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6 Answers

Commercial Instrument Training Requirements – Past Training

Asked by: 1966 views Commercial Pilot

I'm working towards my Commercial certificate and will need 5 hours of instrument training time in a single engine. I don't have my instrument and i do have recent instrument training time in a multi engine to get to the total of 10 hours.

So...can i use the 8 hours of instrument training time i logged from my private pilot training? 

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6 Answers



  1. Craig on Dec 02, 2019

    If the flight instructor who gave you that training during your ppt training had an instrument rating on his/ her instructor certificate, was otherwise qualified & documented it correctly in your logbook, then I would say YES. See the Rholfing interpretation below…next to last paragraph. While the FAA commented on in relation to the instrument rating, it would seem to apply to CPL training too.

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

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  2. Craig on Dec 02, 2019

    By documenting correctly I mean using verbiage in your logbook as listed in 14 CFR 61.129 (a)(3)(i).

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  3. David R on Dec 03, 2019

    Ah ok thanks….i got my private about 15 years ago and lost my log book. I have a medical from 2014 and some other supporting materials to recreate my hours. So sounds like i have no choice but to do the 5 hours in single instrument now. I’ve got plenty of recent hours instrument but its all in a multi and i’m working towards commercial single.

    appreciate the help!

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  4. Craig on Dec 03, 2019

    ****correcting a spelling error. It should read “Rohlfing interpretation”.

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  5. John Scarry on Dec 03, 2019

    The relevant Legal Interpretation is Hartzell https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Hartzell%20-%20(2010)%20Legal%20Interpretation.pdf which reads in part:

    The Theriault interpretation reinforces the existing requirement that instrument training used to satisfy the aeronautical experience requirements under §61.129 needs to be clearly documented by the applicant for the commercial pilot certificate. The interpretation dispels the notion that holding an instrument rating is, on it own, sufficient evidence that the applicant has fulfilled the aeronautical experience requirements for a commercial pilot certificate under §61.129. However, we anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under §61.129. The interpretation did not establish an additive requirement for the number of hours of instrument training required to meet the aeronautical experience requirements of §61.129.

    It was reiterated in Oord https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Oord-AOPA%20-%20(2018)%20Legal%20Interpretation.pdf

    To allow for training time to count towards both§ 61.65(e) and§ 61.129(c)(3)(i) in cases where it meets the requirements ofboth, as stated in the letter to Ms. Kristine Hartzell dated December 17, 2010, that time must be logged consistent with§ 61.51 and documented in a manner that demonstrates the time counts towards the commercial pilot certificate and ratings. In its letter to Ms. Hartzell, the FAA explains it is “merely clarifying the requirement that the applicant for a commercial pilot certi6eftte ~vide evidence that th~y have met the requirements of§ 61.129.”
    To summarize, if training conducted pursuant to§ 61.65(e) meets the requirements of
    § 61.129(c)(3)(i), that time can count towards the five hours ofinstrument aeronautical experience under§ 61.129(c)(3)(i). However, pursuant to§ 61.51, that time also must be logged as prescribed allowing for verification by the FAA.

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  6. John Scarry on Dec 03, 2019

    To summarize Theriault , Hartzell, Oord, and Rohlfing:

    You can use any instrument training you receive for a different rating or certificate if the instructor is instrument rated and the training is appropriately logged.

    And as a corollary to that, you can use any training for one rating or certificate provided that the instructor is appropriately rated, the training is appropriately logged, and the training occurs in an an appropriate aircraft.

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