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Combined Private Pilot Instrument Certification

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Student Pilot

My question is about FAR 61.65(g)(1).  How do you apply the “up to 45 hours of cross-country flight time” credit?

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1 Answers



  1. Kris Kortokrax on Jan 25, 2020

    I would advise you not to pursue this course of action.

    61.65(d)(1) requires 50 hours of cross country PIC time for the instrument rating.
    61.65(g)(1) allows you to credit 45 hours of time flying with an instructor to be credited toward the requirement. Combined with the 5 hours of solo (PIC) cross country required for the Private, it totals to 50 hours.

    Read the Kuhn legal interpretation:
    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2014/Kuhn%20-%20(2014)%20Legal%20Interpretation.pdf

    Although the question was asked about 61.129(a)(4), the language in 61.65(g) is the same.
    “performing the duties of pilot in command with an authorized instructor”
    The interpretation does not allow you to log PIC, unless you are rated for the aircraft (which as a student, you would not be). It also does not allow you to log dual instruction.

    Further, when you get ready to pursue the Commercial, you need to meet the requirements of 61.129(a)(2), which requires 100 hours of PIC and 50 hours of cross country PIC. There is nothing in 61.65 that would allow you to credit the 45 hours for the requirements of 61.129.

    For the combined Private & Instrument, you also take one checkride for both ratings at the same time. It is an all or nothing proposition. If you were to complete the maneuvers for the Private successfully and fail one of the Instrument maneuvers, you get nothing.

    A much better course of action is to complete the Private first. Then, while you are getting dual for the Instrument, you are logging PIC time. While doing any cross country for the Instrument, you are logging cross country PIC. When it comes time to do the Commercial, you will either meet the requirements or at least be much closer.

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