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7 Answers

Commercial experience requirements (61.129) – combine 300 nm, night VFR, TAA?

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Commercial Pilot

Hello:

I recently completed my 100 nm/2 hr day and night XCs. CFI and I flew out during the day and returned at night. We also flew TAA (G1000, with auto pilot) so this took care of around 5 hours of TAA requirement as well.

I need to get 5 hours of "night VFR" and remaining 5 hours of TAA. I also need to complete the 300 nm XC. Can I combine all 3, by flying with CFI at night?

(I do have solo night VFR hours from earlier in life, but cannot combine solo and with-CFI, so keeping it all with-CFI, and not using any earlier night VFR hours)

Thanks!


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7 Answers



  1. Mark Kolber on Jul 05, 2023

    You can combine the night because the night stuff for the commercial is a general experience requirement. But the remaining 5 hours of TAA is a “training” requirement so it cannot be combined with the solo requirement because the solo substitute – performing the duties with a CFI on board – is not a training event, even though you are doing it with a CFI.

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  2. PVS on Jul 05, 2023

    Is the CFI a “solo substitute”? Asking based on the fragment within *** below

    “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) ***”

    The TAA requirement also references § 61.127(b)(1) in its preamble, but additionally also uses the word ‘training’, while the above para says “duties of pilot in command” and no mention of “training”

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  3. Jeff Baum on Jul 05, 2023

    The portion of regulation 61.129(a)(4) which references “…or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board,” is an either/or situation. The “…performing the duties of PIC…” means that while a CFI may be onboard, they may not instruct, teach nor assist. They are prohibited to act as an “Authorized Instructor”. You are demonstrating that you are able to operate the airplane as a solo PIC. This is usually done when there is an insurance requirement which the (ahem) Learner Pilot does not meet the insurance requirements for solo flight.

    The kicker with this reg is that you must choose to either make all of the Solo requirements as SOLO, or all of the solo requirements must be conducted under the provision of 61.129(a)(4). You may NOT combine them. If you choose to use that provision you need to reference that you used the reg in the comments for the DPE.

    61.129(a)(3)(ii) allows you combine aircraft to gain the 10 hours of training (CFI required) “…10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, OR ANY COMBINATION THEREOF.” So you could get 5 hours of training in a TAA and 5 hours in a complex to meet the requirement, but a CFI must be onboard and acting as an “Authorized Instructor”.

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  4. PVS on Jul 05, 2023

    Thanks for the detailed answer Jeff. What do you say about a 300 nm XC, done in night VFR, in G1000/TAA, with a CFI (but not instructing) and crediting this single flight towards 3 reqs: long XC, TAA hours and night VFR hours?

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  5. Jeff Baum on Jul 05, 2023

    The problem with that scenario is that you must complete the 10 hours of “solo” either as Solo or as Performing the Duties of PIC with a CFI onboard but not instructing. You may not combine the two. I would have to reject the 300nm “Solo” XC unless ALL of the “solo” time was completed under the 61.129(a)(4) provision. And, yes, I have had to reject an applicant for that exact situation.

    The TAA time would work as that is required TRAINING time (requires a CFI). The “solo” night and 300nm “solo” XC would not unless ALL “solo” time was accomplished under the 61.129(a)(4) provision.

    It’s not that the DPE wants to reject the time. It’s that the regulation requires that the “solo” must meet one or the other situation. We’re not allowed to permit a combination. I’ve had to reject a couple of commercial applicant for just this situation. A DPE failing to do so would risk loosing their DPE status, and the applicant(s) might face a FAA retest. Not good for anyone.

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  6. Kris Kortokrax on Jul 06, 2023

    An applicant for a Commercial Pilot certificate needs 250 hours of flight time. Why do we need to try and cram as many training requirements into one flight? What do we do for the remaining hours? Joyride?

    Just an observation.

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  7. PVS on Jul 06, 2023

    @Kris.- already have 250 hours, and trying to save $ on meeting reqs. Also, in my part of the country aircraft (and instructors) are in great demand during the summer, and finding open time slots is hard.

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