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Commercial Pilot Aeronautical Experience Logbook Entries

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Commercial Pilot, FAA Regulations

My question relates to some that have already been asked with regard to 61.129 flight experience requirements. I am an Instrument Rated Private Pilot ASEL with just shy of 250 hours TT. Without copying the requirements of 61.129(a)(3) here, I would like to know if my Instrument training time may be counted towards the Commercial Certificate, and if my CFI may add the 61.129 notation to my logbook for flights almost a year ago. 

I earned the Instrument Rating as a Part 141 student, and have since been building time for the Commercial Certificate under part 61.

It is my understanding that 61.129 used to make mention that the XC time be done "under VFR" (http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/sun%20-%20(2011)%20legal%20interpretation.pdf). This requirement has since been removed.

This AOPA site and the LOI linked below make it seem possible. 

http://www.aopa.org/News-and-Video/All-News/2010/December/20/FAA-clarifies-commercial-pilot-instrument-requirements 

http://download.aopa.org/epilot/2010/101220theriault.pdf 

Can I ask my CFII to enter "Satisfies  61.129(a)(3)" in my logbook for XC and hood time while training for the IR, and apply it towards Commercial experience?

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2 Answers

  1. Best Answer


    Mark Kolber on Nov 10, 2013

    Since you’ve done some of the research, you know that your specific questions haven’t been formally answered. So this is strictly a personal (not legal) opinion:

    I’m going to give a very hesitant “maybe” to the amendment of the earlier instrument training flights to indicate they also met 61.129(a)(3)(i) requirements. In addition to general concerns over back-dating anything official (which means your instructor might not be comfortable doing it), I’m also concerned that your earlier lessons were in a 141 environment where flight lessons and their goals are incredibly task-specific which means the 141 school may have some very specific policies on the issue.

    As to “double-dipping” the instrument dual cross country into one or both of the commercial dual cross countries, my answer is “no.” The Theriault letter is one of a number of official and semi-official FAA comments on the use of flight training to meet the requirements of more than one certificate or rating. The key phrase to look for is “on the areas of operation” which appears in 61.129(a)(3). It generally means that the tasks referred to are specific to that certificate or rating and none other.

    In the case of the commercial instrument training requirement, the FAA softened it’s view, recognizing that instrument training for the IR was likely to meet some if not all of the instrument training requirements for the commercial (2011 Hartzell interpretation http://goo.gl/bcSPXR). But, and although the commercial dual cross countries no longer need to be under VFR, 61.127 still encompass “areas of operation” different, if not in form, than in kind, from the “areas of operation” in 61.65. Although it deals specifically with student cross countries in relation to commercial cross countries, I think the language in Theriault that the cross country must be done while training for the commercial certificate, not a different certificate (or rating). See also the 2nd half of the 2011 Murphy interpretation (http://goo.gl/GFvPVy).

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  2. Jeff B. on Nov 22, 2013

    Thanks, Mark. I looked back in my logbook and realized that I’ve covered the dual cross-country time since getting the instrument.

    I’ll be asking a follow-up question about the Instrument time, posting a new thread.

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