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Does night time from my private pilot training count toward my commercial pilot rating?

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Commercial Pilot, FAA Regulations, Helicopter

I am getting close to getting my commercial pilot license for helicopters. I have a question about some of the requirements for night time. 61.129 (c)(3)(ii) states that I need 5 hours of night VFR with 10 takeoffs and landings. During my flight training for my private pilots license I had to have 3 hours of night VFR. Does this time count towards my commercial requirements?

Part 61.129 (c)(3) states that I need 20 hours of flight training in the areas listed in 61.127(b)(3) including... Which makes me think that I need to get 5 more hours for my commercial rating.

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4 Answers



  1. John D. Collins on Aug 29, 2012

    The 20 hours of flight training in the areas listed in 61.127(b)(3) have to be accomplished after you have earned your private pilot license. Since the night time is part of the 20 hours, you can’t count the time prior to earning your private pilot certificate. The time you logged for your private pilot training counts towards your time requirement in 61.129 (c)(1) and (2), but not (3) which is training specifically to meet the commercial training requirements.

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  2. Koehn on Aug 29, 2012

    AOPA covered this a while ago, and there’s another question on this topic on askacfi.com, but yes, you can count instrument time toward the commercial ticket.

    Relevant quote: The FAA’s new clarification of that LOI said in part, “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.”

    See here: http://www.aopa.org/advocacy/articles/2010/101220FAA_clarification_on_letter_of_interpretation.html

    And specifically here: http://download.aopa.org/epilot/2010/101220theriault.pdf

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  3. Koehn on Aug 29, 2012

    From the AOPA:

    The FAA’s new clarification of that LOI said in part, “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.”

    http://www.aopa.org/advocacy/articles/2010/101220FAA_clarification_on_letter_of_interpretation.html

    http://download.aopa.org/epilot/2010/101220theriault.pdf

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  4. Kris Kortokrax on Aug 29, 2012

    John’s answer to the original poster was spot on. The poster asked about using night time from his private helicopter training to satisfy requirements for a commercial helicopter rating. You post an answer concerning using instrument training time to satisfy the instrument requirements for commercial training.

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