FAR 61.129

FAR 61.129

(3) (i) Ten hours of instrument training…;

(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 … with an authorized instructor on board… that include—

(i) One cross-country flight of not less than 300 nautical miles total distance, … and

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings… at an airport with an operating control tower.

I’m restarting commercial ASEL training after a long break. I went for the checkride several years ago, but didn’t take it. 61.129 didn’t allow for “performing the duties of pilot in command,” and I did not have any solo night landings* – every night flight as PIC had family or friends onboard. I deployed to Iraq shortly afterwards with the Army Reserve and didn’t finish.

Now, I’m restarting. I have a couple of questions as I review logbooks and FARs to study.

1. FAR 61.129 (3) (i) – I’ve always assumed being instrument rated covered this. Somewhere recently I saw the claim that these ten hours had to be part of a commercial training program. That makes no sense. I can see ten hours for someone who’s not IFR rated. Guidance?

2. FAR 61.129 (4) says ten hours solo *OR* ten hours performing the duties of PIC… Am I correct in ready “or” as “all solo” or “all performing” rather than some combination of the two?

Minor dilemma and I’d like the group’s advice:

I have done the 300-mile cross country solo – 4.9 hours. I can meet the meet the five night hours and six of the ten landings with existing dual flights.

So, for the purposes of 61.129 (4) I have essentially half of each of the “or” options.

Five solo night hours would be cheaper than flying the long cross country dual. I could fly the long cross country with a CFII and get some additional benefit out of it.

I don’t “need” cross country time for the ticket – I have almost 300 hours XC of 600+ total airplane hours. Money isn’t the deciding factor. Maybe not even a factor at all.

What do you suggest? Thanks!

[Edit: A quick search here indicated that "dual" isn't going to be considered the same as "performing the duties of PIC," so I think part of my own question is answered. I just noticed you can edit posts; I didn't think that was the case.]

*The school’s precheckride checklist said “10 PIC landings” rather than “10 solo landings.” However, it was ultimately on me to have properly read the FARs, not just rely on someone else. Lesson learned. Starting over nine years later!

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