61.129 (a) (3) (i)
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For commercial pilot ASEL applicant who has instrument airplane rating do they have to complete the ten hours of instrument training  required by 61.129(a)(3) (i) after successfully completing their instrument rating?  If one has completed that trainng during the instrument airplane training is it required to complete ten hours of traing, again, for the comercial training requirement.  Is there some endorsement that is required to stipiulate that the training received in 61.65 is also training required/received for the commercial ASEL.  Thank you.
2 Replies
Votes
What matters is what the instrument instructor put in the remarks blocks for the instrument rating training flights.  It doesn't have to specify 61.129(a)(3)(i) but it does have to show the training covered the required tasks, specifically, attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems.  If the instrument instructor listed those areas in the logbook entries for the 10 hours the applicant wants to count, it meets the requirement.  And because the reg says "including" those areas, not just in those areas, it's OK if other areas were covered in addition to the four specified ones,  Also note that per the letter of the regulation, it must be simulated instrument time in flight with a view-limiting device -- simulator time on the ground and actual instrument in flight do NOT count towards this requirement.

References:
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2010/theriault%20-%20%282010%29%20legal%20interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2011/theriault%20-%20(2011)%20legal%20interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2010/hartzell%20-%20%282010%29%20legal%20interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Oord-AOPA%20-%20(2018)%20Legal%20Interpretation.pdf

Moral of the story for instrument instructors: Document every task you do on each flight when making logbook entries for instrument rating training.  The more you write the better, even if you need two or more lines in the logbook to write it all out.  Or as Tom Clancy writing in the voice of Dr. Catherine Ryan said, "If it isn't written down, it didn't happen."
Votes
Hello.  Thank you very much for the clarification and references.  Yes makes sense that the training task accomplished should be recorded for each flight.  As was the case in my training.  Thanks again for help.  Oh yes and Clancy is one of my favorite writers!  John