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Commercial License 50 AATD Hrs per 61.129

Asked by: 2226 views Commercial Pilot

It seems pretty self explanatory but I need to ask the question again for clarity. 

As far as specifics, I am a private pilot with instrument rating and have accumulated around 170 hrs SE time.  Working on building time towards commercial license and understand via 61.129, I can credit 50 hrs of 250 in an AATD towards my commercial license. 

I wanted to clarify the reg; Having finished private and instrument through a 141 program, I have already accumulated 29.6 hrs in an AATD Flight Sim. Specifically I was allowed to credit sim time towards the instrument rating.

Does the 61.129 mean I can only credit 20.4 hrs of sim in the AATD for a total of 50 TT in simulator towards commercial? 

Or is it a separate 50 hrs, and I am able to log 50 additional hrs in the AATD towards my commercial license? 

Thanks for your help!

1 Answers



  1. CarsonAviation on Aug 03, 2019

    We have heard various versions of this topic asked by students from different parts of the country and we have gotten different answers from different FSDOs. The core question to be answered is, “can you count time that you already counted toward private or instrument toward commercial?”

    We had a student who left us to do his advanced ratings at ATP in Dallas tell us that ATP’s policy is that CPL training MUST BE LOGGED as CPL training in the student’s logbook, and that earlier logged time that was counted toward the PPL certificate was not sufficient as it would be lacking the endorsements that it was conducted specifically to meet the commercial training requirements of FAR 61.129(a)(3). He said that was some sort of rule that the Dallas DPEs insist on seeing in a candidate’s logbook prior to checkride.

    Out here on the west coast, we’ve sent numerous candidates in for CPL checkrides who don’t have any specific flights that endorse FAR 61.129(a)(3) in their books and the DPEs seem to not mind. I know that in a few of those cases, time that had been previously counted toward the PPL rating was counted again toward the CPL rating without issue.

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