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Commercial flight training hours required

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Commercial Pilot

It looks like the requirements list 20 hours of dual instruction required for commercial flight training. I am an instrument rated pilot with 1100 hours, all aspects of the cross countries, night flying, and anything else I could tell satisfied individually. I do need training in the maneuvers  such as the chandelles etc. and I expected to have to spend 5 to 7 hours on dual instruction for this. But I’m not sure if I’m reading this correctly, 20 hours is the minimum required.   I am trying to achieve this rating just “for fun“ so 13 to 15 extra hours may put me out of the spend I want to put into this. 

 If anyone can clarify this, that would be great. By the way this is all for single-engine land. Thank you! 

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2 Answers



  1. LTCTerry on Mar 26, 2019

    Did you read beyond “20 hours?” in 61.129?

    Ten of the 20 hours are instrument training. You are IFR rated, so you “should” have credit for those ten hours. Still need ten…

    Have you done a dual, two-hour, 100-NM straight line distance day cross country? That’s two more hours, still need eight…

    Have you done a dual, two-hour, 100-NM straight line distance night cross country? That’s two more hours, “just” need six more to get to 20…

    The next section in 61.129 describes ten hours of solo or ten hours “performing the duties of pilot in command in a single engine airplane with an authorized instructor on board.” All ten must be solo, or all ten must be “simulated solo” – can’t be some of each.

    Find the instructor you want to fly with and start out by going through the FARs and your log book to determine what you need before you start any flying. Old Army saying, “Plan your work, and work your plan.”

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  2. John Scarry on Mar 29, 2019

    Depending on how it was logged, you may have enough hours of instrument training to meet the requirement:

    §61.129 Aeronautical experience.
    (3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—

    (i) Ten hours of instrument training

    The Office of the Chief Counsel issued a Legal Interpretation for David Oord in 2018 that spells out what is required.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2018/oord-aopa%20-%20(2018)%20legal%20interpretation.pdf

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