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Aeronautical Experience for Commercial.

Asked by: 1312 views Commercial Pilot

Riddle me this... Would my night VFR take off's & landings time logged with an instructor as a student pilot count toward the  61.129 a ii ( Five hours in night VFR...) for my commercial rating? ( I'm being told only time that can be counted toward commercial rating is that which has been logged after obtaining private pilot certificate). THANK YOU!

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3 Answers



  1. Jeff Baum on Apr 23, 2022

    Riddle me this… Is flight time with a CFI onboard considered “solo”?

    61.129(a)(4)(ii) requires 5 hours of SOLO night experience to include 10 takeoffs and 10 landings at an airport with an operating control tower. That means by your self. No one else in the airplane.

    So, no, your night experience acquired during your private pilot training would not be applicable.

    And since I’ve run into this with a few Commercial Applicants, the requirement is for both 10 takeoffs and 10 landings, not just 10 landings.

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  2. Aero on Apr 23, 2022

    So I guess my confusion stems from the actual reg
    and the text that specifically states “with and authorized instructor on board”

    (Quoted here):
    (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.

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  3. Jeff Baum on Apr 23, 2022

    A lot of folks miss the “or” / “and” in regulations. In this case there is an “or”.

    You quote 61.129(a)(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…”

    You may fly the required 10 hours solo.

    OR

    You may have a CFI (authorized instructor) onboard while you “preform the duties as pilot in command”. This is usually due to insurance having a minimum hour requirement which the student doesn’t meet. You are required to be able to perform as PIC whether the CFI is there or not. A CFI may be onboard but may not provide any instruction nor assistance, so it is not flight instruction. And this would not be part of the required 20 hours of flight instruction. It needs to be logged noting that this alternative was used in leu of the required solo time.

    While you were flying the 3+ hours of night Instruction towards your Private certificate with your CFI, you were not “performing the duties as PIC”, you were receiving dual instruction. This is why your previous night time as a Student Pilot will not count towards the 10 hour requirement.

    By the way, this is an “either/or” situation. You may have a CFI onboard, while you perform the duties as PIC for all 10 hours (and it must be a CFI) – OR – you may fly these requirement 10 hours solo. You cannot mix them.

    Hope this helps to explain the reg.

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