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Can the 250NM XC required for the instrument rating per 61.65(d)(iii)(A) also count for the 100NM day dual commercial XC required in 61.129(3)(iii)?

My 250NM XC during instrument training included a leg that exceeded 100NM from the departure field. Simply put: have people been able to get away with "double dipping" on this requirement? I read a LOI stating that you couldn't apply requirements for a certificate while pursuing another certificate.

However, an instrument rating is a rating, NOT a certificate.

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    $\begingroup$ It appears that you can do that, because you would be using a portion of training with specific requirements to comply with another training with general requirements. The LOI appears to state that's ok, but the opposite is not. $\endgroup$ Jun 8, 2021 at 3:19
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    $\begingroup$ The wording DAY VFR was removed from the 61.129(a)(3)(iii) regulation in October 2009. I was about to respond that I was told it needed to be day VFR but since I did that requirement the regulation has changed. $\endgroup$
    – wbeard52
    Jun 8, 2021 at 4:08

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First, see this question for some extra context. As a general statement, you can use instrument training to count towards commercial training, but only if you can demonstrate that it met the commercial requirements.

If you look at the commercial XC requirements, you can see it explicitly requires that the training has to be to commercial standards:

(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least

[...]

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

So what does that mean for you? Well, if you can prove that your IR XC training was to commercial standards then you can double dip it. Perhaps you're at a flight school that deliberately plans and documents things that way. Or your IR instructor is willing to endorse your logbook with the remark that the IR XC was conducted to commercial standards.

On the other hand, if you did your instrument rating ten years ago and only started working on your commercial recently, it would probably be tough to "provide evidence" (as the FAA puts it) that your IR XC was indeed to commercial standards.

You could ask the DPE who'll do your checkride what they're looking for, although that draws attention to the question and you might not know which DPE you'll use. So all in all, if there's any doubt about whether your IR XC was to commercial standards, the simplest thing is simply to go fly a new, commercial XC with your instructor.

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  • $\begingroup$ How might an IFR cross country flight performed 10 years prior NOT conform to "commercial standards" by virtue of elapsed time? If the origin and destination are logged, the distance can easily be determined at any time. $\endgroup$ Oct 5, 2023 at 20:22
  • $\begingroup$ When you say "commercial standards," do you mean the list of topics in §61.127(b)(1)? These are almost identical to the list of topics for the private in §61.107(b)(1) so I'm not sure where you're getting the idea that "it explicitly requires that the training has to be to commercial standards." $\endgroup$
    – Chris
    Oct 5, 2023 at 20:53
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There doesn't appear to be anything in the regulation that says you can't double dip. The Theriault interpretation you linked to implies you can't, but it doesn't provide a source for that beyond just "see §61.127."

The Pratt interpretation explicitly rescinds that interpretation for being wrong anyway (albeit wrong in a different way), so it's not clear that there is any statement from the FAA still in force that they believe you can't double dip even with certificates.

Still, despite there being nothing saying you can't, there's not really anything you could point a DPE to to show you can, so it's probably wiser to not to so I'm case your DPE doesn't like it.

§61.127 does say that the training needs to be done on the topics listed in §61.127(b), but that shares topics with §61.65(c) for an instrument rating, so there's no reason you can't do both at the same time.

Though if you did your IR XC with a CFI-I who doesn't have their CFI-A, I suppose they wouldn't count as an "authorized instructor" for the purposes of the commercial training, which may or may not cause it not to count.

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I don't thing the term "double dipping" is even appropriate in this context: If you applied for two jobs, both of which require a bachelor's degree, would you be required to have two bachelor's degrees? Of course not.

Now, if there was a required progression from commercial to instrument, (or vice versa) it would be logical to presume that the requirements are cumulative... or that one is a prerequisite for the other. In other words, you need to fly a >250/100nm X-country to get your commercial, commercial is required before instrument, and for instrument you also need a >250/100nm X-country, therefore you need two total.

However, this is not the case. A Commercial Pilot Certificate and an Instrument Rating are completely separate and independent things. You can have either without the other.

Regulations are generally restrictive, not permissive. In the absence of a specific regulation stating that the requirements for each cannot be met by by the same event, it should be presumed that a single X-country flight that meets the requirements for both may be counted for either.

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