JohnBurke

You're reading the regulation out of context.

You can fly the cross country on your own and it will credit toward your commercial certification. There is no need to do your night landings as part of a cross country flight; you can do them locally, if you wish.

The long cross country referenced in 14 CFR 61.129(a)(4)(i) need not be done at night.

The night landings in 61.129(a)(4)(ii) need not be done on a cross country flight.

https://www.ecfr.gov/cgi-bin/text-id..._1129&rgn=div8

This flight time, the 10 hours of 61.129(a)(4)(i), can be done solo, or with an instructor, but not a combination of both. The FAA Chief Legal Counsel stated in 2016 that the regulation doesn't permit doing part of those 10 hours as instruction received and the other part solo; it's either one or the other, but not both: https://www.faa.gov/about/office_org...rpretation.pdf

The FAA has held in legal interpretations that the use of the language in the regulation, where it references other regulation, must be taken into account. In this case, 61.129(a)(4) allows that the cross country and night landings may be done with an instructor or solo, but also notes that instruction received must be done to cover the requirements of 61.127(b)(1). 61.127(b)(1) regards the areas of operation required for training toward the commercial certificate. The use of this language means that the night landings and cross country should be associated with training toward the commercial certificate (as opposed to having done a long solo flight as a student pilot, for example). It also means that if the night landings had been conducted during preparation for the private, they would not count; this requirement applies specifically to preparation for the commercial.

https://www.ecfr.gov/cgi-bin/text-id..._1127&rgn=div8

Because you can do the cross country and the landings solo or with an instructor, you can do your cross country and landings now, and it will be credited toward the commercial certificate. If you had done this with an instructor in prior training, such as toward your private, it would not count toward the commercial, as it must be on the areas of operation in 61.127(b)(1), meaning it must be done in commercial training. In this case, you're asking about doing it solo, as a private pilot: you can go do the landings now if you like, and the cross country. You do not need to do the night landings as part of a cross country flight, and you do not need to do the cross country flight at night.

The intent of the regulation is that your long cross country flight and your night landings are done in conjunction with your training for the commercial pilot certificate, that those requirements are met while you're receiving your instruction, and training to a higher level of certification.

If you choose to do the cross country instruction, you can combine it with instrument training under the hood. The FAA chief legal counsel has noted that this is acceptable. The following legal interpretation applies, though the specific question asked regards helicopters. https://www.faa.gov/about/office_org...rpretation.pdf

Again, if you read the language of the regulation, the requirements of 61.129(a)(3)(i) are specific to the areas of operation for the commercial pilot certificate. Your training toward the private won't count: training under a hood for flight by reference to instruments as part of your private certificate, cannot be credited toward the requirements for the commercial.

That said, if you're doing your instrument rating and undergoing the necessary instruction, it will count toward 61.129(a)(3)(i). You must receive instrument training specific to 61.127(a)(1), which is commercial training, and includes performance maneuvers, slow flight and stalls, emergency operations, etc.

It's important to understand how this applies; you can get a commercial pilot certificate without an instrument rating; the instrument training requirements of the commercial pilot certificate recognize that and set minimum instrument instruction requirements that must be met by someone who does not hold an instrument rating.

Finally, while not specific to your question, the latter part of the following legal interpretation applies, because it addresses the issue of training received prior to commercial training. It points to the need to have training applicable specifically to the level of certification you're seeking. Simply put, per the prior example, training received toward the private wouldn't count toward the commercial; training for the commercial must be specific to the commercial: when you see language in the regulation which references another regulation (in this case, 61.129 referencing 61.127), it should be read that the training and time logged must be specific and applicable to that other regulation (eg, commercial).

If you're working on your instrument rating and hammering out the hours toward that, which is leading into your commercial, and your training has included the areas of operation in 127(a)(1), then you'll have met the requirements of 61.129(a)(3)(i). https://www.faa.gov/about/office_org...rpretation.pdf