Supervised Solo

[midlifeflyer]

Very interesting Chief Counsel opinion on the use of "performing the duties of pilot in command in [an aircraft] with an authorized instructor on board" (commonly referred to as "supervised solo") to meet solo requirements.

You can't mix and match. All of the solo hours need to be either solo or supervised solo. For the commercial ASEL, for example, you can't do your long commercial cross country with a CFI on board and do the rest of the solo requirements by yourself.

2016 Grannis Interpretation

 

[RussR]

Why would anybody even ask this question?

I never considered that you couldn't combine them. I have sent Commercial applicants for checkrides with mix-and-matched time with no problems.

However, upon re-reading the reg, I actually agree with the Chief Counsel's interpretation. It does pretty clearly say 10 hours solo OR 10 hours supervised solo.

That doesn't mean I agree with the regulation, I think it's silly for it to be only one way or the other. But the Chief Counsel doesn't write the regulations.

 

[midlifeflyer]

From the letter, looks like there were a group of CFIs who disagreed on it. Since it directly affects the cost of flight training, maybe they thought it was important to have an answer one way or another.

 

[DFH65]

This is a perfect example of why pilots come to dislike the FAA. I don't see how it makes a bit of difference in the real world. Your either PIC or your not CFI on board or not. They are simply parsing the words legally without consideration of real world application.

 

[Caramon13]

Aha..well, I'm glad I brought a CFI with me on my long XC. But I guess the rule makes sense.

However, I don't see how this would benefit CFI's or increase flight training costs, quite the contrary @midlifeflyer. Suppose you decide to do your CPL long distance solo. Are you REALLY going to need or want a CFI on board for the 5 hours of night requirement? You probably can find that somewhere in your logbook between PPL and CPL at some point..no problem.

Or vice/versa, if you already have 5 hours of night why would you pay an instructor to do your long XC? Seems these CFI's just talked themselves out of 5 hours of dual..

 

[GeorgeC]

I never understood what the big deal was with the long XC or 5 hours of night solo. Why would you want an instructor to begin with?

 

[midlifeflyer]

Aha..well, I'm glad I brought a CFI with me on my long XC. But I guess the rule makes sense.

However, I don't see how this would benefit CFI's or increase flight training costs, quite the contrary @midlifeflyer. Suppose you decide to do your CPL long distance solo. Are you REALLY going to need or want a CFI on board for the 5 hours of night requirement? You probably can find that somewhere in your logbook between PPL and CPL at some point..no problem.

Or vice/versa, if you already have 5 hours of night why would you pay an instructor to do your long XC? Seems these CFI's just talked themselves out of 5 hours of dual..

I agree with what you said, but here's "why would you pay"? (You or I and a lot of pilots wouldn't, but it's not about you or me or them)

Here's one time-splitting scenario I think Flight Standards might want to avoid: We have a commercial trainee who is qualified to act as PIC from legal, insurance, and practical standpoints. But he is still very nervous about long cross country flights. So, instead of embarking on his own, he opts to have the CFI with with him for the long cross country. OTOH, he is comfortable with doing some local flights solo to get the rest of the solo hours and requirements and would not want to pay a CFI for that. Or maybe the reverse; perfectly happy to do the long cross country, but that night solo? Maybe not so.

With a "mix and match" rule, he pays the CFI for what he wants and doesn't pay for what he doesn't want. Trainee gets to avoid doing something he is uncomfortable with solo for a relatively small price.

Without a "mix and match" rule, the trainee has to make a choice. (a) Pay a lot for the CFI to accompany for all the solo requirements and spend a bunch of extra money, or (b) learn some self-reliance.

I suspect (WAG) the FAA wants to avoid that bad training scenario but a rule that says "supervised solo can only be used if you are not qualified to fly the aircraft solo" would be completely unworkable.

 

[midlifeflyer]

I never understood what the big deal was with the long XC or 5 hours of night solo. Why would you want an instructor to begin with?

Remember the rule was originally designed to allow a commercial multi applicant to complete solo requirements although she could not fly a twin solo due to insurance requirements. Even the extension of the rule to other ratings uses the same rationale.

 

[Caramon13]

I agree with what you said, but here's "why would you pay"? (You or I and a lot of pilots wouldn't, but it's not about you or me or them)

Here's one time-splitting scenario I think Flight Standards might want to avoid: We have a commercial trainee who is qualified to act as PIC from legal, insurance, and practical standpoints. But he is still very nervous about long cross country flights. So, instead of embarking on his own, he opts to have the CFI with with him for the long cross country. OTOH, he is comfortable with doing some local flights solo to get the rest of the solo hours and requirements and would not want to pay a CFI for that. Or maybe the reverse; perfectly happy to do the long cross country, but that night solo? Maybe not so.

With a "mix and match" rule, he pays the CFI for what he wants and doesn't pay for what he doesn't want. Trainee gets to avoid doing something he is uncomfortable with solo for a relatively small price.

Without a "mix and match" rule, the trainee has to make a choice. (a) Pay a lot for the CFI to accompany for all the solo requirements and spend a bunch of extra money, or (b) learn some self-reliance.

I suspect (WAG) the FAA wants to avoid that bad training scenario but a rule that says "supervised solo can only be used if you are not qualified to fly the aircraft solo" would be completely unworkable.

Right I get all that, but between PPL and CPL, are there people who NEVER get in the requirements for night? And also in that time period or also perhaps including training before PPL, are there people who NEVER have 5 hours night/dual with the other requirements?

Seems like the average pilot would be able to make the night hours work either dual or solo and the only thing that REALLY matters on this ruling is whether or not you take an instructor with you on your long XC. If you do, you better have the 5 hours night dual somewhere and if you don't well...same thing applies.

I took an instructor with me on my long XC, not because I was nervous but because after it I wanted to pickup some complex/dual time for the 10 hours dual/complex under 61.129(3)(ii) on the way back.

So I guess what I'm getting at is nervous people aside, it seems like this rule just makes you take a harder look at your logbook to see if you have either of the solo conditions I mentioned and if you have one but not the other..you're pretty screwed giving this ruling.

For example:

I have 5 hours solo that meet requirements, but I wanna do the long XC dual. Great, now I need to pay an instructor for 5 hours to get the night in before the long XC will be doable under the new ruling.

Or..

I have 5 hours dual and I'm sick of my instructor..I wanna do the long XC solo..but now I can't..I HAVE to take the guy..

 

[midlifeflyer]

Right I get all that, but between PPL and CPL, are there people who NEVER get in the requirements for night?

There are plenty of pilots who feel night flight involves an unacceptable level of increased risk and would not have "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" while solo.

But yeah, as you point out, there are plenty of other scenarios in which one might want to mix and match.