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2 Answers

CPL requirements

Asked by: 2186 views Commercial Pilot

Can the long 250 nm x/c required for the instrument rating [61.65 (d)(2)(ii)(A)] be used to meet the CPL requirement for the 100 nm daytime x/c [61.129(a)(3)(iii)]?  I've heard some references that you cannot "double dip".

 

Thanks...Randy

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2 Answers



  1. Mark Kolber on Dec 10, 2023

    This may or may not help, but there are a series of Chief Counsel letters on the relationship between the instrument and commercial requirements. One is linked. Those are primarily concerned with whether instrument tasks performed for the instrument rating count toward the “instrument training” required for the commercial, but the main takeaway seems to be that commercial and instrument tasks can be combined so long as the instructor documents that areas of operation of both were covered,

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Oord-AOPA_2018_Legal_Interpretation.pdf

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  2. LTCTerry on Dec 12, 2023

    I try hard to ensure Learners get all the Instrument Rating and Commercial Pilot cross country requirements completed as part of the 50 hours of XC flight. Then no need to worry about trying to double dip as it all counts towards the 50.

    It would be awful to try to convince the DPE the day of the checkride that you were good to go.

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