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141 IR night time can be counted to 61 CPL night dual xc?

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Commercial Pilot, Instrument Rating

I have a part 61 CPL guy, who has foreign license. He got more than 1500 hours.

Based on his EASA, he converted to FAA PPL then started 141 IR.

During IR, we had a night IR xc, which is about 3.6 hours and more than 100nm.

So my question is, could this night IR xc be counted toward his 61 CPL requirement?

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1 Answers



  1. Kris Kortokrax on May 09, 2019

    I would say no, because of the wording in 61.129(a)(3). It requires that the dual for Commercial be given for the items identified in 61.127. Training under 141 for an Instrument rating would not satisfy that.

    However, look at 61.41(a). Since he has 1500 hours, he quite likely has a Commercial certificate from his country and would be able to find a night dual X-C that would meet the requirements for 61.129. Check his logbook to see if you can find it.

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