Building Commercial Time: Interpreting the CARS

There has been some discussion and confusion among some of the people I’ve talked to with regards to logging time to put towards your commercial license.

In an attempt to clear some of this up, I have put my interpretation of the CARS below. Please feel free to chime in with your comments.

The CARS state that you need 200 hours of total time for your CPL. Of those 200 hours 100 hours need to be pilot in command. The following question was asked: “Can you log time towards your CPL if you have a passenger?”

As far as I understand the answer is yes. You are pilot-in-command, therefore you can log the hours as such. However, if you are renting an airplane, is your rental PST exempt (and eligible for tuition tax credit) if you are taking a passenger up for the purposes of building commercial time? I got mixed responses from various people. From what I understand (by interpreting the CARS only) is that your rental should be PST exempt and eligible for the tuition tax credit for the reason that you are renting the plane for the purposes of building commercial time, regardless if there is a passenger or not.

Some of the ambiguousness of the CARS has to do with the fact there are no defined definitions for the terms “solo” and “pilot-in-command”. Take my next question: “Can you take a passenger on your 300nm required trip?”.

The CARS (421.30(4)(a)(ii)(B)(I)) says:

25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure;

Here the term “solo” is used rather than “pilot-in-command”. This leads me to believe that you cannot bring any passengers on that trip as it must be completed alone.

You’re probably thinking to your self: “Just don’t log a passenger in your log book for your trip!”. I thought the same. Again,looking at the CARS (401.08(2)), nowhere does it say that you need to record that you took passengers in your log book.

What is your interpretation of the CARS? Do you agree with what I’ve said so far? To summarize:

– Building time for your CPL with passengers is allowed and should be PST exempt and tax deductible from rental fees (if you are eligible).

– You must make the 300nm trip alone, with no passengers.

– There is no requirement to record if you took passengers or not in your log book. Only if you were pilot in command or not.

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4 thoughts on “Building Commercial Time: Interpreting the CARS

  1. Only one person on 300 NM cross-country?
    I think alot of the college programs would be failing to do that on all their cross-country flights. Usually it is two students, one flies there, one flies back, both satisfy the 300NM requirement for their licenses.
    If we compare Solo with Dual, Solo being without an instructor, Dual being with an instructor, it shouldn’t matter if a passenger comes with you.
    I personally took a passenger on my cross country. It is great experience to fly with someone else, especially on a trip, point to point – like a charter trip as a commercial pilot. Maybe bringing a passenger should be mandatory?
    In my logbook I had my passengers write a few comments in the “Remarks” section of my logbook. It is great now, 3000+ hours later to go back and read through it like a guestbook at an airport or a house. Who did you fly that day, what do they remember?

  2. I also have it from the horses mouth at TC. The definition of “solo” for all post-PPL flying is as opposed to “dual” instruction time. So long as it is otherwise legal to carry passengers, feel free. The only other requirement is that the flight be duly recorded in the PTR.

  3. Tom,
    Thanks. You do bring up something I totally forgot, and that’s the PTR.
    All solo flights, for the purposes of building the time needed for the CPL need to be recorded in a PTR as well as your log book.
    That’s something I’m not doing right now. I’ve only been logging time in my log book. I’ll have to go pick up a PTR and start copying my entries over before they become too numerous.

  4. Got a chuckle out of this thread that I only read today. I learned to fly at CYTZ in the pleistocene era in a Fleet Canuck. Since that time, including the past 35 years of flying outside of Canada I have logged “solo” time regardless of whether there was a passenger. If there was an instructor it was dual. Now I am getting a CFI certificate in the US, and I just learned that here, solo is just that i.e., alone in the aircraft. PIC can be solo or with a passenger. Inquiring minds at the FAA want to know which is what. I had to go back more than 45 years to clear that up for both night and day, as well as count night landings. Painful!

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