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Can instrument cross countries be used towards commercial cross country requirements?

Asked by: 15637 views , , ,
Commercial Pilot, FAA Regulations, Instrument Rating

I am currently trying to finish up my commercial rating after just finishing instrument a couple months ago.  I have completed the 250 nm cross country during my instrument training but used it as my long instrument xc when I applied for my instrument rating.  Can this also be applied for my long 250 nm xc for my commercial rating?  Thanks for the help.

11 Answers



  1. Timothy Broadwater on Sep 18, 2012

    The simplest answer is, no. The long IFR cross country 61.65 (d) (2) is a dual flight and the long cross country for the commercial is a solo flight 61.128 (A) (4)(i) and must have a total length of 300NM.

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  2. CFI Academy on Sep 18, 2012

    Very interesting question. I am in a rush, so will try to reply back tomorrow, but in the meantime here is a link to 61.129, read para (A)(4)….. (Tim I am sure you were referring to the same reg, prob a typo).
    http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=45bcf39c0d9f42bacc126afe581f8398&rgn=div8&view=text&node=14:2.0.1.1.2.6.1.5&idno=14

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  3. Jason Blair on Sep 19, 2012

    The answer is no, for another reason. A specific flight requirement toward a rating or certificate can only be used toward one rating or certificate. If it was used for the Instrument, it cannot be used additionally for the Commercial.

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  4. CFI Academy on Sep 19, 2012

    Jason, I am afraid I can’t agree with you on this. Example – student pilot solo flights are counted towards commercial PIC time requirements. Instrument rating training time is counted towards 3 hours instrument training required for commercial, and so on….

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  5. Kris Kortokrax on Sep 19, 2012

    Ryan asked if he could use his 250 NM dual instrument cross country to satisfy the 300 NM solo (or baby sat, non-dual) cross country requirement for a commercial certificate. The answer to his question is an unequivocal no.

    61.129(a)(4) starts out by stating the time logged must be accrued training for the requirements of 61.127(b)(1). These are the areas of operation for a commercial certificate and must be satisfied as a requirement separate from the private certificate. If logged correctly, the instrument dual may be applied toward the commercial requirement.

    See the Murphy interpretation (Jan 11, 2011) concerning satisfying commercial requirements while still working toward the private certificate.

    In Theriault (Oct 10, 2010) Legal Counsel said that instrument training time acquired while pursuing the instrument rating could not be applied toward the commercial requirements. This opinion was question by AOPA (Dec. 17, 2010) and the FAA backed off a bit.

    Also, if you read the reg, you would see that the instrument training requirement is 10 hours, not 3.

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  6. CFI Academy on Sep 19, 2012

    we should review Hartzell (Dec 17, 2012) as well then. It all comes down to the logistics and planning. If during the IR training (61.65) the CFII covers and documents the training areas of 61.129, in that case IR training can suffice commercial TEN hours requirement.
    I find this thread getting very interesting and educational. Thanks.

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  7. CFI Academy on Sep 19, 2012

    Hartzell (Dec 17, 2010) – too bad we can’t correct typos after submitting…

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  8. Kris Kortokrax on Sep 19, 2012

    I did review Hartzell. Hartzell is the AOPA opinion I mentioned. A rose by any other name….

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  9. CFI Academy on Sep 19, 2012

    My understanding of these interpretations – it is not forbidden, or anything, it is simply a matter of planning on the part of the instructor and the student. To simply answer – NO to the question asked here would not be a correct answer.
    If the CFII, during providing the training for instrument rating, also covers the items listed in 61.129 for commercial, in that case 10 hours of instrument time for commercial training does not have to repeated.

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  10. Kris Kortokrax on Sep 19, 2012

    The question of utilizing instrument dual instruction to satisfy the commercial instrument requirement has nothing at all to do with Ryan’s question. We are in agreement that the instrument dual should satisfy the commercial requirement for instrument training.

    My NO answer to Ryan’s question is correct and I stand by it.

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  11. CFI Academy on Sep 19, 2012

    Obviously I got distracted. You are right about your answer to Ryan’s specific question. My apologies.

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