Night Time qualification for commercial pilot
- Thread starter gsfinn
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MauleSkinner
Touchdown! Greaser!
Might help to start with the regulatory reference you’re looking at.
A commercial applicant should not be suffering from regaphobia or regulitis. Are you having trouble understanding this?
(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 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) that include--
***
(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.
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Ari
Is English your first language? If it is, then you probably just need to slow down. If not, then you still need to slow down but you likely have more recent and more formal instruction on how to parse, and craft, a sentence. The way you wrote this post makes it seem like you are blasting through words and clauses without considering punctuation or sentence structure. That is a surefire strategy to miss the meaning of even the simplest regulations, such as the one you're asking about.
Pinecone
En-Route
You also have to take into account the indentation when reading regulations.
So you need 10 hours of solo time. As part of that, you need at least 5 hours night. Since this is an indent from the 10 hour requirement, it is part of that, so yes, you need 5 hours night solo time.
So you need 10 hours of solo time. As part of that, you need at least 5 hours night. Since this is an indent from the 10 hour requirement, it is part of that, so yes, you need 5 hours night solo time.
455 Bravo Uniform
Final Approach
I think what the guys meant to say is “Welcome to POA”! Right guys? 
I sometimes wonder whether they still teach outlining in 5th grade.
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Llewtrah
OK - I'll bite (and risk the usual PoA smackdown).
I suspect the OP may be confused by the "OR" in the reg cited above, which I don't see anyone commenting on (and which I've emphasized). Personally, I can understand the confusion: need the night time be truly solo?
Plus, it seems to clearly be an "either-or": either the 10 hours is solo OR it's with an instructor; it's not worded as "Ten hours, either as solo flight time and/or PIC with an authorized instructor on board..." or similar. So, taken literally, it would seem the night time (and x-c time) could not be a mix of solo plus PIC-with-instructor; it must be all of one or the other as a subset of 10 hours which is one or the other.
So - can someone address this by including a clarification of the "or" statement, regardless of the OP's punctuation or even their original intent?
MauleSkinner
Touchdown! Greaser!
Take it literally.
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Llewtrah
Okayyyy…
It literally says you need to do these 10 hours either solo OR as PIC with an instructor on board. As structured, it doesn’t permit a mix. And, more to what I think is the OP’s question, this section can be satisfied without truly doing solo - for anything.
So, if you do the x-c part (for (4)i) solo, any time spent as PIC with an instructor on board for night doesn’t count for the 10 hours and vice versa. One needs to plan on satisfying (4) by either doing 10 hours solo or by meeting the two indented requirements (x-c and night) as PIC with an instructor on board - and not mixing. No actual solo is ever needed.
That seems to be taking it literally. That said, I’m not sure that’s how the average DPE would look at it but I’m not sure; I did my stuff solo for my Commercial, so it was moot for me.
MauleSkinner
Touchdown! Greaser!
Correct.
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Llewtrah
Then, instead of people rolling in with criticisms of punctuation and snide remarks about indents, wouldn’t it have been more helpful to say “yeah, it may not make a lot of sense but you can actually meet the requirements by never actually going solo so long as you have an instructor riding along for the 10 hours in (4)”?
MauleSkinner
Touchdown! Greaser!
If that was what he had asked, yes. But that wasn’t what he asked.
Not only your take literally, but also the FAA Chief Counsel's.
That may well have been @gsfinn's confusion. And an understandable one if it is asked. There are a number of nuances there. One is what you mentioned: all or nothing in terms of true "solo" vs "CFI on board" (which many abbreviate as "PDPIC" - "performing duties of PIC"). The other is that if the PDPIC option is being used, it is not counted as training received. So, for example, one may not combine the "solo" cross country with the two required dual ones.
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3G
All of the hours for 14 CFR 61.129 (4) (i) AND (ii) must be accomplished as either:
1. Solo. No other person(s) authorized in/on/around/being towed by/stowed away in the flying machine.
-or-
2. PDPIC. PDPIC means the applicant in the left seat performing PIC with a dead, dumb, and mute CFI along for the ride billing the applicant for the time spent being dead, dumb, and mute . No additional person(s) authorized in/on/around/being towed by/stowed away in the flying machine.
Lindberg
Final Approach
Is that even the FAR the OP is asking about? I didn't see where it says 5 hours of total time.
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Ari
The OP seemed to be reading 61.129(a)(4)(ii) ("5 hours in night VFR conditions") in a vacuum, rather than by reference to its context in 61.129(a)(4) ("Ten hours of solo flight time ... that include").
MauleSkinner
Touchdown! Greaser!
I don’t believe “total time” exists in regulation. The OP is mixing and matching regulatory and non regulatory terms, further confusing himself.
That's the way most think of it, and pretty much the way it is done. But there have been a few indications that it can be a bit more. If we go back to the original - designed for the commercial multi where insurance won't permit solo, the CFI is the pilot in command. Even the main Chief Counsel opinion on the subject (there are others) talks at one point in terms of the candidate being "under the supervision of another pilot - in this case an authorized flight instructor." I even recall some very early FAA discussion of how it could be treated as a 2-pilot crew training exercise, although I haven't heard of people treating it that way.
wow what a idiot response!
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GeorgeC
There are 10 kinds of people: those who can parse a sentence into a tree, and those who cannot.
MauleSkinner
Touchdown! Greaser!
Ask an idiot question, get an idiot response.
There's more than one issue there. Maybe 10
Parsing can also be a problem but I'm just looking at the basic Point-Subpoint indented outlining concept. Since the regs are built that way, we see a lot of questions like that. Does this have to be solo? is one of the common ones. Another is "does this have to be done with a CFI?" when the task is a subcategory of "training."
Personally, I think the real issue is that we tend to teach paraphrases of regulations rather than reading regulations. The buring red fruit mnemonic is the one I rant about the most, but If I ask a question like this (it's from a IPC quiz I'm working on)
You are planning a cross country flight from TTA to Ocean Isle (60J). Forecasts indicate conditions at Ocean Isle beginning two hours before and continuing for 90 minutes after your arrival time will be better than 10 SM visibility with a 3,000' scattered to broken ceiling. Are you required to file an alternate?
I hope it's not a majority, but I do expect a significant number of incorrect answers.
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RussR
En-Route
I'd be willing to bet the majority will get it wrong. But I like that question and what you're testing with it, so I very well might steal it!
It's along the same lines as selecting cruising altitudes for VFR. Here where the ground elevation is about 1200, I often get told by clients that westbound at 3500 is not a valid altitude.
The question is crocked. Scattered anything doesn't make a ceiling. The question is as Miss Mona Lisa Vito would say a Bull---- question.
MauleSkinner
Touchdown! Greaser!
The question has nothing to do with the weather. It’s just to distract you.
Yes, but @flyingron is correct. I should either make it a ceiling or not use the term. That's why
I haven't gotten to the final editing/typo/correction phase.
Thanks Ron.
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Bro do you even lift
has anyone said it has to be at night?
Better?
You are planning a cross country flight from TTA to Ocean Isle (60J). Forecasts indicate conditions at Ocean Isle beginning two hours before and continuing for 90 minutes after your arrival time will be better than 10 SM visibility with scattered to broken clouds at 3,000 feet AGL. Are you required to file an alternate?
60J has no instrument approaches. You always need an alternate regardless of the weather. Of course, I'm well attuned to this as I am based at a field with no instrument approaches.
What's really stupid, is that if I go to the closest field with an approach (5 NM away), I can use that as an alternate (provided its weather is good). Now if I were to use that airport as my original destination, I'd have to go much further away to get an alternate if the 1-2-3 didn't hold. I always list CLT as my alternate anyhow.
What's really stupid, is that if I go to the closest field with an approach (5 NM away), I can use that as an alternate (provided its weather is good). Now if I were to use that airport as my original destination, I'd have to go much further away to get an alternate if the 1-2-3 didn't hold. I always list CLT as my alternate anyhow.
I'm absolutely thrilled you know the answer. I would never have expected that! I figured you'd be in that significant number of pilots I expect to get it wrong.
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It's like asking what the ceiling minimums are for the ILS RWY 20 Approach at RUQ (for part 91 operators).
flyingcheesehead
Taxi to Parking
Ah jeez. You got me. I was like "What weird thing does that plate say?"
It's a plain old approach plate. Very average ILS.
"It's the visibility, stupid."
Yes, there's no such thing as a ceiling minimum on a plate.
Rgbeard
En-Route
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rgbeard
Some people find it easier to make themselves seem larger by making those around them seem smaller.
Lately, a few have progressively become like this.
I know this rings flat, but… welcome to POA.
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Lindberg
Final Approach
Was this intentionally ironic?
If not, then it's perfectly reasonable to assume there's a correlation between your ability to use proper punctuation and grammar and your ability to understand it.
MauleSkinner
Touchdown! Greaser!
Amazing the difference between this thread and the elevator horn thread…first post for both OPs, but the tone of that first post makes a huge impact.
Pinecone
En-Route
Probably not.
I had a fun one with a Federal Reg. The office that wrote the reg put out an official interpretation of what it said. I disagreed. I finally found the guy who wrote the reg and the interpretation. I told him he was wrong. He insisted he was right. So I asked him to take out a copy of the reg, clear his mind of what he thought it said, and just read it as written. I hear, "mumble, mumble OH S**T." He then says that I am right, it doesn't say what he meant to say.
Next cycle, the changed the reg to match what they wanted it to say.
bentmettle
Pre-Flight
I highlighted the bold bits - where does the reg state this? There is no expression in the reg of any kind of limitation on passengers outside of the requirement to be Solo in the first instance. I read this as permitting passengers if a CFI is in the plane.