Commercial cross country requirements

[midlifeflyer]

I'll bounce this off of a few DPE's and get their take.

Well, I and also with Mark on this.

Greg, you're not really agreeing with me (as opposed to the FAA). And you never know, he just might find a DPE who is willing to go against the Chief Counsel's official interpretation

Your second question concerns how the pilot performing the duties of PIC with an authorized instructor may log flight time. Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received.​

2014 Kuhn Letter

Not seeing a clear distinction that all 10 hours need to be either / or, but that specifically might be my bias.

It's your bias. We all have them.
2016 Grannis Letter

I wish I was important or smart enough to make this stuff up.

 

[RussR]

I'll bounce this off of a few DPE's and get their take. I read 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 -

(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​

I don't see any language about what activity the CFI / CFII needs to be doing or not to be doing. Either way both are logging as PIC.

Not seeing a clear distinction that all 10 hours need to be either / or, but that specifically might be my bias.

I also understand that "solo" means no passengers in the airplane - which means when you took your spouse to the beach it can't count. If you only took your family dog it would. Which makes no sense, but ..........

The either/or is because the regulations says ten hours of solo, OR 10 hours of PDPIC. Not "10 hours of solo or PDPIC". This was clarified in a Chief Counsel interpretation:

https://www.faa.gov/about/office_or...ps/2016/Grannis_2016_Legal_Interpretation.pdf

Regarding whether "solo" makes sense, I'd argue that you have to draw the line somewhere, if you're trying to ensure the pilot has some experience "making all the decisions". Sure, if your spouse sits in the back and reads a book that may meet the intent of the regulation. But if your airline pilot father is in the right seat, making decisions and basically directing the flight, that clearly does not (in my opinion). Even if the passenger isn't a pilot, they can be very helpful - I've seen spouses that do all the navigation and radio work and looking for traffic, for example. You have to make your own mistakes and see the effect of your decisions to learn from them.

And believe me, there are plenty of pilots out there who are afraid to fly without someone in the seat next to them, for safety and as a security blanket. Do you really want those people working as Commercial pilots without a little more seasoning? To me, this "solo" requirement is really about that. Ensuring the pilot has at least a minimum of "real", "non-training" experience.

 

[midwestpa24]

Yep. If it's not an insurance thing (or for some other reason the flight school precludes it), the pilot can fly it solo.

That is exactly what it is, and for the reasons I have said already in this thread. Many of the puppy mill Part 141 schools decided it was more effective use of a students time and money to skip the traditional PPL/IR/CSEL/CMEL training route, and jump straight to PPL/IR/CMEL since most of their students intend to go straight to the airlines and won't need a CSEL.

The catch is, insurance companies don't want low-time non-multi engine rated pilots flying multi-engine airplanes solo, even though it can be accomplished legally via endorsements. So the FAA changed the regulation to allow the "solo" commercial experience requirements to allow the instructor to be present.

 

[WDD]

Greg, you're not really agreeing with me (as opposed to the FAA). And you never know, he just might find a DPE who is willing to go against the Chief Counsel's official interpretation

Your second question concerns how the pilot performing the duties of PIC with an authorized instructor may log flight time. Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received.​

2014 Kuhn Letter


It's your bias. We all have them.
2016 Grannis Letter

I wish I was important or smart enough to make this stuff up.

Yikes!!! - thanks for posting this, as odd and disappointing as it is. But nothing to do about I guess. Who would have thought an unelected lawyer in a bureaucracy would make policy with a legal opinion.......