Welcome Guest. Sign in or Signup

1 Answers

How is

Asked by: 2306 views ,
Commercial Pilot, FAA Regulations, Flight Instructor, General Aviation

If a private pilot is seeking a commercial license for with AMEL under FAR 61.129 (b) 4, how does the 10 hours “solo” requirement get logged?  No insurance company will allow this solo time, so the caveat “PIC performing PIC duties with instructor present” is used in leu of solo.  This is problematic: who is actually PIC?  What endorsement must the CFI/MEI make before this time is logged?  Does the CFI sign each flight still?  How about filling out the 8710 form on this?

Ace Any FAA Written Test!
Actual FAA Questions / Free Lifetime Updates
The best explanations in the business
Fast, efficient study.
Pass Your Checkride With Confidence!
FAA Practical Test prep that reflects actual checkrides.
Any checkride: Airplane, Helicopter, Glider, etc.
Written and maintained by actual pilot examiners and master CFIs.
The World's Most Trusted eLogbook
Be Organized, Current, Professional, and Safe.
Highly customizable - for student pilots through pros.
Free Transition Service for users of other eLogs.
Our sincere thanks to pilots such as yourself who support AskACFI while helping themselves by using the awesome PC, Mac, iPhone/iPad, and Android aviation apps of our sponsors.

1 Answers



  1. Mark Kolber on Dec 07, 2020

    • The instructor is the Part 1 PIC – has to be. The student is not rated and is not solo.
    • There is no endorsement before the flight because there is no endorsement which applies. If the student actually flew solo – only person on board – they would need a 61.31 solo endorsement shown in A.72 in AC 60-61H.
    • The student logs the MEL time and the total time but not solo (it isn’t), dual (it is not an instructional flight), or PIC (not solo or rated).
    • The logbook should reflect that the time was logged under 61.129(b)(4). AFAIK. the FAA does not have a specific form for this but based on prior history, I would recommend adding “Performing the duties of PIC with an instructor on board per 61.129(b)(4)” to whatever other remarks you might make. As the CFI involved, I would endorse the entry. If you want to have a column for the time entry, use a blank one but I don’t think it is necessary.

    Most of this is covered in the FAA Chief Counsel’s 2104 Kuhn letter, https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2014/Kuhn%20-%20(2014)%20Legal%20Interpretation.pdf

    +2 Votes Thumb up 2 Votes Thumb down 0 Votes


The following terms have been auto-detected the question above and any answers or discussion provided. Click on a term to see its definition from the Dauntless Aviation JargonBuster Glossary.

Answer Question

Our sincere thanks to all who contribute constructively to this forum in answering flight training questions. If you are a flight instructor or represent a flight school / FBO offering flight instruction, you are welcome to include links to your site and related contact information as it pertains to offering local flight instruction in a specific geographic area. Additionally, direct links to FAA and related official government sources of information are welcome. However we thank you for your understanding that links to other sites or text that may be construed as explicit or implicit advertising of other business, sites, or goods/services are not permitted even if such links nominally are relevant to the question asked.