64. This revision of Sec. 61.129 amends the commercial pilot
certification solo aeronautical experience requirements to allow the
aeronautical experience to be performed either solo or while performing
the duties of PIC with an instructor on board
This final rule revises Sec. 61.129(a)(4), (c)(4), (d)(4), (e)(4),
and (g)(2) to allow the commercial pilot certification aeronautical
experience to be conducted either solo or while performing the duties
of PIC with an instructor on board. Even though the commercial pilot
certification aeronautical experience requirements for a multiengine
airplane rating allow the aeronautical experience requirements to be
conducted either solo or with an authorized instructor on board (See
Sec. 61.129(b)(4)), the solo aeronautical experience requirements were
purposely written differently for other aircraft categories. This is
because comments received in response to Notice No. 95-11 (60 FR 41160-
41284; August 11, 1995) indicated that some insurance policies prohibit
persons who do not already hold the multiengine airplane category and
class rating on their pilot certificate from flying solo in multiengine
airplanes.
Five commenters supported the proposed provision permitting flights
previously required to be performed solo with an instructor on board.
One commenter stated the knowledge requirements are unchanged, and an
additional pilot scanning for traffic enhances safety. Three commenters
asserted that upon receiving private pilot certificates, pilots are
permitted to fly solo and carry passengers, and should have no further
solo flight requirements.
Thirteen commenters opposed the provision with seven arguing that
solo flight contributes to the development of essential self-reliance,
decision-making, and command skills. Two commenters stated that, under
the proposed rules, a pilot could progress all the way to an ATP
certificate with only 10 hours of solo flight early in training. One
commenter recommended pilots completing a commercial certificate with
zero solo time in class be issued ratings limited to second in command
(SIC) privileges. One commenter suggested if it is not possible for an
applicant to perform the flights solo, then dual instruction
requirements should be increased. Two commenters believed the proposed
provision is driven by insurance and cost concerns, rather than safety
or education concerns and insurance concerns should not restrict solo
flight by commercial pilot candidates. The commenter stated most
commercial pilot training is performed in either a single engine fixed
gear airplane or in some low performance single engine retractable gear
airplane, neither of which is difficult to insure.
The Greater St. Louis Flight Instructor Association rejected the
argument that flights with an instructor on board foster cockpit
resource management (CRM) skills, noting that the purpose of part 61
training is to prepare pilots to fly to single-pilot standards, not to
prepare them for a future airline career. The association also asserted
the proposed provision subverts the intent of Sec. 91.3, which defines
the PIC as directly responsible for, and the final authority on, the
operation of the aircraft. Finally, the association asserted students
ostensibly acting as PIC will defer to flight instructors and
Examiners.
One commenter recommended solo cross country experience be
required, but that pilots working toward a commercial multiengine
airplane rating be permitted to perform the flights in a single engine
airplane to avoid potential insurance conflicts. Two commenters,
including AOPA, recommended permitting performance of cross country
flights solo or with an instructor on board and that commercial pilot
candidates be permitted to perform the flights with passengers on
board. One commenter recommended all pilots who hold a private or sport
pilot certificate be permitted to fulfill solo flight requirements for
additional certificates or ratings with an instructor on board, or
while carrying passengers, arguing that carrying passengers allows
pilots to share costs and expose potential future students to the
experience of flight without degrading safety. Finally one commenter
opposed the underlying requirement for a long cross country flight from
commercial pilot candidates because it is only meant to conform to ICAO
standards.
Since the adoption of Sec. 61.129, the FAA has learned that some
operators of the other categories and classes of aircraft also have the
same insurance policy restrictions. Many of these aircraft operators
also believe solo provisions for commercial pilot certification-
multiengine airplane rating is beneficial in teaching crew resource
management (CRM). These provisions permit the training to be performed
solo or with an instructor on board while the applicant is performing
the duties of PIC in a multiengine airplane. Some operators have said
that they will be agreeable to their commercial pilot applicants
practicing abnormal and emergency procedures if the applicant's
instructor was on board. Therefore, this final rule provides for
commercial pilot certification for the single engine airplane,
helicopter, gyroplane, powered-lift, and airship ratings to be
performed either solo or while performing the duties of PIC with an
authorized instructor aboard.
We believe the negative comments against this proposal are more of
a philosophical disagreement than a safety issue. The existing rule,
Sec. 61.129(b)(4), has permitted the commercial pilot-airplane
multiengine training to be performed either solo or with an instructor
on board since August 4, 1997, and there has not been any difference
noted in safety or the quality of the skills and abilities of
commercial pilot-airplane multiengine applicants. We believe applicants
and instructors have used this training for commercial pilot-airplane
multiengine applicants to achieve proficiency in crew resource
management and coordination with an SIC designated pilot.
For the stated reasons, the FAA is adopting the revision as
proposed in the NPRM.
Hell, you could have done all of that stuff in your 170. In fact, your trip from the ConUS back to Alaska in the 170 easily counts for the solo XC.
But I did do the long cross country in my 170 last month. It was a nice flight across the Arctic Circle and back.
