Commercial Aeronautical Experience question

centralhome

Well-Known Member
In the Aeronautical Experience section 61.129 it says 20 hours of training on the areas in 61.127(b)(1). that include at least 10 hours instrument training, and 10 hours complex airplane training. My questions are, can you use any of the Instrument training time from the Instrument training you got for the Instrument Rating? Or does it have to be additional after you have you're Instrument Rating? And can you use the complex time you received for you're Multi-engine Rating to satisfy the 10 hours complex?
If you cannot use the previous training I assume you can mix the training together, like the 10 hours of complex time could include the (2) 2 hour VFR cross countries you have to do?
It is a little confusing because it is saying a minimum of 20 hours in areas in 61.127(b)(1), which include 10 Instrument training, 10 Complex, and (2) 2 hour cross countries. So to do it in the minimum 20 hours, you would have to combine them. So say I take a 2 hour flight and spend 1 hour on Instrument training and 1 hour on Commercial Maneuvers. Could that be considered 2 hours of Instrument training and 2 hours of areas in 61.127(b)(1)?

Thanks for any answers you can give me.
 
The interpretation by the FAA has been that if you have an instrument rating, you don't need 10 more hours for the Commercial. However, the FAQ's said that will not detract from the overall hours requirement of the certificate. Not sure if the latter is being enforced by FSDOs.

I really wish the FAA would just say we can't double count various types of training; that would eliminate much of the need to get interpretations to tell us which we can double count and which we can't.
 
The interpretation by the FAA has been that if you have an instrument rating, you don't need 10 more hours for the Commercial. However, the FAQ's said that will not detract from the overall hours requirement of the certificate. Not sure if the latter is being enforced by FSDOs.

I really wish the FAA would just say we can't double count various types of training; that would eliminate much of the need to get interpretations to tell us which we can double count and which we can't.
I know SLC FSDO is enforcing that, I had to reschedule my own checkride over this issue.
 
I know SLC FSDO is enforcing that, I had to reschedule my own checkride over this issue.
The 15 hours (at least) that you got with a double-eye during your instrument training can count as satisfying the 10 hour commercial requirement. Are you saying the SLC FSDO is not accepting that?
 
The 15 hours (at least) that you got with a double-eye during your instrument training can count as satisfying the 10 hour commercial requirement. Are you saying the SLC FSDO is not accepting that?

No, he's saying that that 10 hours doing instrument stuff on the Commercial will need to be spent doing 10 more hours of lazy eights.
 
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