I had 2 examiners ask me to make sure mine was all done in the same day. It may not be written, but it is certainly implied and adhered to.
If that was the case, we could do a 250nm cross-country one day and then a week later do another one and try to take credit for it.
Definitely. Im pretty sure there is an FAA interpretation for this but I cant seem to find it again...
What I did find was
John Lynch's Part 61 FAQ
It's since been replaced by the FAA by a far less detailed FAQ site so I dont know that I'd rely on it but the information on Part 61.129 starts on page 200. I know I've seen an official FAA interpretation that it need not be done in a single day and John's FAQ says pretty much the same thing.
They dont want to encourage someone to push on into deteriorating conditions just because they're "close" to the destination and dont want to lose credit for the flight.
Even some of the more readily available interpretations such as Van Zanen (2009) state how the pilot chooses to log segments is totally up to the pilot. If date were really an issue, how would you log those flights that go past midnight or those that are logged in UTC past midnight which ranges from +4 to +8 hours (or more in Hawaii and Alaska) in the US.
What's more confusing to me is the definition of Solo time. I've read several interpretations regarding logging of "solo" time and the history of the rules that suggests the intent of making the 300NM "solo" was to explicitly preclude "dual" time such as when multi while still unrated for multi and/or flying a plane that requires a crew of more than the PIC (thus no plane's with a required SIC).
Indeed Lynch's FAQ explicitly acknowledges the "simulated solo" that permits a CFI to come along was added purely due to insurance requirements.
I've seen nothing that suggests the term solo under this part means "sole-occupant" and in fact see more to suggest the intent was more as "sole-pilot." To me this interpretation is a collision with 61.87 relating to a student pilot but whereas 61.87(a) explicitly states the definition for solo under that subsection is "as the sole-occupant of the aircraft" there is no such definition of "solo" under 61.129 and the FAA has already issued rulings that though applying the time from "student-solo cross-countries" is allowed, the "student solo xc" cannot be applied towards any of the explicit cross-country requirements under 61.129 which by extension to me means a pilot pursuing a commercial under 61.129 is not a student pilot. So why cant you be the "solo-pilot with passengers?"
There's also a potential collision between 61.109 and 61.129 but again 61.109 states the solo time as "solo flight training time" indicating a student level of knowledge whereas 61.129 just says "solo flight time" and as already noted is a certificated pilot.
In the case of 61.87 and 61.109 the use of the word Solo is a restriction under which you can operate the plane meaning you are either DUAL with your instructor or you are the sole occupant. Once you have your ticket punched though, that requirement is removed and there is no expectation by the FAA that you log when you have or dont have passengers so really who's to say you did or did not have a passenger on board?
In some regards, having passengers on board is more realistic scenario. Sometimes they can be helpful providing charts or frequencies but more often than not they're a distraction; especially on longer flights.
I am aware that 61.51(d)(2) makes a provision for logging of "solo time" stating its only when you are the sole occupant but this to me is a holdover from before part 61 was rewritten when a student pilot could not log "PIC" and thus the "solo" column was born. Many log books dont even include a column for "solo" and the absence of a restatement that "solo under this part means sole occupant" for 61.129 when it is restated in 61.87 and 61.109 is notable.
Does anyone have an actual FAA interpretation on this or is it all scuttlebutt and "how I've seen it done?"
To me it seems the "solo" is an attempt to make the regs all read the same between multi/single/roto/etc. Most people transition to mult-engine in the commercial but the rule was included as such in the SEL section for those who got their PPL in a multi and are now adding a SEL (or maybe rotocraft, etc). Thus as a not previously rated Multi-pilot you'd could not take passenger or log PIC time with passengers because you are a student pilot for the purpose of Multi (just like when you start getting your private).
The rule was later updated to include "simulated solo" with an instructor because of issues with many flight schools insurance refusing to insure a "solo" multi-engine pilots without a rating or few hours or at all. The "simulated solo" even has interpretations that allows the instructor to permit passengers on board at their discretion which again goes back to the ability to take passengers during primary training when the instructor is on board at the instructor's discretion. I've also seen interpretations that permit the instructor to provide limited instruction and/or to act as a SIC on the 300NM "simulated solo" which negates arguments that the "CFI can ride along because they know not to interact with the pilot." If they can act like a SIC or offer limited instruction on CRM/PIC duties or as a safety pilot (there is was an interpretation suggesting 61.129(b)(4)(i) could be met under SIM instrument) than why cant a passenger who knows nothing about CRM/PIC duties or working as a SIC not come along? Or even a second pilot who might know these things and can act as a safety pilot but also knows not to directly involve themselves?
Also it should be noted there is nothing in the regulations preventing you from flying the 300NM as a one-way trip keeping it to 300NM. If the plane is being rehomed or otherwise is not required to be returned to its origin, then there's no problem on the other hand, most of us expect the plane to come back to the origin which means the 300 NM trip is really somewhere at least above 500NM for most of us but you could just as easily split the flight and the costs with another pilot even under the "sole-occupant" definition... Simply fly to a destination with a major airport serviced by one of the discount airlines and trade off at that airport.
KSAN to KPHX for example is 356 NM and is serviced by Spirit for $80 one-way... Puttering along at $125/hr for 120KTAS is $375 + $80 for the commercial flight = $455; some $300 cheaper than the roundtrip cost of doing it yourself and with the benefit of getting 2 people signed off for only slightly more than the price of 1. Even if one person had to spend the night in town because of no return commercial flight, splitting the hotel room still comes out cheaper. Of course you just have to remember to put in an extra stop (or 2) since most of us do the 3rd landing at a 3rd airport on the return leg as a landing at the origin.
