A question about the revised aeronautical experience requirements for commercial cert

[Nav8tor]

The latest rev to 61.129 (4) (Aeronautical Experience for a commercial certificate) allows an instructor to be on board the airplane for the 300 nm X-C and night TO&Ls at a controlled field.

...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—
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and
(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.

So a commercial candidate could meet the requirements by flying the entire 10 hrs either solo or with an instructor on board. What's not clear to me is if the 10 hrs can be made up of a mixture of solo time and instructor-on-board time. Specifically, I meet the requirements of (i) with a long cross country I flew as PIC with an instructor on board, but I did all of the 5 night hours for (ii) solo. A strict interpretation of the first sentence in the above quote would say that my experience doesn't meet the requirement because of the mixture of time with and without the instructor on board.

What do you folks think?

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

So a commercial candidate could meet the requirements by flying the entire 10 hrs either solo or with an instructor on board.

That's correct.

What's not clear to me is if the 10 hrs can be made up of a mixture of solo time and instructor-on-board time. Specifically, I meet the requirements of (i) with a long cross country I flew as PIC with an instructor on board, but I did all of the 5 night hours for (ii) solo.

If you did that cross country before 10/20/09, you may have trouble counting it. For such a flight to count, the instructor must specifically endorsed it to say the flight was made with you performing the duties of PIC, typically referencing the applicable regulation. Since that reg didn't exist before 10/20/09, you may have trouble showing that it was done the way the new reg says, and that your instructor was not performing any PIC duties.

That said, after re-reading the preamble to the reg change, I don't think the fact that you did the long XC with an instructor and the night stuff solo will raise any issues as long as the instructor endorsing the long XC flight makes an appropriate entry, such as, "ABC-DEF-GHI-ABC simulated solo XC per 61.129(a)(4)(i) /s/ IM Instructor, 1234567CFI exp 11/31/11."

 

[Nav8tor]

Re: A question about the revised aeronautical experience requirements for commercial

That's correct.
If you did that cross country before 10/20/09, you may have trouble counting it. For such a flight to count, the instructor must specifically endorsed it to say the flight was made with you performing the duties of PIC, typically referencing the applicable regulation. Since that reg didn't exist before 10/20/09, you may have trouble showing that it was done the way the new reg says, and that your instructor was not performing any PIC duties.

That said, after re-reading the preamble to the reg change, I don't think the fact that you did the long XC with an instructor and the night stuff solo will raise any issues as long as the instructor endorsing the long XC flight makes an appropriate entry, such as, "ABC-DEF-GHI-ABC simulated solo XC per 61.129(a)(4)(i) /s/ IM Instructor, 1234567CFI exp 11/31/11."

Thanks Ron. The flight was 12 years ago.

Out of curiosity, were in the FARs does it say that the instructor needs to make the specific endorsement about simulated solo?

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Out of curiosity, were in the FARs does it say that the instructor needs to make the specific endorsement about simulated solo?

Since it's a flight which requires an instructor aboard, the instructor must endorse it (61.189(a)). And in order to prove that the flight meets 61.129(a)(4), there must be something in the log entry showing you were either solo or performing the duties of PIC with an instructor present. The exact wording isn't set, hence my use of the word "appropriate" and an example of an endorsement which would be acceptable, but not the only way to word it.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Since it's a flight which requires an instructor aboard, the instructor must endorse it (61.189(a)).

I have a bit of a problem with that.

§ 61.189 Flight instructor records.

(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.

Unless I missed something, the only reason the CFI is to be aboard on "solo" cross countries is for "insurance" reasons. I don't think that rises to the level of a flight that "requires an instructor to be aboard". What would the 61.189(a) endorsement look like? The instructor is to be a bump on a log during the flight, so no "instruction" is being received.

I do agree that some sort of endorsement for 61.129(a)(4), however.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Ron, under what circumstances does a "solo" flight REQUIRE a CFI aboard? The only thing I can think of is in a situation where the Pilot can legally be PIC but the insurance company won't cover him. In that case, a 61.189 endorsement would negate the 61.129(a)(4) endorsement because the CFI would have to be little more than a bump on a log. In other words, no instruction AT ALL taking place.

And for that matter, I don't see how the CFI could log any of it.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Ron, under what circumstances does a "solo" flight REQUIRE a CFI aboard? The only thing I can think of is in a situation where the Pilot can legally be PIC but the insurance company won't cover him.

It doesn't matter whether the pilot can be PIC or not -- take the case of a PP-ASEL-IA doing initial Commercial in a twin -- not rated, not signed off for solo, but still needing that "simulated solo" time for 61.129(b)(4). The problem is the insurance, -- even if legal to be PIC, the insurer often won't allow someone to fly the plane solo without a lot more experience than most folks have in that situation, whether they're rated or not.

In that case, a 61.189 endorsement would negate the 61.129(a)(4) endorsement because the CFI would have to be little more than a bump on a log. In other words, no instruction AT ALL taking place.

The FAA doesn't seem to see it that way. Put it this way -- if the instructor doesn't endorse it, and there's no solo time logged (as there cannot be since the applicant was not the sole occupant), then the logbook entry does not appear to meet the requirements for 61.129(a/b)(4).

And for that matter, I don't see how the CFI could log any of it.

The instructor doesn't have to log it, but I see no reason why s/he can't, since that person was acting as an instructor during a flight when an authorized instructor is required by the regulations. 61.51(e)(3)

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Unless I missed something, the only reason the CFI is to be aboard on "solo" cross countries is for "insurance" reasons. I don't think that rises to the level of a flight that "requires an instructor to be aboard".

It's not that an instructor must be aboard (although in some cases it could, e.g., PP-ASEL-IA doing initial Commercial in a twin and not signed off for solo in twins), but that only an instructor can be aboard if the flight isn't actually solo.

What would the 61.189(a) endorsement look like?

"ABC-DEF-GHI-ABC simulated solo XC per 61.129(a)(4)(i) /s/ IM Instructor, 1234567CFI exp 11/31/11."

I do agree that some sort of endorsement for 61.129(a)(4), however.

Exactly -- there has to be some proof that the non-solo flight still met the requirements of 61.129(a/b)(4), i.e., that only the presence of an instructor was the reason it wasn't actually "solo." The instructor's endorsement provides that.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

"ABC-DEF-GHI-ABC simulated solo XC per 61.129(a)(4)(i) /s/ IM Instructor, 1234567CFI exp 11/31/11."

That takes care of the 61.129 endorsement nicely, however, for a 61.189 endorsement:

§ 61.189 Flight instructor records.

(a) A flight instructor must sign the logbook of each person to whom that instructor has given flight training or ground training.

Since it is expressly forbidden for the CFI to GIVE flight training on said flight, any sort of 61.189 endorsement would completely negate a 61.129 endorsement.

Sorry, Ron. Can't buy any sort of 61.189 endorsement.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

The FAA doesn't seem to see it that way.

Not to be argumentative, but you are going to have to prove that one.

Put it this way -- if the instructor doesn't endorse it, and there's no solo time logged (as there cannot be since the applicant was not the sole occupant), then the logbook entry does not appear to meet the requirements for 61.129(a/b)(4).

Why wouldn't just one endorsement covering 61.129 cover it? Why does a 61.189 endorsement have to be made since there is no training taking place?

 

[Nav8tor]

Re: A question about the revised aeronautical experience requirements for commercial

...there has to be some proof that the non-solo flight still met the requirements of 61.129(a/b)(4), i.e., that only the presence of an instructor was the reason it wasn't actually "solo." The instructor's endorsement provides that.

OK, so there should be some proof that the only occupant other than the PIC was an instructor? Can that take the form of any type of instructor endorsement? Suppose the X-C or night flights included a BFR or IPC? You'd have the endorsement saying the instructor was aboard but it wasn't really "simulated solo" since there was some form of dual given.

 

[Nav8tor]

Re: A question about the revised aeronautical experience requirements for commercial

...it is expressly forbidden for the CFI to GIVE flight training on said flight...

Greg, where are you getting that from? I must have missed it somewhere.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

OK, so there should be some proof that the only occupant other than the PIC was an instructor? Can that take the form of any type of instructor endorsement. Suppose the X-C or night flights included a BFR or IPC? You'd have the endorsement saying the instructor was aboard but it wasn't really "simulated solo" since there was some form of dual given.

Well, Lee. The only thing the "solo" with an instructor applies to is the Commercial Cross Country. Your examples really don't fall under that category.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Greg, where are you getting that from? I must have missed it somewhere.

The new cross country rules allow for the "solo" cross country to have an instructor aboard if needed to make the flight Insurance Legal. 61.129 in part:

(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—

(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

Although this section covers single engine, (b) of the same section covers Multi Engine.

 

[Nav8tor]

Re: A question about the revised aeronautical experience requirements for commercial

Well, Lee. The only thing the "solo" with an instructor applies to is the Commercial Cross Country. Your examples really don't fall under that category.

For the cross country flight in question I have an instructor endorsement that says a BFR was completed as part of the flight. The length of the flight meets the requirements for the commercial cross country and since a BFR was included I have an endorsement which is the proof that an instructor was on-board.

I guess to avoid potential confusion with an examiner I'll just do a long solo cross country per the requirements.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Why wouldn't just one endorsement covering 61.129 cover it? Why does a 61.189 endorsement have to be made since there is no training taking place?

I'm confused by this question. You make a 61.129 endorsement because 61.189 says you have to sign the trainee's log, but it's just one endorsement in the log citing 61.129.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

OK, so there should be some proof that the only occupant other than the PIC was an instructor? Can that take the form of any type of instructor endorsement? Suppose the X-C or night flights included a BFR or IPC? You'd have the endorsement saying the instructor was aboard but it wasn't really "simulated solo" since there was some form of dual given.

I don't see any problem with that as long as the trainee is "performing the duties of PIC." There's nothing in 61.129 which says the instructor can't tell the trainee what tasks s/he wants the trainee to do (e.g., "Fly this approach") as long as the trainee performs those tasks without further assistance (e.g., answering questions about how to fly that approach).

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Well, Lee. The only thing the "solo" with an instructor applies to is the Commercial Cross Country.

It also applies to the night flying in 61.129(a/b)(4)(ii).

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

For the cross country flight in question I have an instructor endorsement that says a BFR was completed as part of the flight. The length of the flight meets the requirements for the commercial cross country and since a BFR was included I have an endorsement which is the proof that an instructor was on-board.

I guess to avoid potential confusion with an examiner I'll just do a long solo cross country per the requirements.

I see no problem here as long as the instructor wrote in your log that the flight also qualified under 61.129(a)(4)(i).

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

I'm confused by this question. You make a 61.129 endorsement because 61.189 says you have to sign the trainee's log, but it's just one endorsement in the log citing 61.129.

61.189 says no such thing. 189 covers FLIGHT or GROUND TRAINING. Since Training is strictly verboten, 189 does not even apply.

You make a .129 endorsement to cover .129, not because 189 says so because it clearly does not.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

I see no problem here as long as the instructor wrote in your log that the flight also qualified under 61.129(a)(4)(i).

Wait just a doggone minute. How do you come up with that? How can a flight review POSSIBLY be contained is such a flight and still qualify?

The whole purpose for 129 is to substitute a CFI for SOLO in the event that insurance comes to play. In other words, the purpose of the flight must be "Solo" Cross Country. No other purpose. In other words again, IF a flight review is covered during that particular flight, it cannot qualify for the solo cross country under 61.129(a)(4)(i).

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

61.189 says no such thing. 189 covers FLIGHT or GROUND TRAINING. Since Training is strictly verboten, 189 does not even apply.

Where to you see that? All it says in 61.129(a)(4) is that the pilot must be "performing the duties of PIC."

In any event, without some sort of endorsement, it's impossible for the applicant to show that the non-solo flight complied with 61.129(a)(4). What I can't figure out is what you mean by a "61.189 endorsement." In this situation, you endorse the log, you say what was done citing the appropriate reg, and sign it. Whether you consider that a "61.129 endorsement" or a "61.189 endorsement" or whatever, the documentation of the flight being conducted per 61.129(a)(4) must be there. If you can figure out how to do that other than with my FAA-tested endorsement listed above, I'd be happy to hear it.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

Wait just a doggone minute. How do you come up with that? How can a flight review POSSIBLY be contained is such a flight and still qualify?

Where in 61.129(a)(4) do you see anything saying that you can't do a flight review as part of this flight as long as the pilot is "performing the duties of PIC"? Now, if he can't do that, and I have to teach him up to speed, then I'm not signing it off for 61.129(a)(4), just 61.56(a). But that's not to say that if the pilot demonstrates PIC proficiency without assistance that I can't sign off both.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Change "endorse" to "entry" in my previous posts. I tend to use them synonymously. Sorry for that confusion.

Ok, I guess we have a difference of opinion of just what 61.129 is all about. Either that, or we are having a failure to communicate.

(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—

(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

Since this is under the section of the regs that is supposed to cover "Solo" experience for the purposes of obtaining a commercial rating, I figure the pilot should for all practical purposes act as if he is solo on the flight. As I see it, the ONLY reason the reg is worded the way it is is to allow for an instructor to go along to keep the insurance company happy. In other words, the instructor is to keep his mouth shut while the other pilot is "performing the duties of PIC".

The only thing that the instructor should put in the "student"'s logbook would be to annotate that the flight was conducted under the provisions of 61.129(a)(4)(i). 61.189 has nothing to do with it.

I THOUGHT you were the one that originated the idea that the instructor in this situation could do nothing during this flight other than sit there. I thought you basically said that if the instructor had to do anything related to the flight, then the flight would not count as far as this section is concerned.

Posts 3 and 15 of this thread on another board. http://forums.aopa.org/showthread.php?t=60608&highlight=61.129

If that is the case, nothing other than "solo" cross country stuff should be done. Certainly not a Flight Review, or any other form of instruction.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Where in 61.129(a)(4) do you see anything saying that you can't do a flight review as part of this flight as long as the pilot is "performing the duties of PIC"? Now, if he can't do that, and I have to teach him up to speed, then I'm not signing it off for 61.129(a)(4), just 61.56(a). But that's not to say that if the pilot demonstrates PIC proficiency without assistance that I can't sign off both.

When, on a solo cross country, would you be able to do a flight review? I think you have a different idea of just what 61.129 is all about than I do.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

When, on a solo cross country, would you be able to do a flight review?

During the flight? Just what is it that you are required to do on a flight review that you can't do on a 2-hour out-and-back to a place more than 100nm away? There's nothing in 61.129(a)(4)(i) which says the pilot can't perform various other tasks asked for by the instructor during the flight.

 

[nosehair]

Re: A question about the revised aeronautical experience requirements for commercial

Greg, ...you have the mis-understanding that an instructor must be talking to be instructing. Nope.

One of the conditions that I require to endorse a pilot candidate for a checkride, is that he/she can execute a "simulated checkride" with no instruction from me. Evaluation is a part of training.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

During the flight? Just what is it that you are required to do on a flight review that you can't do on a 2-hour out-and-back to a place more than 100nm away? There's nothing in 61.129(a)(4)(i) which says the pilot can't perform various other tasks asked for by the instructor during the flight.

I guess we will just have to get a Chief Counsel interp then. I am of the opinion that if an instructor does any sort of instructing on a cross country flight that is SUPPOSED to be SOLO but by the conditions of 61.129 has that instuctor aboard that negates the whole thing. The instructor is there ONLY to make the flight legal insurance wise and for NO OTHER purpose. PERIOD.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Greg, ...you have the mis-understanding that an instructor must be talking to be instructing. Nope.

No I don't. This is about a flight that is SUPPOSED to be solo, but for insurance purposes must have a CFI aboard to make the flight legal.

 

[TMetzinger]

Re: A question about the revised aeronautical experience requirements for commercial

Please don't get a regional interpretation - ask the chief counsel - that way there'll be one binding answer, rather than a bunch of different answers depending on which region you ask.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Please don't get a regional interpretation - ask the chief counsel - that way there'll be one binding answer, rather than a bunch of different answers depending on which region you ask.

That is what I meant. Edited.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

If you feel that strongly, Greg, I think you should get that interpretation from the Chief Counsel.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Apparently I am failing to communicate my position effectively here.

Prior to this current rewrite 61.129(a)(4) said SOLO. Period. Only living human being on the airplane. Now it says solo or performing the duties of pilot in command. As I understand it, that last provision was put in there to allow for a pilot to fly an airplane that he is otherwise qualified to fly except for insurance purposes.

Since 61.129(a)(4) still mentions solo time, I contend that the spirit of the reg is that the pilot is to treat the flight as if he is the sole human occupant of the airplane. I contend that since a CFI is considered de jure if not de facto PIC, the wording "performing the duties of pilot in command" is there to make it clear that the student is to consider himself Pilot In Command irregardless of the CFI in the other seat.

Now, I am going to quote a couple of passages from a thread on another board that Ron wrote.

It's the insurance issue mentioned below.

Perhaps because they trust the instructor to sit there mutely and do nothing unless disaster is imminent.

Read the reg again -- the instructor is not supposed to help. The applicant is supposed to do all PIC functions by him/herself. As an instructor, when I've been aboard for such a flight, I make it clear that I'm just there as insurance ballast, and that if I have to intervene, the pilot doesn't get 61.129(a/b)(4) credit for the flight over my signature. And I'm here to tell you, sometimes it can be awfully hard to zip lip and sit on my hands on those flights, but I have to do it, and so far, everyone's been able to get the credit.

Now, since this was originally supposed to be a SOLO flight, and as Ron has mentioned above and I have also mentioned in other posts, I contend that the flight is to be treated as a solo flight by the pilot irregardless of whether the CFI is in the other seat or not. THAT is what I think the intent of the regulation is and to look at Ron's posts above, that is what I though HE thought the intention was.

I don't see how ANY other flight training (i.e. a flight review) can be conducted during the flight.

Ron is getting wrapped around the axle about the phrase "performing the duties of Pilot In Command". I contend that that was the FAA's way of dealing with the fact that an instructor MAY be onboard and would be the de jure if not de facto PIC.

Until otherwise challenged, I contend that anyone who does anything other than a "solo" cross country with a CFI aboard is running the risk of having the DPE at checkride time disallowing the flight. If one wants to be 100% sure of having his cross country allowed under the new provisions of 61.129(a)(4), he better make sure the CFI sits on his hands and keeps his mouth shut during the flight.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

If you feel that strongly, Greg, I think you should get that interpretation from the Chief Counsel.

Ron, I may just do that, but I am batting ZERO in that regard.

However, I am 100% sure the FAA will have no problems with the way I do it. I am not so sure about yours. So in that regard, it really isn't me that needs the interp.

 

[flyingcheesehead]

Re: A question about the revised aeronautical experience requirements for commercial

Greg, FWIW I agree with you - "Solo" should be, if not able to do it actually solo, as close as possible to the real thing. If the instructor has to speak up at all, it shouldn't be counted.

However, I am 100% sure the FAA will have no problems with the way I do it. I am not so sure about yours. So in that regard, it really isn't me that needs the interp.

And the ironic thing is that it's Ron who usually says that exact thing!

Ron, what's changed your mind on this, and why?

 

[TMetzinger]

Re: A question about the revised aeronautical experience requirements for commercial

My takeaway from Ron's position is that if he has to correct anything, either verbally or physically, then the student "fails" and the flight is no longer a supervised solo. On the other hand, giving the student tasks that the student does without any correction required would satisfy the requirements for a flight review.

As someone else said, it's the difference between instruction and evaluation.

 

[nosehair]

Re: A question about the revised aeronautical experience requirements for commercial

Prior to this current rewrite 61.129(a)(4) said SOLO. Period. Only living human being on the airplane. Now it says solo or performing the duties of pilot in command. As I understand it, that last provision was put in there to allow for a pilot to fly an airplane that he is otherwise qualified to fly except for insurance purposes.

The operative word here is, "as I understand it,".

Nowhere in the re-write is there any mention of insurance, or that the instructor cannot instruct.

To me, this is the same as flying dual and logging it PIC. Exactly the same.

Before I came to these boards and discovered that people logged PIC when dual and not yet "performing the duties of PIC", I was struck dumb.

I always considered that the wording of "sole manipulator" meant, essentially, "performing the duties of PIC" in order to log it as such.

Meaning that the instructor is capable of making the decision as to the quality and character of the student's extent of being "sole manipulator".

The actual definition of sole manipulator changes with the aircraft type, wx conditions, operating environment, etc., so a strict definition is impossible.

Yet, the strict application of the words in the reg leave me no alternative but to let it go. It just doesn't matter.

The new reg re-write is just making it a legal alternative to the actual solo; to fly with an instructor logging it PIC, and the new rule allows this Dual-as-PIC.

 

[poadeleted20]

Re: A question about the revised aeronautical experience requirements for commercial

My takeaway from Ron's position is that if he has to correct anything, either verbally or physically, then the student "fails" and the flight is no longer a supervised solo. On the other hand, giving the student tasks that the student does without any correction required would satisfy the requirements for a flight review.

As someone else said, it's the difference between instruction and evaluation.

Bingo.

 

[Greg Bockelman]

Re: A question about the revised aeronautical experience requirements for commercial

Sigh!

 

[Everskyward]

Re: A question about the revised aeronautical experience requirements for commercial

Before I came to these boards and discovered that people logged PIC when dual and not yet "performing the duties of PIC", I was struck dumb.

I always considered that the wording of "sole manipulator" meant, essentially, "performing the duties of PIC" in order to log it as such.

Meaning that the instructor is capable of making the decision as to the quality and character of the student's extent of being "sole manipulator".

The actual definition of sole manipulator changes with the aircraft type, wx conditions, operating environment, etc., so a strict definition is impossible.

Yet, the strict application of the words in the reg leave me no alternative but to let it go. It just doesn't matter.

The new reg re-write is just making it a legal alternative to the actual solo; to fly with an instructor logging it PIC, and the new rule allows this Dual-as-PIC.

While I might agree with you in spirit that isn't the way the regs are written. I always thought that there should be more correlation between logging and acting as PIC but that's not the way it is. I think you should at least be pretending to act as PIC before you are able to log it. I also think that "solo" should mean that you are the only one in the airplane. Even if someone is able to perform tasks up to speed there is definite psychological difference when you are working without a safety net and I think that is important for pilots to learn or experience. I think they should have left the solo hours for private at 20 instead of decreasing it to 10 for just that reason. Of course no one asked me any of these things..