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Do my hours count towards part 141 commercial?

Asked by: 938 views , , , ,
Commercial Pilot, FAA Regulations, Student Pilot

I got my private under part 61 with 47 hours and then flew 10 hours on my own for fun. I then changed flight school and got the IR SE under part 141, doing  34.5 hours of flight training and 13.6 hours of sim until my check ride. Now I'm currently training for my SE commercial (part 141) and have so far flown 54.1 hours of training following the syllabus and 11.5 hours of sim. I have already completed the XC, NIGHT and INST requirements and have 12.8 hours of DUAL left to meet the requirements of the syllabus. I  would like to know how many of the hours I have flown before starting my commercial training count towards my commercial requirements. 

Also, what the minimum requirements would be under part 141 as my school said I need 190hours of which they will count up to 30 hours of sim time but the minimum requirements I have found say I need a minimum of 120 hours.

A breakdown of my hours are as followed:

Private - Part 61

Dual: 32.9, PIC: 14.2, Inst: 3.5

Plane rentals for fun:


Instrument Rating SE - Part 141

Dual: 46.6, PIC: 34.5, Inst:28.4

Commercial SE (on going training, same flight school as IR) - Part 141

Dual: 42.2, PIC: 54.1, Inst: 11.7

Total times:

Dual: 121.7, PIC: 102.8, Inst: 43.6, Total time: 145.4 

Thank you in advance,




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1 Answers

  1. Kris Kortokrax on May 18, 2017

    Here is a link to a legal interpretation that contains a statement that you need 190 hours of flight time for a Commercial under Part 141 instead of 250 under Part 61.


    The 120 hours to which you refer is the time required for the Commercial course. Normally, under Part 141, you would get your Private with 35 hours and your Instrument with 35 hours. 35 + 35 + 120 = 190.

    However, you did your Private under Part 61. The Commercial course undoubtedly had a prerequisite for a Private with Instrument. You met those requirements. Once you complete the 120 hours for the Commercial course, you should be eligible for the practical test with whatever hours you have, since it will be more than 190.

    The answer to your question is that none of the hours you flew prior to the 141 Commercial course counts toward the requirement for 120 hours.

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