***Link*** :: [Kuhn 2014](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2014/Kuhn_2014_Legal_Interpretation.pdf) ***Description*** :: logging flight time for [[CPL]] when completing certain requirements with instructor onboard ***Author*** :: [[FAA Office of the Chief Counsel]] #### Key Quotes * You asked several questions concerning crediting required flight time under § [[FAR 61.129 CPL Experience Reqs|61.129]](a)(4) by performing the duties of pilot in command ([[PIC]]) in a single engine airplane with an authorized instructor on board instead of performing this required flight time as solo flight time. * Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received. #source #legal-interpretation