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FAA part 141 requirements for Commercial training

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Commercial Pilot

I am working on updating our part 141 Commercial Pilot training curriculum and am confused on the requirements in Appendix D (Commercial Pilot Certification Course).
Appendix D, 2.(b)(1) states the student must hold a instrument rating  to enroll in the commercial course (or be taking it concurrently)..
However, the 4. (b)(1)(i) states that of the 55 hours of flight training, it must include 10 hours of instrument training.  

If the student has an instrument, this training seems redundant.
Has anyone had experience with this?  Can the DPE count a students past instrument training for this requirement? 

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1 Answers



  1. Mark Kolber on Jan 20, 2023

    It does seem redundant. But the FAA’s position is that having an instrument rating does not automatically cover the commercial requirement.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Oord-AOPA_2018_Legal_Interpretation.pdf

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