61.129 Dual or Solo

[nonstop]

Hi guys just a quick FAR interpretation. 61.129 says you need to do a 2 hour day x-country of at least 100 miles and 2 hours of night of at least 100 miles straight line distance. It does not use the words "with an authorized instructor" like 61.129(4). Must the student meet this requirement solo or with the instructor? Any clarification will help. Thanks in advance.

 

[rframe]

It's dual as implied in 61.129(a)(3) - "20 hours of training...",
and as contrasted by the explicit "solo or PIC with supervision" requirements of 61.129(a)(4).

Also it's argued that it should be VFR cross-country training. When I went for my Com-SEL, my DPE didn't like that I had used it as an opportunity to get in some hood time, but since it doesn't explicitly say VFR in that part he allowed it but wanted me to be aware that when acting as a CFI in the future that I should use this as for VFR cross-country training scenarios, not just tracking a VOR or GPS track under the hood.

 

[Hammertime]

...it's argued that it should be VFR cross-country training.

That's because it used to specify that it be VFR until they overhauled part 61 two or three years ago. The FAA saw the light, and realized that VFR cross country training for a commercial applicant is about pointless. As far as I know a good number of large 141 schools petitioned to get this changed. Unfortunately, the aviation industry is always dragged kicking and screaming through any change. Your DPE will have to join the rest of us in the 21st century eventually.

 

[rframe]

It actually would make more sense to me if they would require it to be VFR given the scope of a COM-SEL certificate on its own. The local FSDO examiner said he's failed many CFI candidates in G1000's by dimming the display after they've been out doing maneuvers for a while and asking them to teach him how to get home and they were totally lost.

I used it for hood time toward an IPC, but honestly felt like it was a waste of time as far as the commercial check ride requirements go.

 

[unclenobby]

DUAL flight as mentioned since it falls under flight training - VFR, simulated or actual does not matter now they took VFR out of the wording, I try and incorporate the flights into instrument training and include a comment that it meets the requirements for commercial training per whatever the reg # is.

 

[A150K]

It's dual as implied in 61.129(a)(3) - "20 hours of training...",
and as contrasted by the explicit "solo or PIC with supervision" requirements of 61.129(a)(4).

Also it's argued that it should be VFR cross-country training. When I went for my Com-SEL, my DPE didn't like that I had used it as an opportunity to get in some hood time, but since it doesn't explicitly say VFR in that part he allowed it but wanted me to be aware that when acting as a CFI in the future that I should use this as for VFR cross-country training scenarios, not just tracking a VOR or GPS track under the hood.

Why Not? There is no requirement and I've never seen any FAA guidance on what they want, so it's really none of his business...My entire thing was scenario based (ABQ-TUS-ABQ, knocked out 7 of the 10 required complex hours). He handed me a mock part 135 charter and told me to plan as closely to the pax demands as possible. We went day VFR down and night IFR back (storms along the I-10 corridor and there is no way in hell I'd try to cross the redding pass VFR at night), but no hood time.

 

[MidlifeFlyer]

Why Not? There is no requirement and I've never seen any FAA guidance on what they want,

Are you aware that the rule was changed about 3 years ago and before then, there was definitely a requirement and FAA guidance saying that it (or at least most of it) had to be VFR?

A lot of folks don't keep up with this stuff so continue to think that the old rule applies. On top of that, given that the commercial practical test deals with visual maneuvers, a good number of people believe that so should the training regimen.

The DPE? We'll, they "should" be up-to-date on the regs they're working with and they "should not" require (or at least not pink slip someone for) any maneuver not included in the PTS.

 

[A150K]

Are you aware that the rule was changed about 3 years ago and before then, there was definitely a requirement and FAA guidance saying that it (or at least most of it) had to be VFR?

A lot of folks don't keep up with this stuff so continue to think that the old rule applies. On top of that, given that the commercial practical test deals with visual maneuvers, a good number of people believe that so should the training regimen.

The DPE? We'll, they "should" be up-to-date on the regs they're working with and they "should not" require (or at least not pink slip someone for) any maneuver not included in the PTS.

Yes, I am aware of the previous rule.