CPL Long X-Country Question

[AA34]

Yes to the bold. It doesn't necessarily have to mention 61.129 but that's the easiest and cleanest way to document that both were covered for the instructor and the applicant and DPE reviewing the logbook.

This is from a series of Chief Counsel opinion letters beginning in 2010. The first was a "no double dipping" opinion on the usual theory that the "areas of operation" are covering, if not quantitatively, qualitatively different things. Completely ridiculous. The second softened it, saying the entry should refer to both the 61.65 and 61.129 requirements. The most recent, the 2018 Oord letter, ciders the history as well as the current rule.

This is great info. Thank you very much.
I am going to go back and have my CFII notate “61.129a3(i)” in the remarks section for dual flights during instrument training that will suffice for the commercial requirements. I’m hoping this will be enough? I’ve got the question out to local DPE’s as well.

 

[MidlifeFlyer]

This is great info. Thank you very much.
I am going to go back and have my CFII notate “61.129a3(i)” in the remarks section for dual flights during instrument training that will suffice for the commercial requirements. I’m hoping this will be enough? I’ve got the question out to local DPE’s as well.

I suspect most DPEs think the whole thing is silly and will be thrilled you are making the effort to be compliant with the technicalities. Personally, I'd note "per 61.65 and 61.129."