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Performing the duties of PIC

Asked by: 6267 views Commercial Pilot, FAA Regulations, Flight Instructor

Here is a question of research for instructors:

When the commercial pilot requirements changed (2010, 2011?) and inserted this phrase to the solo requirements:

“…performing the duties of pilot in command in a single engine airplane with an authorized instructor on board”

What does this mean?  What is allowed to be crossed over?  ie:  Can the 2 hours from the 100 NM  Night Dual cross country count towards the 5 hours of solo (or “…performing the duties of pilot in command in a single engine airplane with an authorized instructor on board”)?  Same question about the 10 take off and landings at a controlled tower.

What I am also looking for is any documentation, legal ruling, or AC speaking to this?

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1 Answers



  1. Mark Kolber on Nov 12, 2013

    Nothing can be “crossed over.” “Performing the duties” is a substitution for solo flight that, as I recall, originally appeared in the 1997 revision to Part 61 as a way to solve the problem of commercial multi students being unable to solo due to insurance restrictions.

    It was later extended in the October 2009 Part 61 revision to other certificates and ratings.

    In either case, the idea is for the student to either act as though he’s solo, although being supervised by the CFI, or to act as though he is PIC of a multi-pilot crew, with the CFI as crew.

    Your best bet for a reference is going to be to go to the government’s Federal Register site and pull up the October 2009 Final Rule. There are only a few legal interpretations on the subject. I don’t have them handy but I din’t think they address your question directly.

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