In response to a request from the Aircraft Owners and Pilots Association, the FAA recently issued a clarification of an October 8, 2010 letter of interpretation (“LOI”). The LOI stated that the training for an instrument rating under FAR 61.65(e) does not meet the requirements for aeronautical experience to obtain a commercial pilot certificate under FAR §61.l29. However, the clarification confirms that, as long as the logged instrument flight training indicates that it meets the requirements for both the instrument rating and the commercial pilot certificate, that training can be used to meet the requirements of FAR §61.l29.
The clarification specifically states that “we anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will meet at least some, if not most, or quite often, meet all the requirements for instrument aeronautical experience as required under §61.129.” The clarification goes on to note that the LOI “did not establish an additive requirement for the number of hours of instrument training required to meet the aeronautical experience requirements of §61.129.”
Thus, it is important that an airman training for his or her instrument rating and that airman’s flight instructor be sure that instrument training is logged to reflect that the training meets both the requirements of FAR 61.65 and FAR §61.l29. This will meet the FAA’s requirement that the instrument training used to satisfy the aeronautical experience requirements under FAR §61.l29 is “clearly documented,” and it will hopefully avoid any questions about the training’s applicability if the airman later decides to train for his or her commercial pilot certificate.