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Commercial Pilot Aeronautical Experience

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Commercial Pilot

I am a private pilot/single engine land with an instrument rating.  I have 530 hours and recently decided to get my commercial license.  In reviewing the flying requirements questions came up for me as to what I still need to do to meet the aeronautical experience.

I have reviewed my past flying and have the following:

(1) While training for my instrument ticket I accumulated 12 hours hood time and 8 hours simulation time.  Does this satisfy the commercial requirements of 10 hours view limiting time?

(2) I have 67 hours of cross country time with legs over 50NM?  Does this satisfy the cross country time? 

(3) I did a night cross country while working on my private license that was over 2 hours and had one leg over 100NM. Does this meet the commercial requirement even though this was done while working towards my private?

I am trying to determine what flight experience I already have that will not have to be repeated while working on my commercial.


Thanks for your help!

2 Answers

  1. Sam Dawson on Feb 06, 2013

    The training you received for your private and instrument does not count toward the specific training requirements listed in 61.129(a)(3). The flight time you have accumulated does count toward the time required in 61.129(a)(1), (2) and (4) with some exceptions.



    “In answer to your second question, are the requirements of 14 C.F.R. §61.129(c)(3)(i) met
    by the student getting an instrument rating or training for an instrument rating? The answer
    is no. The training given to satisfy the instrument training aeronautical experience of
    §61.129(c)(3)(i) may also be used to count toward the aeronautical experience of §61.65(e),but the opposite is not true. The reason for this is that the training required under §61.65(e) is general, while the training under §61.129( c)(3)(i) lists very specific operations that must be accomplished to satisfy the requirements.

    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.”


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  2. Mark Kolber on Feb 07, 2013

    One of the important parts of Sam’s answer is that, and a good way of thinking about what the Chief Counsel said in those opinion letters is, for each certificate and rating, there are three types of flight requirements. I’ll use the commercial single to illustrate them, but it applies pretty much universally for FAA certificates and ratings:

    1. General experience requirements: These can be with and instructor or without, and everything counts from your first lesson. For the commercial single, these are the 61.129(1) and (2). Notice that there are no special conditions about these flights except, for the (b) category, the FAA wants you to have logged PIC.

    2. Training requirements: “Training” is a special word. It means dual instruction; flight training with a CFI. An example is 61.29(2), “20 hours of training…”

    3. Certificate/rating specific requirements: The third is mentioned as part of the second – “…on the areas of operation listen in.” When the FAA uses that phrase, it’s a signal that these are tasks that are specific to =this= certificate or rating. Even if it seems to you that you’ve already done it for another certificate or rating, it doesn’t count for this one. The theory is, that the same flight done as a commercial student is different, at least in kind, from similar training you did for your private.

    So, for example, your night dual cross country for your private may have been long enough to meet the 61.129 requirements. But it was not “training on the areas of operation listed in § 61.127(b)(1).”

    And your “67 hours of cross country time with legs over 50NM?” would meet the general experience requirements in 129(a)(2)(ii), so long as you logged PIC time on those flights. But even if long enough, they would not meet the solo cross country requirement (“on the areas of operation”) in 129(a)(4)(i).

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