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3 Answers

61.129 Duties of PIC

Asked by: 1571 views Commercial Pilot, FAA Regulations, Helicopter

I have a commercial helicopter guy wanting to get his fixed wing commercial rating. He doesn’t want to get his instrument rating at this time. He will need 50 hours pic and 20 hours dual. 
He could build that 50 pic by himself and save money. In regards to the 10 hours of solo time, am I able to do those as duties of PIC and then he builds the remaining 40 hours solo? Wasn’t sure if you could mix and match. My understanding is that the or in this reg only applies to those specific 10 hours. Thanks everyone! 

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3 Answers



  1. Jeff Baum on Jul 11, 2024

    I’m not sure exactly why you are asking about the 10 hours “performing the duties of PIC”. This is usually done when someone has PIC time in a different class yet needs the 10 hours solo and the insurance or owner requires more experience than the student currently has to fly solo. Most typically this is seen when there is a multiengine or a complex aircraft and the insurance policy will not cover solo operations.

    When you are flying as a CFI with someone who is using that “performing the duties…” provision, you may not instruct nor help. They are to perform ALL of the duties of a PIC. You are there simply to meet whatever requirement prevents the student from flying actual solo.

    Since he needs a full 50 hours PIC, why not simply solo him and allow him to complete the “ten hours solo” as part of the 50? I’m going in the opposite direction, adding Commercial Helicopter, needing 35 PIC in helicopters and 10 hours solo in helis. My CFI simply endorsed me to operate the helicopter solo and 35 hours of solo(PIC) later I’m just waiting for my add-on checkride.

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  2. Mark Kolber on Jul 16, 2024

    I’m not sure exactly what you are asking so I’m guessing. There appear to be two questions:

    1. All the required solo hours must be either solo or “performing the duties of PIC” with an instructor. No mix and match. Using the commercial single as an example, if you want to do the 5 night hours with an instructor on board, you need to do the 300 NM solo cross country with an instructor also. See the 2016 Grannis Letter: https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2016/Grannis_2016_Legal_Interpretation.pdf

    2. “Performing the duties of PIC” is not logged or countable as dual/training received. See the 2104 Kuhn Letter: https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2014/Kuhn_2014_Legal_Interpretation.pdf

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  3. LTCTerry on Aug 06, 2024

    The way to save money is to do Private ASEL add on first. Then everything else is PIC whether dual or solo.

    ASEL Commercial is pretty useless w/o an instrument rating. Presuming your client has RW Instrument already, Private-first then Instrument training all counts towards the 50 PIC. Add on Instrument is 15 hours. That’s not even 1/3 of the 50.

    Private-first makes all the Commercial maneuvers PIC too…

    Then for the “10 hours” of solo *or* PDPIC just send the guy off solo. Builds experience, competence, and confidence.

    Commercial-to-Commercial is possible but far more expensive.

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