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Can I count all of my flight hours that I gained from part 61 and 141 towards a part 61 commercial license?

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Commercial Pilot, FAA Regulations, Instrument Rating

Hello CFI(I)’s

I am curious to see if I can count all my training hours, solo time, night hours, sim (FTD) hours, and cross country hours that I’ve gained so far towards my commercial license. 
I did my private license at a part 61 school. 
I’m doing my IFR at a part 141 school and I’m looking into going back to part 61 for my commercial license.
I also am planning on doing 14 hours of sim time on a FTD towards my IFR rating at the 141 school I’m doing my IFR at. 

I just want to see if I can count all those solo hours, sim hours, cross country hours, dual training hours, night hours, and any other hours I may have that qualify towards my aeronautical experience requirement for the SEL commercial license. I know I need a total of 250 hours and some time in a TAA and 3 hours of instruction that are in preparation for the practical test, but can I include everything else towards my commercial ticket? 

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1 Answers



  1. Mark Kolber on Mar 29, 2020

    All FAA certificate and rating qualifications have two different types of requirements. General experience requirements and rating-specific training requirements. You can identify the rating-specific requirements by the words, “training on the areas of operation…”. If you read through 61.129 you will see both types.

    Your prior logbook entries all count toward the general experience requirements.

    For the most part, prior training aimed at meeting the requirements for a “lower”. certificate or rating does not meet the “areas of operation” requirement. There are exceptions, particularly in the instrument requirements. The CFI who will be doing your commercial training is in the best position to determine that,

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