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How is

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Commercial Pilot, FAA Regulations, Flight Instructor, General Aviation

If a private pilot is seeking a commercial license for with AMEL under FAR 61.129 (b) 4, how does the 10 hours “solo” requirement get logged?  No insurance company will allow this solo time, so the caveat “PIC performing PIC duties with instructor present” is used in leu of solo.  This is problematic: who is actually PIC?  What endorsement must the CFI/MEI make before this time is logged?  Does the CFI sign each flight still?  How about filling out the 8710 form on this?

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1 Answers



  1. Mark Kolber on Dec 07, 2020

    • The instructor is the Part 1 PIC – has to be. The student is not rated and is not solo.
    • There is no endorsement before the flight because there is no endorsement which applies. If the student actually flew solo – only person on board – they would need a 61.31 solo endorsement shown in A.72 in AC 60-61H.
    • The student logs the MEL time and the total time but not solo (it isn’t), dual (it is not an instructional flight), or PIC (not solo or rated).
    • The logbook should reflect that the time was logged under 61.129(b)(4). AFAIK. the FAA does not have a specific form for this but based on prior history, I would recommend adding “Performing the duties of PIC with an instructor on board per 61.129(b)(4)” to whatever other remarks you might make. As the CFI involved, I would endorse the entry. If you want to have a column for the time entry, use a blank one but I don’t think it is necessary.

    Most of this is covered in the FAA Chief Counsel’s 2104 Kuhn letter, https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2014/Kuhn%20-%20(2014)%20Legal%20Interpretation.pdf

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