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14 CFR 61.129(a)(4) requires solo flight time or flight time performing the duties of a pilot in command with an authorized instructor on board. Time must be logged properly to ensure compliance and inclusion in the Commercial ASEL Report. Here's how to log the time in the ForeFlight logbook:

PIC Solo (No Instructor Onboard)

If the flight is conducted solo, without an instructor on board:

• Log the time as Solo
• Specify relevant flight conditions (e.g., cross-country, night, etc.).
• If the pilot is rated in the applicable category and class of aircraft, the time can also be logged as PIC.

PIC with an Instructor Onboard

If the flight is conducted with an instructor on board:

• Log the time as PIC
• Specify relevant flight conditions (e.g., cross-country, night, etc.).
• Add the instructor to the Crew & Passengers section as an instructor. The instructor is not providing instruction, so do not log Dual time.

Failure to log this correctly (e.g., adding Dual time or omitting the instructor from Crew & Passengers) will prevent the time from being included in the Commercial ASEL Report.

For more information about the FAA's requirements for logging solo time versus PIC time with an authorized instructor on board, refer to the following legal interpretations:

• Grannis legal interpretation letter - Clarifies that a pilot must choose either to log hours as solo flight time or as flight time performing the duties of pilot in command with an authorized instructor on board.
• Kuhn legal interpretation letter - Explains how the pilot performing the duties of PIC with an authorized instructor may log flight time.