ASEL Commercial Aero Experience Question
 

Quoting 61.129:


Regarding the two items in bold above (3iii & 3iv): Is there any specification on whether these two flights are supposed to be solo or dual received?

I've had one CFI tell me that because those two flights fall under 20 hours of 'training' that they are supposed to be dual received w/ an instructor aboard.

I've had another CFI tell me that it doesn't need to be flown with an instructor. I'm pursuing this information from other sources outside of APC, but still wanted to gain some input here as well.

Anyone with any good insight for me on this?

Dual only, no question about that.
see 61.1:

Training time means training received—

(i) In flight from an authorized instructor;

(ii) On the ground from an authorized instructor; or

(iii) In a flight simulator or flight training device from an authorized instructor.

Definitely dual instruction. Good news is that if you have a private pilots certificate you probably already have that requirement satisfied.

Its dual flights. Not sure where you copied that reg from but the "VFR" has been removed for a couple of years now. They can now be completed under IFR so you can do them during your instrument training. The flights do have to be completed after your private pilot check ride.

This is the current reg below. The underlined part below tells you that is has to be dual.
§ 61.129 Aeronautical experience.

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least—
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.
(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least—
(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

Yep,

As has been said; the 2 Hr flights are dual. Most usually do them on the same day and with reduced power... You might buy your CFI dinner while waiting for Civil Evening Twilight... Additionally, If you are IFR certified and current; you can do all or a portion of your Commercial X Country IFR.

I apolagize.

I misread the reg for total distance of 100nm and not as it is as total straight line distance from departure to destination.

So you probably don't have that from ppl training , but maybe instrument as yoda said.

And as everyone has said, definitely dual instruction
Cheers Jathin

No. The FAA legal counsel issued a letter of interpretation that says you can not count the private training xc toward the commercial.