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3 Answers

complex time for commercial rating

Asked by: 2932 views Commercial Pilot, FAA Regulations

I am working on my commercial rating.  My question is about the training requirement 61.127 (3)(ii) for complex time.  Recently I have heard that the regulations have now changed where flying a TAA (Technically Advanced Aircraft) counts towards your complex time.  I flew over 10 hours in a qualified TAA during my private pilot training.  Can I count this for my commercial requirement or does it have to have been done during commercial training time?

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3 Answers



  1. Mark Kolber on Jan 15, 2020

    Dunno of an official answer on your exact s scenario, but notice that the 61.129 requirement is for training “in the areas of operation…” of commercial tasks. That is a key phrase used by the FAA repeatedly to differentiate between tasks required for different certificates and ratings. For the most ludicrous example, even having an instrument rating doesn’t *automatically* mean you don’t have to do the commercial instrument training tasks.

    In the private to commercial area, the FAA has been very consistent in saying that one cannot use pre-private tasks to satisfy commercial requirements. The don’t have to be done after some “announcement” that “I am now starting commercial training” (there’s no such thing in the Part 61 world) but they do have to be after earning the private certificate.

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  2. John D Collins on Jan 15, 2020

    I think you meant tor reference the requirements of 61.129 (a) (3) (ii) which read as:

    §61.129 Aeronautical experience.
    (a) * * *
    (3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
    (ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

    I could not find a specific opinion of the FAA General Counsel on this topic, but observe that the training for a private pilot areas of operation in 61.107(b)(1) are not identical with those specified in 61.127(b)(1), although there is considerable overlap. Also several of the areas that do overlap are to different standards and what must be demonstrated is that you meet the requirements of 61.127(b)(1) and not 61.107(b)(1). Without a FAA General Counsel Opinion on your question, I would not recommend you attempt to satisfy the commercial training requirement with training received towards the private pilot certificate. Kris Kortokrax or Mark Kolber are the experts and l look forward to their comments.

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  3. Craig on Jan 15, 2020

    Agree with the previous posters that you might not be able to apply your PPT time to the CML time. The Murphy 2011 interp next to last paragraph is one of the legal interpretations to which the others may have been referring.

    faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Murphy%20-%20(2011)%20Legal%20Interpretation.pdf

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