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Can I use 3 Instrument hours from PPL towards IR?

Asked by: 1995 views Instrument Rating

If I have 3 hours of Instrument time during my part 61 Private Pilot, can I use that 3 hours towards 40 hours Instrument during my part 61 IR training? 

For example, one of the IR requirements are 40 hours instrument, which 15 hours dual with CFII.  If I complete all 15 dual, which 15 + 3(from private), does this mean I only need 22 hours remaining to meet 40 hours?  

Or those 3 hours don’t count at all?

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2 Answers



  1. John D Collins on Jun 12, 2019

    See this FAA general counsel opinion https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2016/rohlfing%20-%20(2016)%20legal%20interpretation.pdf

    I think this is mostly a technical point, but even if it can be used towards meeting the IFR rating, not many students are going to be ready for the practical test in the minimum 40 hours.

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  2. Hee on Jun 12, 2019

    Thank you.
    The letter you’ve attached is helping me a lot to answer my question clearly. I will definitely add 3 hours towards 40 hours, but need 15 hours of Instrument training from CFII.

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