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61.129 Clarification

Asked by: 3019 views Commercial Pilot, FAA Regulations

Specifically about 61.129(a)(3)(i, iii and iv)...

On i: I've read the Hartzell letter and the "documenting" portion makes me think that if I did my instrument before thinking about commercial and it doesn't note the FAR parts in the logbook entry, I should plan on doing 10 hours of foggle work. Or does the fact that I have entries that state some of the items i.e. Partial Panel, Slow flight, Stalls, etc... under the hood count? It never hurts to do more training, just trying to plan my work.

On iii and iv: I get they are dual flights, I get that they can't be pulled up from other license/rating work, but what's the interpretation around the nature of the flight? Do they have to be VFR or is it acceptable to do the night XC under the foggles?  61.127(b)(1) notes Navigation as an item, but that's all I see.

I don't see any language specifying and wanted to see the consensus is. Thanks in advance!

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1 Answers



  1. Robert Jankowski on Mar 30, 2016

    To your first question, if the entries are logged as meeting the required training items then you shouldn’t have an issue. My opinion is that if the examiner sees that you have an instrument rating, they don’t dig too deeply into verifying the 61.129(a)(3)(i). I have heard of one person who had the FAA along for her commercial or multi-add on check ride and they went thru her logbook with a fine tooth comb and issued her a 709 ride for her instrument rating but told the examiner to continue as technically she held a valid certificate with the instrument rating. If it’s all properly documented, this problem should never pop up no matter who is looking at your logbook.

    To your second question, there is no verbiage to require that they be done in VMC (I believe an older version changed around 2009 stated that they must be done in VFR conditions). It would stand to reason that if you were properly rated, current and the aircraft was legal, you could do these flights under IFR or under foggles while logging simulated instrument time so long as your instructor is acting as your safety pilot.

    Good luck! The commercial maneuvers are lots of fun!

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