CPL(airplane) experience requirements

[cowman]

So I'm getting closer to scheduling a checkride and we're going through the experience requirements, specifically what's in 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.

I went out and did part (ii) solo last week just to make sure it's there. Annoyingly, although I have LOTS of flights in my logbook that would otherwise work for part (i) none that I can recall were flown solo... or fall short of one of the other requirements. I've contrived a reason to go somewhere > 250nm away to knock it out, was going to just have my CFI come along so we could all log time and I could possibly bring my family along for the fun of it. However, my CFI is saying that BOTH (i) and (ii) have to be done either solo or with an instructor- in other words I can't do one part of it solo and another with an instructor. So he says if he went along I'd have to re-do my 10 towered night takeoffs and landings with him. That's not how I'm reading it but if I understand what he's telling me right, that's the interpretation.

Anyone have any insights on this? Interpretations/etc? I might just call the DPE and ask him how he'd interpret it since he'll be the one judging it.

Also to anyone early in their flying career, a word of advice- start logging solo time. I know it's not even a column/box in a lot of logbooks but if you decide to do CPL a decade and hundreds of hours later it's helpful.

 

[dmspilot]

So I'm getting closer to scheduling a checkride and we're going through the experience requirements, specifically what's in 61.129(a)(4)



I went out and did part (ii) solo last week just to make sure it's there. Annoyingly, although I have LOTS of flights in my logbook that would otherwise work for part (i) none that I can recall were flown solo... or fall short of one of the other requirements. I've contrived a reason to go somewhere > 250nm away to knock it out, was going to just have my CFI come along so we could all log time and I could possibly bring my family along for the fun of it. However, my CFI is saying that BOTH (i) and (ii) have to be done either solo or with an instructor- in other words I can't do one part of it solo and another with an instructor. So he says if he went along I'd have to re-do my 10 towered night takeoffs and landings with him. That's not how I'm reading it but if I understand what he's telling me right, that's the interpretation.

Anyone have any insights on this? Interpretations/etc? I might just call the DPE and ask him how he'd interpret it since he'll be the one judging it.

Also to anyone early in their flying career, a word of advice- start logging solo time. I know it's not even a column/box in a lot of logbooks but if you decide to do CPL a decade and hundreds of hours later it's helpful.

It's ten hours of one or ten hours of the other. Not some of one and some of another with a total of 10 hours. IOW your instructor is correct. There is a CC letter somewhere that makes it official.

 

[cowman]

It's ten hours of one or ten hours of the other. Not some of one and some of another with a total of 10 hours. IOW your instructor is correct. There is a CC letter somewhere that makes it official.

Darn, I was hoping someone had a better interpretation. Oh well it least it will be a quiet flight.

It's certainly irritating being well in excess of these experience requirements in the spirit of the regs but not the letter...

 

[TCABM]

Seems clear to me. 10hrs solo OR 10hrs PDPIC. Pick your poison up front and complete the subtasks as one OR the other, but don’t mix and mingle.

 

[cowman]

Seems clear to me. 10hrs solo OR 10hrs PDPIC. Pick your poison up front and complete the subtasks as one OR the other, but don’t mix and mingle.

That appears to be the consensus. I probably read the reg a dozen times myself and if nobody had told me I never would have interpreted it that way.

Am I just being obtuse or is there an FAA way of reading these things that I've just never quite gotten 'with' before?

 

[MauleSkinner]

That appears to be the consensus. I probably read the reg a dozen times myself and if nobody had told me I never would have interpreted it that way.

Am I just being obtuse or is there an FAA way of reading these things that I've just never quite gotten 'with' before?

Note that it doesn’t say 10 hours of solo or PDPIC. It says 10 hours of one or 10 hours of the other. It really is plain English.

 

[sarangan]

The somewhat puzzling requirement to log 10 hours of solo flight time - completely alone in the airplane - probably dates back to a time when pilots took the commercial checkride directly from a student pilot certificate. That would also explain why the commercial maneuvers are essentially a more precise version of those on the private pilot checkride. But when you first earn your private certificate and then work toward commercial, the way the regulations are written doesn’t quite make sense. At least, that’s how I see it. After all, what are you really going to learn on a solo cross-country that you wouldn’t learn just as well with passengers on board?

 

[MauleSkinner]

The somewhat puzzling requirement to log 10 hours of solo flight time - completely alone in the airplane - probably dates back to a time when pilots took the commercial checkride directly from a student pilot certificate. That would also explain why the commercial maneuvers are essentially a more precise version of those on the private pilot checkride. But when you first earn your private certificate and then work toward commercial, the way the regulations are written doesn’t quite make sense. At least, that’s how I see it. After all, what are you really going to learn on a solo cross-country that you wouldn’t learn just as well with passengers on board?

Independence and/or self-reliance.

 

[midlifeflyer]

That appears to be the consensus. I probably read the reg a dozen times myself and if nobody had told me I never would have interpreted it that way.

I guess the reg is subject to being interpreted either way. But "consensus" is irrelevant when there is an official interpretation from the FAA guiding the process. This isn't the first time and it won't be the last time regulations were interpreted in a way that reflected policy.

 

[midlifeflyer]

Also to anyone early in their flying career, a word of advice- start logging solo time. I know it's not even a column/box in a lot of logbooks but if you decide to do CPL a decade and hundreds of hours later it's helpful

Actually happened to a pilot I used to know. Solo wasn't logged and the DPE rejected the claimed solo hours.

 

[RussR]

After all, what are you really going to learn on a solo cross-country that you wouldn’t learn just as well with passengers on board?

Quite possibly a lot, compared to someone whose passenger was their airline pilot friend with 20000 hours who helped them with every detail of the flight and made all the important decisions.

The only way to really prevent that is to have the requirement be "solo".

 

[midwestpa24]

Really the only reason the regulation was changed to allow an instructor on board was to help the puppy mills that were skipping single engine commercial and having students do their initial commercial in a multi. It made it very difficult to complete the required solo flying in a multi. The real intention is to have it done solo, learning think and manage the flight on your own, without a babysitter. It makes a lot of sense if the only cross-country time in your logbook is the minimum required for the PPL, this flying may expand your experience limit.

For those of us that went back years later to get a commercial, it was just a check box. I had over a hundred hours of cross-country time, had flown trips over 1,000nm, but still didn't have the boxes checked and was forced to go commit aviation.

 

[Lindberg]

I guess the reg is subject to being interpreted either way. But "consensus" is irrelevant when there is an official interpretation from the FAA guiding the process. This isn't the first time and it won't be the last time regulations were interpreted in a way that reflected policy.

Spot on.

I get a chuckle from the opinion stating that "the language . . . is clear." A long time ago, someone beat into my head that if you feel the need to say that, it's probably not true. Same with "clearly," and "obviously." All are best used facetiously.

I've also observed that the Dunning-Kruger effect applies to grammar and reading comprehension.

 

[MauleSkinner]

I get a chuckle from the opinion stating that "the language . . . is clear."

So how is 10 hours of one or 10 hours of the other readable as some combination thereof?

 

[midlifeflyer]

It makes a lot of sense if the only cross-country time in your logbook is the minimum required for the PPL, this flying may expand your experience limit.

Depends when you got the PPL. When I got mine, the student pilot long cross country was 300 NM total with a landing 100 NM from the original departure point. In 1997, shortened to student solo and moved it to the commercial requirements which, until then had a solo requirement with a 150 NM straight line solo. The need for a significant solo cross country is related to ICAO requirements

 

[cowman]

So how is 10 hours of one or 10 hours of the other readable as some combination thereof?

As someone who used to be a programmer I'll put it this way... since it doesn't say explicitly it all comes down to where you assume the brackets go ()[] . But I think my mistake here is reading a bit too critically and applying common sense. If with instructor is acceptable or solo is acceptable then why wouldn't one of each be fine as well?

I think the fact the FAA had to issue a letter clarifying it is proof enough that it's not that clear.

 

[MauleSkinner]

As someone who used to be a programmer I'll put it this way... since it doesn't say explicitly it all comes down to where you assume the brackets go ()[] . But I think my mistake here is reading a bit too critically and applying common sense. If with instructor is acceptable or solo is acceptable then why wouldn't one of each be fine as well?

I think the fact the FAA had to issue a letter clarifying it is proof enough that it's not that clear.

I think the fact that the FAA had to issue a letter clarifying it is proof that somebody wanted to read it differently than it was written.

Where would you put the brackets to read it as a combination of solo and PDPIC?

 

[GeorgeC]

I probably read the reg a dozen times myself and if nobody had told me I never would have interpreted it that way.

You are not alone.

 

[midlifeflyer]

As someone who used to be a programmer I'll put it this way... since it doesn't say explicitly it all comes down to where you assume the brackets go ()[] . But I think my mistake here is reading a bit too critically and applying common sense. If with instructor is acceptable or solo is acceptable then why wouldn't one of each be fine as well?

The problem with so-called "common sense," in addition to sense not being common and common not typically being sensible, is that it's biased. You want to divide it up so the FAA's refusal to do so defies your common sense.

I'm neutral on the subject. Maybe that's why I can easily see the "sensible" reason for all or nothing. This is a solo requirement. Period. The original purpose for the PDPIC substitute solo was for the commercial multi. It came about because insurance requirements pretty much made multi solo an impossibility. A few years later, the FAA expended it to other commercial ratings. The stated reason was that there were similar issues faced by commercial applicants in some higher performance aircraft.

So PDPIC is a need-based regulation. The reg obviously doesn't say you can use substitute solo "only if you need to;" it probably can't. But an all or nothing interpretation kinds of pushes people in that direction.

 

[cowman]

The problem with so-called "common sense," in addition to sense not being common and common not typically being sensible, is that it's biased. You want to divide it up so the FAA's refusal to do so defies your common sense.

I'm neutral on the subject. Maybe that's why I can easily see the "sensible" reason for all or nothing. This is a solo requirement. Period. The original purpose for the PDPIC substitute solo was for the commercial multi. It came about because insurance requirements pretty much made multi solo an impossibility. A few years later, the FAA expended it to other commercial ratings. The stated reason was that there were similar issues faced by commercial applicants in some higher performance aircraft.

So PDPIC is a need-based regulation. The reg obviously doesn't say you can use substitute solo "only if you need to;" it probably can't. But an all or nothing interpretation kinds of pushes people in that direction.

The thing is I started out months ago with being told "those need to be done solo or with an instructor". Then I read the reg on my own later... really had no specific intention of whether I'd do it solo or with an instructor. My only real bias here was I was looking for a way to make it a more interesting trip than just landing at some distant airport, doing a touch&go somewhere else and coming home. Either by having someone along to talk to or meeting up with someone/getting lunch/seeing or doing something interesting on the way- didn't really care.

I also had no knowledge of the history of all of this as far as the original intent or anything... allowing this 'with instructor' at all seemed kinda weird to me too.


To get even deeper in the weeds, when I talked to my CFI about this he also mentioned he was trying to get a clarification for another student who had done his flight across separate dates with an instructor. I always assumed it had to be on the same day, if it can be across several days I've already got something that meets the requirements in my logbook.

 

[MauleSkinner]

The thing is I started out months ago with being told "those need to be done solo or with an instructor".

Your other bias is that you went into it with a paraphrased version of the reg that didn’t reflect the actual requirements. That paraphrased version is what could have the brackets arranged to allow a combination, but the actual reg would not.

 

[midlifeflyer]

To get even deeper in the weeds, when I talked to my CFI about this he also mentioned he was trying to get a clarification for another student who had done his flight across separate dates with an instructor. I always assumed it had to be on the same day, if it can be across several days I've already got something that meets the requirements in my logbook.

My long commercial solo covered 3 days. As an aside, “with an instructor” depends on how it’s logged. It’s not “dual.” Yes, there are definitely weeds here.

 

[cowman]

Hmm so... I'll ask this one.
About a month after passing my PPL checkride I made the following flights all of which were solo and I have a clear enough memory of the whole time to be confident of that.

8/9/2014 KEAU(my then home base) -> KPPQ which was over 300nm. I hung out/stayed with friends for several days
8/15/2014 KPPQ -> KIGQ met my wife who drove in for her sister's wedding and spent a few days in the area for that
8/18/2014 KIGQ -> C35 wife's friend was driving me nuts so I attempted to go home knowing I'd probably have to divert for weather which I did. There was a Hotel and a Pizza Hut within walking distance of the field and I ate a whole pizza by myself in a hotel room that night.
8/19/2014 C35 -> KEAU finally returned home.

If all that was part of one trip on one day there's no question it would meet the requirements. Can I still count it as one trip with it being over the course of 10 days and therefore satisfy the CPL experience requirement?

 

[MauleSkinner]

Hmm so... I'll ask this one.
About a month after passing my PPL checkride I made the following flights all of which were solo and I have a clear enough memory of the whole time to be confident of that.

8/9/2014 KEAU(my then home base) -> KPPQ which was over 300nm. I hung out/stayed with friends for several days
8/15/2014 KPPQ -> KIGQ met my wife who drove in for her sister's wedding and spent a few days in the area for that
8/18/2014 KIGQ -> C35 wife's friend was driving me nuts so I attempted to go home knowing I'd probably have to divert for weather which I did. There was a Hotel and a Pizza Hut within walking distance of the field and I ate a whole pizza by myself in a hotel room that night.
8/19/2014 C35 -> KEAU finally returned home.

If all that was part of one trip on one day there's no question it would meet the requirements. Can I still count it as one trip with it being over the course of 10 days and therefore satisfy the CPL experience requirement?

The only issue I would have is ensuring that your logbook shows it as “solo”.

While I would agree that it would qualify otherwise, it would probably be a good idea to call the examiner you’re planning to use and make sure he’s on the same page.

 

[midlifeflyer]

I agree on both points,

The only issue I would have is ensuring that your logbook shows it as “solo”.

As I mentions, I knew a pilot who was turned away because the logbook entry did not indicate it was solo.

While I would agree that it would qualify otherwise, it would probably be a good idea to call the examiner you’re planning to use and make sure he’s on the same page.

The FAA’s position on this comes down to the old, orphaned Part 61 FAQ statement, "The 'original point of departure' for the purpose of a cross country does not change with a new day or delay." Or the statement in a later Chief Counsel letter that, “the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted.”

That’s pretty open ended, but I think there are limits. I recall a discussion of the subject in which a pilot quipped, “I consider all of my logged x,000 hours to be one cross country flight.” If that sounds, silly, you got the picture. I can see some questioning of whether even the pilot involved thinks of three trips over the course of more than a week for different purposes as a unit.

So, yeah, i would definitely review a multi-day flight with my DPE ahead if time.

 

[Initial Fix]

8/9/2014 KEAU(my then home base) -> KPPQ which was over 300nm. I hung out/stayed with friends for several days
8/15/2014 KPPQ -> KIGQ met my wife who drove in for her sister's wedding and spent a few days in the area for that
8/18/2014 KIGQ -> C35 wife's friend was driving me nuts so I attempted to go home knowing I'd probably have to divert for weather which I did. There was a Hotel and a Pizza Hut within walking distance of the field and I ate a whole pizza by myself in a hotel room that night.
8/19/2014 C35 -> KEAU finally returned home.

Yes. Make sure it’s logged solo. I used something similar over a multi day trip (solo)

 

[nauga]

Or the statement in a later Chief Counsel letter that, “the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted.”

Given the FAA's insistence on rigid adherence to their pubs and processes, combined with a tendency to bury procedural nuances outside the procedures, the emphasized word in your quote is unfortunate. This was in the Chief Counsel letter?

Nauga,
who tells people where he's going

 

[midlifeflyer]

Given the FAA's insistence on rigid adherence to their pubs and processes, combined with a tendency to bury procedural nuances outside the procedures, the emphasized word in your quote is unfortunate. This was in the Chief Counsel letter?

Nauga,
who tells people where he's going

Yes, that's a quote from this Chief Counsel letter. There were two which talk about it that year. One uses the term "discreet." The other doesn't. I'm not sure if there's really a difference.

I think it creates a subjective standard with objective limits rather than something black and white. The "objective limits" are pretty much what a 1st year law student referred to a "The BS Rule:" You can quote all the rules, regulations, and cases you want, but at some point the judge says, 'BS! You're screwed!'"

Edited to remove "objective." The limits really are subjective too.

 

[sarangan]

Independence and/or self-reliance.

My comment wasn’t about the rule itself - that part is clear. “Solo” means sole occupant. What I was addressing is the rationale behind that rule. Carrying passengers is a privilege you earn only after passing a checkride, demonstrating to an examiner that you possess the maturity and independence to fly with others on board. That’s why it seems counterintuitive to argue that a passenger could be, say, your uncle who’s an ATP making flight decisions for you - meaning you’d still have to prove your independence and self-reliance all over again. The idea of a buddy ATP tagging along and effectively taking over the flight doesn’t seem like a strong enough justification to write a rule into the FAR - though I’m not saying it couldn’t happen. There must be another simpler reason. My speculation is that the original intent might have been to treat the commercial and private paths as alternatives rather than sequential steps. If the commercial certificate were your first checkride, then requiring solo time, cross-country time, and similar elements would make much more sense - and that framing makes several of the requirements read more logically, at least to me.

 

[midlifeflyer]

What I was addressing is the rationale behind that rule.

Here's what the FAA said when adding it (the 300 NM solo was previously a private pilot requirement):

the FAA has added language to the existing solo cross-country requirements to ensure pilots meet minimum standards specified under Annex 1 to the Convention on International Civil Aviation. The additional language requires that an applicant for a commercial pilot certificate complete a solo cross-country flight of a total of not less than 300 nautical miles. The existing rule states that a cross-country flight must have landings at a minimum of three points, one of which is at least a straight line distance of 250 nautical miles from the original point of departure. All commercial pilot applicants with a private pilot certificate currently meet the total 300-nautical-mile requirement; however, private pilots certificated after the effective date of this rule will not, due to the decrease in the solo cross-country flight requirements for private pilots set forth in this rule. The FAA wants to ensure that the requirements under Annex 1 to the Convention on International Civil Aviation are specifically met, to facilitate the acceptance of U.S. Pilot Certificates internationally.​

 

[sarangan]

Here's what the FAA said when adding it (the 300 NM solo was previously a private pilot requirement):

the FAA has added language to the existing solo cross-country requirements to ensure pilots meet minimum standards specified under Annex 1 to the Convention on International Civil Aviation. The additional language requires that an applicant for a commercial pilot certificate complete a solo cross-country flight of a total of not less than 300 nautical miles. The existing rule states that a cross-country flight must have landings at a minimum of three points, one of which is at least a straight line distance of 250 nautical miles from the original point of departure. All commercial pilot applicants with a private pilot certificate currently meet the total 300-nautical-mile requirement; however, private pilots certificated after the effective date of this rule will not, due to the decrease in the solo cross-country flight requirements for private pilots set forth in this rule. The FAA wants to ensure that the requirements under Annex 1 to the Convention on International Civil Aviation are specifically met, to facilitate the acceptance of U.S. Pilot Certificates internationally.​

Thanks for that. I hadn't considered ICAO as factor in this.

 

[MauleSkinner]

The idea of a buddy ATP tagging along and effectively taking over the flight doesn’t seem like a strong enough justification to write a rule into the FAR -

Agreed. But as a practical matter, at this level an examiner can tell the difference between a pilot who has 7 hours total solo time with most of his PIC logged concurrently with dual received and a pilot who has been out flying by himself and acting as PIC. The latter is usually better at planning and executing a flight and identifying risks and making decisions along the way.

 

[flyingron]

That appears to be the consensus. I probably read the reg a dozen times myself and if nobody had told me I never would have interpreted it that way.

Am I just being obtuse or is there an FAA way of reading these things that I've just never quite gotten 'with' before?

Here's the reg:

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

You have to look at where the conjunction or falls. It's either "ten hours of solo flight time" OR "ten hours of flight time performing duties". If they wanted it to allow a mix it would have been "Ten hours of solo flight time in a single engine airplane or performing the duties..."

 

[iamtheari]

I’m just glad they haven’t interpreted it as requiring both of those items to be done in the same “an airplane.” That would have undermined the J-3 Cub road trip I did for the long cross country because it’s not legal for night.

 

[RussR]

Yes, that's a quote from this Chief Counsel letter. There were two which talk about it that year. One uses the term "discreet." The other doesn't. I'm not sure if there's really a difference.

And it really uses the word "discreet", meaning "circumspect" instead of "discrete", meaning "separate". Multiple times.

I'm sure there a joke there.

 

[midlifeflyer]

And it really uses the word "discreet", meaning "circumspect" instead of "discrete", meaning "separate". Multiple times.

I'm sure there a joke there.

Or just a bad speller and proofreader.

 

[nauga]

Or just a bad speller and proofreader.

At least it wasn't in anything important, or change the meaning from what was intended.

Nauga,
who was apparently held to a higher standard

 

[flyingcheesehead]

The somewhat puzzling requirement to log 10 hours of solo flight time - completely alone in the airplane - probably dates back to a time when pilots took the commercial checkride directly from a student pilot certificate.

I don't think there has ever been a time where you could go student -> commercial. I think you're referring to when it was far more common to go directly from private to commercial, skipping the instrument.

But, sounds like it was really just an ICAO thing.

And it really uses the word "discreet", meaning "circumspect" instead of "discrete", meaning "separate". Multiple times.

I'm sure there a joke there.

The joke is that this comes from the same agency that gave us a Glider Flying Handbook that had an entire section on Wench Launching.

 

[midlifeflyer]

And it really uses the word "discreet", meaning "circumspect" instead of "discrete", meaning "separate". Multiple times.

I'm sure there a joke there.

The bigger potential problem in the Chief Counsel letter is this part.

“the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted.”​

That doesn’t sound like, “review your logbook for your cross countries after getting the private, combine a few sequential ones you treated as separate 4 years ago, and call it one.”

That doesn’t mean you can’t. But it’s a reason to discuss it with the DPE in advance. That may be especially true these days when DPEs are apparently seeing a good number of pilots, particularly for the commercial, who don’t meet requirements.

 

[bonefishpete]

So an aspiring ppl should explicitly mark log book “solo” for cross country when no one else is aboard?