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§61.129 – CPL Aeronautical experience – which hours count?

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Commercial Pilot, FAA Regulations

I am working to finish up my commercial certificate (SEL) and have some questions about §61.129

After obtaining the PPL and before starting the CPL training I did the following training / flights which might count towards the requirements of  §61.129:

  1. A couple of hours of night VFR training with more than 10 landings (with and without CFI; airport with operating tower) as described in §61.129 4(ii)

Question: Do this hours count toward  the requirements §61.179 4(ii)?

 

  1. I also did some hours of training in a complex aircraft to obtain the complex endorsement (with CFI)

Question: Do this hours count toward the requirements §61.179 3(ii)?

 

  1. I did a solo cross country flight which fulfills the requirements of §61.129 4(i) before I started the commercial training.

Question: Does this cross country flight count for §61.129 4(i)?

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2 Answers



  1. Mark Kolber on Jul 23, 2019

    61.129(4) lists solo or “substitute solo” (“performing the duties of pilot in command with an authorized instructor on board”).

    The important things to understand about substitute solo are (1) it is not training received and is not logged as dual, and (2) you can’t mix and match solo and substitute solo. IOW, all 61.129(4) solo tasks must be one of the other Recheck your logbook with that in mind. It would be very unusual to have substitute solo unless it was in the course of actively pursuing the commercial certificate, so chances are your solo night towered takeoff and landing hours count toward the requirement so long as properly documented.

    Without actually looking at you logbook, the complex training hours count, as does the solo cross country (again assuming no subdue solo issues).

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  2. gerhardm on Jul 24, 2019

    Mark, thanks a lot for you explaination! Now it is clear for me! Again thanks!

    Gerhard

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