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Is PPL a prerequisite in order to get credit towards Commercial for a 100nm Dual XC ( day or Night )

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Commercial Pilot, Private Pilot, Student Pilot

So.

One has to complete a dual XC of 100nm as part of the dual training requirements for the Commercial Certificate. One of the dual XCs has to be daytime, and a second night time.

A person who has earned a Sport Pilot or Recreational Pilot Certificate, is a "certificated pilot". If this person has aspirations of pursuing not just a PPL, but a Commercial certificate as well, could a 100nm dual be credited towards a future Commercial even though the person is just rated as a sport or recreational pilot?

In other words, could dual instruction on a 100nm+  XC be used for fulfilling not only some of the PPL requirements, but say the Commercial as well.

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1 Answers



  1. Jeff Baum on Aug 13, 2021

    Yes. A Private Pilot certificate is required under the Eligibility Requirements for a Commercial Certificate in 61.123.

    “61.123(h) Hold at least a private pilot certificate issued under this part or meet the requirements of 61.73;”

    “In other words, could dual instruction on a 100nm+ XC be used for fulfilling not only some of the PPL requirements, but say the Commercial as well.”

    No. 61.129 Aeronautical Experience (a)(3) requires “20 hours of training…” to include;
    “(iii) One 2-hour cross country flight in a single engine airplane in day time conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;”
    “(iv)One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;”

    The FAA General Counsel’s Theriault Interpretation states:
    “The third question in your inquiry asks whether an applicant for a Commercial Pilot CertifIcate can use the experience from a night cross-country flight that meets the requirements for a Commercial Pilot CertifIcate under 61.129(c), while the individual was training for a Private Pilot Certificate, to satisfy the requirement for night cross-country flight for a Commercial Pilot CertifIcate? The answer is no. Regardless of whether the applicant previously completed a night cross-country flight that meets the requirements under 61.129(c)(3)(iii), the applicant must satisfy that requirement while training for a Commercial Pilot CertifIcate (see 61.127), not while training for a different certifIcate.”

    Also, the FAA General Counsel’s Murphy Interpretation while addressing 61.129 states;
    “The intent is to increase applicants’ exposure to the demands and pressures of cross-country navigation under both day and night conditions, in increasingly complex airspace conditions, and at commercial pilot level standards. The FAA believes that this additional experience under flight instructor supervision will help produce better trained commercial pilot applicants.”

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