn't log any actual IMC), then there is nothing in your logbook that would even raise the question for the DPE.

 

[tonycondon]

Yes it will count, but make sure the "solo" xc and rest of the 10 hours "solo" time was also done PDPIC.

 

[NoHeat]

I think the FAA is sloppy in this terminology, “VFR conditions.“

They should use VMC always to describe weather conditions and cloud clearance that satisfy visual flight rules. Because conditions are conditions, and rules are rules. That common-sense practice would be clear, but they don’t do it always. And so there’s confusion.

Here’s an excerpt from the pilot/controller glossary, where (a) shows that “VFR conditions “can be applicable while flying under instrument flight rules, which is the OP’s situation.

VFR CONDITIONS− Weather conditions equal to or better than the minimum for flight under visual flight rules. The term may be used as an ATC clearance/instruction only when:
a. An IFR aircraft requests a climb/descent in VFR conditions.
b. The clearance will result in noise abatement benefits where part of the IFR departure route does not conform to an FAA approved noise abatement route or altitude.
c. A pilot has requested a practice instrument approach and is not on an IFR flight plan.
Note: All pilots receiving this authorization must comply with the VFR visibility and distance from cloud criteria in 14 CFR Part 91. Use of the term does not relieve controllers of their responsibility to separate aircraft in Class B and Class C airspace or TRSAs as required by FAAO JO 7110.65. When used as an ATC clearance/instruction, the term may be abbreviated “VFR;” e.g., “MAINTAIN VFR,” “CLIMB/DESCEND VFR,” etc.

 

[Trogdor]

Yes it will count, but make sure the "solo" xc and rest of the 10 hours "solo" time was also done PDPIC.

This.