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A person applying for a U.S. airplane instrument rating must have at least 3 hours of flight training on the control and maneuvering of an airplane solely by reference to instruments. This training can be given by a Certified Flight Instructor Airplane - CFIA (without an Instrument Instructor Rating - CFII).

To obtain an instrument rating the pilot must have 40 hours of actual or simulated time of which 15 hours must be "dual received" from a CFII. The remaining 25 hours of actual or simulated time do not have to be "dual received" by a CFIA or CFII (these hours could be with a Safety Pilot, CFIA or CFII).

SCENARIO: During the PPL flight training all of which was conducted by a CFIA, the pilot received 7 hours of flight training (dual received) on the control and maneuvering of an airplane solely by reference to instruments (which is 4 hours more than the minimum required 3 hours). None of this "dual received" time, since given by a CFIA, can be credited towards the 15 hours of flight training required to be given by a CFII for an instrument rating.

QUESTION: Can the entire 7 hours (not just the 3 hours minimum required for the PPL) of flight training (dual received and logged as given by a CFIA) on the control and maneuvering of an airplane solely by reference to instruments during the pilot's PPL training be credited towards the 25 hours of actual or simulated instrument time required by FAR61.65 (d)(2) [reference shown below]? (Again, not part of the required 15 hours that must be given by a CFII)

REFERENCE

Training for PPL (pertinent portion of the U.S. FAR regulation)

61.109 Aeronautical experience.

3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight; (emphasis is mine)

Training for Instrument Rating (pertinent portion of the U.S.FAR regulation)

61.65 – Instrument rating requirements.

(d) (2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:(emphasis is mine)

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Per the Rohlfing (2016) interpretation you can indeed count the private time in the way you described:

Therefore, the 3 hours of flight training on "the control and maneuvering of an airplane solely by reference to instruments" in § 61.109(a)(3) may be applied toward the 40 hours of actual or simulated instrument time under § 61.65(d)(2), but may not be applied toward the 15 hours of instrument training unless the flight instructor who provided the flight training under § 61.109(a)(3) held an instrument rating on his or her flight instructor certificate and otherwise meets the requirements of § 61.65.

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  • $\begingroup$ I'm familiar with this interpretation, but what about the full 7 hours of time (per my question) during PPL training (not the minimum required 3 hours) being similarly credited towards the 25 hours of non-CFII time for an instrument rating? $\endgroup$
    – user22445
    Commented Nov 18, 2021 at 19:45
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    $\begingroup$ I don't immediately see a reason why the additional 4 hours couldn't be counted in the same way, unless you found something in your research? 61.109 says "at least" 3 hours, meaning it's a minimum and not a fixed amount of time. $\endgroup$
    – Pondlife
    Commented Nov 18, 2021 at 19:56
  • $\begingroup$ I think the full 7 hours can be credited (towards the 25 hours in question [not the 15 required to be given by a CFII]). This would mean that a CFIA gave and logged dual instruction to an instrument pilot-in-training. In past ASE similar questions not everyone has agreed with this position. So I'm hoping someone can find a clarifying and definitive answer. $\endgroup$
    – user22445
    Commented Nov 18, 2021 at 20:06
  • $\begingroup$ @ymb1 I agree. I'm looking for answer that addresses the 7 hours specifically. I do believe the 7 hours would count though based on the general wording of the Rohlfing interpretation. $\endgroup$
    – user22445
    Commented Nov 23, 2021 at 13:51
  • $\begingroup$ @757toga: I understand, but the fact remains, for a definitive answer to the 7 hours specifically, we need another legal case. Or, Law.SE can help with the legal wording of both the regs and Rohlfing assuming they're open to interpretation. $\endgroup$
    – user14897
    Commented Nov 23, 2021 at 13:54

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