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4 Answers

Commercial Dual Cross Country – Can I use Instrument Rating Long XC?

Asked by: 2911 views Commercial Pilot

Can I count the Long XC that I used for my Instrument Rating as my daytime, dual, 2 hr., 100+ miles to destination xc for my commercial rating.  It was logged under Simulated Instrument Conditions but appears to meets all criteria in 61.129.  The reference to 61.127(b)(1) is what is causing me to second-think this and maybe going on another dual XC just to be sure.  Thanks!    


(3) 20 hours of training on the areas of operation listed in Sec. 61.127(b)(1) of this part that includes at least--

[(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;]

(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;

[(iii) One 2-hour cross country flight in a single engine airplane in daytime 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; and

(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test.

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4 Answers

  1. Mark Kolber on Jan 29, 2014

    How is “maybe” for an answer?

    The use of instrument training requirements to also meet commercial training requirements is not completely verbotten as it is with using student flights to meet the training requirements for advanced certificates and ratings. And it has never been uncommon for one to work on both at the same time — even Jepp has a syllabus and coursebook that combines the two.

    The key is whether your CFI is willing to go on record and say as part of the instrument cross country flight lesson endorsement that it met the requirements of both 61.65 and 61.129, that in addition to covering “the areas of operation” in 61.61(c), it also covered the “areas of operation” in 61.127(b)(1).

    The FAA uses the “areas of operation” language to differentiate requirements, and it is used both literally (they read the same in the requirements) and qualitatively (commercial pilot level tasks are presumed to be qualitatively different from student pilot level tasks).

    The FAA Chief Counsel has gone on record with a pretty strict “no” about student pilot tasks be used later for advanced “areas of operation” requirements but has provided some wiggle room with respect to instrument tasks. Compare the Murphy (no student task “double-dip”) at http://goo.gl/GFvPVy with the more liberal instrument training rule in the Hartzell one at http://goo.gl/bcSPXR

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  2. Mark Kolber on Jan 29, 2014

    Weird how my answer shows up as no answer at all. Maybe they’re trying to tell me something? 🙁

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  3. Wes Beard on Jan 29, 2014


    You’re first answer has hyperlinks that needed to be approved before the general public saw the answer.

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  4. Mark Kolber on Jan 30, 2014

    Thanks Wes. I wasn’t aware it worked like that.

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