IACRA Solo time?

[hish747]

A question for the CFIs...
I'm filling out IACRA for my Commercial MEL add-on. In the section where it asks for solo time, I entered 337 hours because that's what I have as of today. My CFI sent it back to me for correction saying that they are only asking about solo time before becoming a private pilot. This doesn't make sense to me but of course the FAA is great at not making sense. Is my CFI right? Of course I don't care either way but I don't want to meet with the examiner and have him say we can't go forward because of an error in IACRA.
Thanks!

 

[AggieMike88]

So he is expecting this to be a much smaller amount? I wonder where he got this idea into his noggin.

I've always entered my total solo time. So far, no DPE has had any comment.

 

[1anG]

So I heard this from a DPE but makes no sense to me. Solo would be any time I was the soul occupant of the airplane. As it makes no difference after the PPL solo time is also PIC time. The commercial XC is supposed to be solo 61.129 says that ur long Xc can be solo or pic with Instructor. It’s still solo time.

 

[Brad Z]

So I heard this from a DPE but makes no sense to me. Solo would be any time I was the soul occupant of the airplane. As it makes no difference after the PPL solo time is also PIC time. The commercial XC is supposed to be solo 61.129 says that ur long Xc can be solo or pic with Instructor. It’s still solo time.

No, solo time is solo time. Solo time is defined in 61.51(d), which states: "Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft."

 

[1anG]

No, solo time is solo time. Solo time is defined in 61.51(d), which states: "Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft."

Oh I agree, just saying that one DPE has the same explanation as the CFI. I agree that solo is sole occupant.

 

[Brad Z]

Oh I agree, just saying that one DPE has the same explanation as the CFI. I agree that solo is sole occupant.

I'm clarifying that a person performing the duties of PIC while an instructor serves as the legal PIC isn't considered solo time. It might count towards aeronautical experience that would otherwise be solo, but it isn't solo time.

 

[tonycondon]

Solo is solo, put whatever your actual solo time is. The DPE just needs to see that your experience.meets the requirements for the certificate that you are applying for. For a commercial Multi (assuming you already have commercial single), that means basically a non zero number in the column. You are the one who is signing off with penalty of law that the number is correct.

Signed, a DPE

 

[hish747]

Solo is solo, put whatever your actual solo time is. The DPE just needs to see that your experience.meets the requirements for the certificate that you are applying for. For a commercial Multi (assuming you already have commercial single), that means basically a non zero number in the column. You are the one who is signing off with penalty of law that the number is correct.

Signed, a DPE

My CFI and I don't disagree about what solo time means. We disagree about what kind of solo time they are asking for in IACRA.
It may not matter, but my Solo time I listed on IACRA for the instrument rating and Commercial SEL was in the hundreds. Wouldn't it be weird if I now said it was only 13 based on my CFI's interpretation of what they want on the IACRA?

 

[Lindberg]

A question for the CFIs...
I'm filling out IACRA for my Commercial MEL add-on. In the section where it asks for solo time, I entered 337 hours because that's what I have as of today. My CFI sent it back to me for correction saying that they are only asking about solo time before becoming a private pilot. This doesn't make sense to me but of course the FAA is great at not making sense. Is my CFI right? Of course I don't care either way but I don't want to meet with the examiner and have him say we can't go forward because of an error in IACRA.
Thanks!

The rating that you are applying for requires post-private solo time (or time acting as PIC with an instructor instead). It seems obvious that you'd document that in IACRA. Conversely, when applying for an additional rating, why would the FAA care exclusively about time needed to qualify for a prior rating? Your instructor's position makes no sense.

 

[Brad Z]

My CFI and I don't disagree about what solo time means. We disagree about what kind of solo time they are asking for in IACRA.
It may not matter, but my Solo time I listed on IACRA for the instrument rating and Commercial SEL was in the hundreds. Wouldn't it be weird if I now said it was only 13 based on my CFI's interpretation of what they want on the IACRA?

What you enter into form 8710-1 form in IACRA is an official record of your flight time. The numbers should match what is in your logbook.

 

[ja_user]

Match your logbook, it’s that simple.

 

[WannFly]

My log book has a column called Solo/PIC time. Am I supposed to remember how many flights I took with pax and how many of them were just me and my soul?

 

[Lindberg]

My log book has a column called Solo/PIC time. Am I supposed to remember how many flights I took with pax and how many of them were just me and my soul?

Yes, at least if you're going for ratings that require solo time. All solo time is PIC. But there's no correlation the other way.

 

[Brad Z]

My log book has a column called Solo/PIC time. Am I supposed to remember how many flights I took with pax and how many of them were just me and my soul?

Weird if it's a combined field. But yes, if you have a reason to log solo you should. With the exception of student pilot and ATP, every part 61 pilot certificate has an aeronautical experience requirement that can be met using solo flight time.

 

[hish747]

Digging a little deeper I see that there are 2 definitions of solo time in the regs.
61.51d defines logging of solo time. "a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft"
This would mean total solo time or 337 hours in my case.

61.87 defines solo time for students: "The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft..." This would mean 13.7 hours as I had when I was a student.

The question is, what is the source for thinking that IACRA is asking for my time as it was more than 20 years ago (61.87)?

 

[flyingron]

The definition in 61.87 ONLY applies to student pilot issues. The words "used in this subpart" means it applies ONLY to 61.87 through 61.95.

 

[Lindberg]

Digging a little deeper I see that there are 2 definitions of solo time in the regs.
61.51d defines logging of solo time. "a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft"
This would mean total solo time or 337 hours in my case.

61.87 defines solo time for students: "The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft..." This would mean 13.7 hours as I had when I was a student.

The question is, what is the source for thinking that IACRA is asking for my time as it was more than 20 years ago (61.87)?

One of those sections is about logging.

 

[Brad Z]

Digging a little deeper I see that there are 2 definitions of solo time in the regs.
61.51d defines logging of solo time. "a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft"
This would mean total solo time or 337 hours in my case.

61.87 defines solo time for students: "The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft..." This would mean 13.7 hours as I had when I was a student.

The question is, what is the source for thinking that IACRA is asking for my time as it was more than 20 years ago (61.87)?

61.51 is logging time. Since you're no longer a student pilot, 61.87 no longer applies. Nevertheless, the two definitions are not mutually exclusive; a student who is the sole occupant of the aircraft is also a pilot who is the sole occupant of the aircraft. A student pilot is in fact a pilot.

 

[flyingron]

One of those sections is about logging.

Yeah, so? The definitions of various flight times are not limited to 61.51's logging aspects. For instance, cross country time is defined in 61.1 and applies to logging and aeronautical experience. Flight Time itself is defined in 1.1. The reason there is no conflict here is because 61.87 specifically says it's only referring to the subpart it is in.

 

[SbestCFII]

A question for the CFIs...
I'm filling out IACRA for my Commercial MEL add-on. In the section where it asks for solo time, I entered 337 hours because that's what I have as of today. My CFI sent it back to me for correction saying that they are only asking about solo time before becoming a private pilot. This doesn't make sense to me but of course the FAA is great at not making sense. Is my CFI right? Of course I don't care either way but I don't want to meet with the examiner and have him say we can't go forward because of an error in IACRA.
Thanks!

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

 

[Brad Z]

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

Don't forget there are solo requirements in 61.129 for commercial pilot candidates.

 

[RussR]

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

Disagree. If you’re flying by yourself, it’s clearly “solo” time as defined in 61.51. I don’t even see any gray area, it’s pretty well spelled out.

 

[Lindberg]

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

Are you the OP's CFI?

 

[RussR]

My log book has a column called Solo/PIC time. Am I supposed to remember how many flights I took with pax and how many of them were just me and my soul?

The columns in a logbook are only what the logbook designer thought were important. They are not mandated by the FAA, nor are they indicative of what is required, is not required, is a good idea, or anything else. Often, compromises have to made for the sake of the space available. For example, some logbooks have a "Day" column and a "Night" column. Some just have a "Night" column, the assumption being of course that if it's not logged as "night", it must be "day". (Personally I think having a "Day" column is a waste of space.) But, commercially available logbooks are not reviewed or approved by the FAA before publication. It is up to you to determine if the logbook you are using has columns that are useful to you.

Weird if it's a combined field. But yes, if you have a reason to log solo you should. With the exception of student pilot and ATP, every part 61 pilot certificate has an aeronautical experience requirement that can be met using solo flight time.

The current Jeppesen "Pilot" logbook (not the massive Professional Pilot one) has a column just like that - "Pilot in Command (incl solo)".

 

[Brad Z]

The current Jeppesen "Pilot" logbook (not the massive Professional Pilot one) has a column just like that - "Pilot in Command (incl solo)".

I’m guessing that labeling of the column first showed up after he 1997 part 61 re-write, as student pilot solo time was not considered PIC time prior to the re-write. Nowadays it’s self evident that solo time is PIC time, but that wasn’t always the case.

 

[smv]

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

Cite?

 

[BrianNC]

I’m guessing that labeling of the column first showed up after he 1997 part 61 re-write, as student pilot solo time was not considered PIC time prior to the re-write. Nowadays it’s self evident that solo time is PIC time, but that wasn’t always the case.

I got my Jeppesen logbook in 1979 and my column is labeled "Pilot in Command (incl solo)" so that can't be the case.

 

[PeterNSteinmetz]

My log book has a column called Solo/PIC time. Am I supposed to remember how many flights I took with pax and how many of them were just me and my soul?

This is why as soon as I had the solo endorsement I added a separate column from the solo/pic time column for solo time only in the margin.

 

[JonH]

Did your CFI mix you up with someone working on their PPL?

Unless IACRA states otherwise, solo time is solo time. If your rating is above PPL, they already know your PPL solo time anyway.

 

[WannFly]

This is why as soon as I had the solo endorsement I added a separate column from the solo/pic time column for solo time only in the margin.

Well I do maintain a separate excel file for IR requirement and may be down the road commercial if I end up doing it. But not every flight is in there tracked solo vs with pax. O well

 

[MauleSkinner]

Keep in mind that what you put in the “solo” boxes of IACRA is also considered PIC...in other words, 337 hours of “solo” time and 300 hours of non-solo PIC would go in as 637 under the PIC heading and 337 under solo.

 

[Ryan F.]

"Solo" time is the time spent flying as a solo student pilot (PIC) without your CFI prior to receiving your initial pilot certificate. After that, when you're flying by yourself, you're not a solo student pilot. You're just flying by yourself.

That is incorrect. Solo time is solo time -- pure and simple. It matters not which certificate or rating was held by the pilot at the time.

 

[PeterNSteinmetz]

Well I do maintain a separate excel file for IR requirement and may be down the road commercial if I end up doing it. But not every flight is in there tracked solo vs with pax. O well

Can you reconstruct at this point. I had a similar issue because I did not realize this right away. I had few enough flights at that point that by reading the dates and comments and looking at my calendar I could figure out which were which. Good luck in your training.

 

[tonycondon]

That is incorrect. Solo time is solo time -- pure and simple. It matters not which certificate or rating was held by the pilot at the time.

I wonder how many DPE's it will take, giving this answer, before it sinks in

 

[James331]

Weird if it's a combined field. But yes, if you have a reason to log solo you should. With the exception of student pilot and ATP, every part 61 pilot certificate has an aeronautical experience requirement that can be met using solo flight time.

ATP?

 

[flyingron]

I don't know why anybody thinks DPEs have any more clue than anybody else in this regard. The FAA endows them with one job, conducting checkrides. They aren't empowered to give meaningful legal interpretations.

 

[WannFly]

Can you reconstruct at this point. I had a similar issue because I did not realize this right away. I had few enough flights at that point that by reading the dates and comments and looking at my calendar I could figure out which were which. Good luck in your training.

Too lazy to go back and do this. I have the time notes for IR and commercial as well, in any case I fly for pleasure.... the ship for going to airlines have long sailed

 

[smv]

I don't know why anybody thinks DPEs have any more clue than anybody else in this regard. The FAA endows them with one job, conducting checkrides. They aren't empowered to give meaningful legal interpretations.

Most of them are at least smart enough to understand the difference between "Solo" and "Not Solo", even if all CFIs apparently cannot.

 

[Brad Z]

ATP?

There are no specific solo aeronautical experience requirements for an ATP certificate. There are no aeronautical experience requirements whatsoever for student pilots.

Sport Pilot, Recreational Pilot, Private Pilot, and Commercial Pilot all require some solo*
aeronautical experience requirements.

*solo, or performing the duties of PIC alternative requirement.