I'm completely flabbergasted by this thread! How could any flight school/ CFI-MEI possibly be confused on this issue, let alone any examiners or FSDOs? The requirements in the FARs are pretty simple to understand an initial commercial student whether single-engine or multi-engine needs a minimum of THIRTY (30) Hours of training for the initial commercial certificate. Twenty hours of dual instruction and ten hours of solo flight. The solo flight can be done with an instructor on board but still needs to be done as a "solo" with the student "performing the duties of a pilot in command."
The requirement for solo/PIC time in a multi-engine aircraft is a separate requirement from the 20 hours of dual training:
61.129(b) 250 Hours total flight time including at least:
61.129(b)(1) 100 hours in powered aircraft, 50+ in airplanes,
61.129(b)(2) 100 hours PIC, 50+ in airplanes, and 50+ cross country, 10+ in airplanes,
61.129(b)(3) 20 hours dual flight instruction,
61.129(b)(4) 10 hours solo flight or 10 hours performing the duties of a pilot-in-command with an authorized instructor on board.
The dual requirements and the solo requirements are two distinctly separate requirements. It is impossible, not to mention, completely ridiculous to infer that since the twenty hours of dual instruction were done with an instructor on board that the solo requirements were somehow completed. If that were the case the solo requirements would be completely superfluous and 61.129(b)(4) could simply be removed.
At a minimum, an initial COM-AMEL student would need a minimum of 25-30 hours of flight time in a multi-engine airplane because only 5 hours of the 10 hours of instrument instruction needs to be done in a multi-engine airplane, but it's still at least 20 hours of dual instruction and 10 hours of solo flight time for a total of 30 hours of which 25 hours has to be done in a multi-engine airplane.
To make it clearer imagine this scenario:
An instrument rated single-engine private pilot wishes to upgrade to an initial commercial multi-engine while concurrently obtaining a type-rating for a Learjet 45 which requires a crew of two pilots. The pilot completes a minimum of 20 hours of dual instruction (15 hours if the commercial instrument requirements were completed and logged for the instrument rating) in a Lear 45 while concurrently training for the type-rating. The pilot would also need to log 10 more hours of "solo" flight in the Lear "performing the duties of the pilot-in-command" while the instructor serves as the "second in command" since the Lear requires a crew of two.
It's this allowance in the FARs that allows flight schools to satisfy the insurance requirements by allowing the instructor to remain on board during the students "solo" flights even if it's a single-pilot airplane.
