Easy to hard

A: Of all the questions the AOPA Pilot Information Center receives about training requirements, this one tops the list. It can be confusing, so let’s break it down into two parts. First, the easy part: To fulfill these 10 hours of required flight time, the commercial applicant can fly the long 300-nautical-mile cross-country solo, as well as the five hours at night including 10 takeoffs and landings. Solo means the pilot is the sole occupant in the airplane. Second, the hard part. The said flight time may also be done while performing the duties of pilot in command with an instructor on board. Note that this is not classified as dual time or dual flight training, as you noted in your question. Rather, the instructor is there just to serve as the PIC for the flight while the pilot in training does the actual flying as if he or she were solo. The intention was not to make this a dual flight training event, but to provide a means for the pilot to acquire the time if not properly rated for the aircraft being flown. Be aware, however, that you cannot combine solo time with instructor time to meet this requirement—you must log the full 10 hours solo or with an instructor present. This is virtually the same wording that is in 61.129(b)(4), training in a multiengine airplane. It makes more sense there as a single-engine-rated pilot flying a multiengine airplane in solo flight, while legal under 61.31(d)(2) with a solo endorsement, is probably not insurable. Hence the primary reason this regulation exists. The FAA added this wording to the single-engine airplane commercial training requirement (as well as commercial helicopter, gyroplane, powered-lift, and airship ratings), although most every private pilot training for a commercial certificate is probably single-engine rated. So, it’s really not needed here, but it is an option if insurance is not available or to foster CRM and practicing abnormal or emergency procedures. In either case, the applicant can count the time toward pilot in command flight time.

Craig Brown is a senior aviation technical specialist in the AOPA Pilot Information Center. [email protected]