Commercial pilot ASEL experience
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What is the reasoning in the wording of FAR 61.129 (a) (4).  Ten hours of SOLO flight in SE airplanes.  Specifically as it applies to the subsection (i) for the cross country requirement of 300 nm etc.  In this case my applicant accomplised a cross country that meet all the requirements of this section but had a non pilot passenger.  So was this not "solo" flight?  The applicant for the commerical certificate was the Pilot In Command of this cross country flight(s).
6 Replies
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Yes, for Part 61 purposes, that was not a solo flight.  The FAA defines "solo" as "sole living human occupant."  Dogs and corpses are OK, but babies aren't..

As for the "why", I guess it's because the FAA wants to know for sure you can really do it all by yourself and doesn't want to quibble about the capabilities or qualifications of anyone else with you.
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Ah, ok I was thinking that was how "solo" appied in the CPL experience too.  Guess the applicant could say his passenger was dead for those six and half hours.  Just kidding!  Thanks!
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Interestingly, there has been an interpretation that the pilot can choose to log all ten hours as solo flight time in a single engine airplane or, in the alternative, log all ten hours performing the duties of a pilot in command in a single engine airplane with an authorized instructor on board. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2016/Grannis%20-%20(2016)%20Legal%20Interpretation.pdf

Furthermore, these hours must be logged while in training for the pursuit of the CPL or while training on the areas of operation listed in 61.127(b)(1).
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Prometheus is correct that there is a non-solo option to meet the requirements of 61.129(a)(4), including the long solo XC in (a)(4)(i), but it's the actual wording of the regulation, not the Grannis interpretation, which allows it.  Grannis isn't relevant to this discussion, as that interpretation merely says that the ten hours required by 61.129(a)(4) must be either all solo or all with an instructor, and not a combination of the two.  That's not the issue at hand, as the passenger in Mr. Shea's case was not an instructor, and thus that time can't be used towards any of the requirements of 61.129(a)(4) since it wasn't solo and the applicant wasn't "performing the duties of pilot in command in a single engine airplane with an authorized instructor on board".

While not relevant to the specifics of Mr. Shea's query, I would note that one question which has never to my knowledge been either asked of or answered by the FAA is whether a passenger may also be aboard while the pilot is "performing the duties of pilot in command in a single engine airplane with an authorized instructor on board."  Plain reading of the regulation suggests no bar to doing that.  Thus, it appears to me (and I'm not a lawyer so this isn't legal advice) that you can bring someone along to observe while "performing the duties of pilot in command in a single engine airplane with an authorized instructor on board."  Whether anyone wants to ask the FAA about this is entirely up to them, and I would remind anyone interested what I learned in the Air Force -- "Never ask a question if you can't stand the answer."

BTW, this particular requirement is another example of why you should continue logging solo time in addition to PIC time at least through receiving your Commercial certificate (there being no solo requirements for ATP).  If that means labeling one of the blank columns found in many logbooks as your "Solo" column, do so.  If you have one of those logbooks which has only a "Solo or PIC" column and no extra blank columns, make a "SOLO" note in the remarks section of the entry for all truly solo flights.
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Well, Grannis is relevant in the sense it helps to elevate the awareness level and adds to Mr. Shea's ability to shine at the next hanger discussion with fellow pilots.
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Prometheus At AOPA:
Well, Grannis is relevant in the sense it helps to elevate the awareness level and adds to Mr. Shea's ability to shine at the next hanger discussion with fellow pilots.

There ya go! 👍