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Commercial Aeronautical Experience: 61.129(a)

Asked by: 4413 views Commercial Pilot, FAA Regulations

Hi, I'm working to finish up my commercial certificate and have a specific question about 61.129(a)...

  • 61.129(a)(4)(ii)  requires "5 hours in night VFR conditions with 10 takeoffs and 10 landings [...]"
  • 61.129(a)(3)(iv) requires "one 2-hour cross country flight in a single engine airplane in nighttime conditions [...]"

If, on the 2-hour cross country flight in nighttime conditions, I am current in the airplane and performing the duties of PIC (while also receiving dual), will those 2 hours count towards the required "5 hours in night VFR conditions"? Thanks - really appreciate any insight! I know there are a few legal opinions around the edges but none seem to directly address my question.

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2 Answers



  1. Nascr1Arrival on Jan 28, 2016

    Absolutely yes. If you’re headed to an airport that is 100nm away most complex airplanes will be there in under an hour, so you might as well do pattern work. You just have to make sure the airport you go to is towered. If you really wanted to fly all night, I don’t see why you couldn’t combine the 300nm flight, the 100nm straight line distance flight, and the pattern work at a towered airport. I’m pretty sure I did that during my commercial training.

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  2. Kris Kortokrax on Jan 28, 2016

    No you cannot count the 2 hour X-C toward the 5 hour of night.

    61.129(a)(3) outlines dual training requirements. The 2 hour night cross country must be a training flight (dual given by an authorized instructor).

    The 5 hours of night in 61.129(a)(4) falls under time acquired while either solo or “performing the duties of a PIC with an authorized instructor on board”. It does not require you to perform this in a complex airplane. One would think that you should be able to rent or purchase and be insurable in a fixed gear single engine airplane and fly this solo.

    The time spent with an authorized instructor on board cannot be logged as dual time (there is a legal interpretation to this effect). The instructor is there ostensibly for insurance reasons (more for multi-engine and helicopter students).

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