FAA NOT accepting Private IFR time for CPL

[S-Works]

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/Theriault.pdf

Interesting interpretation.

[IO540]

All the Commercial training is done to higher tolerances than the equivalent Private training.

In one way this is common sense.

And it won't affect many people because almost nobody is going to have a 150nm x/c night flight with an instructor in their logbook, which they just happened to have done years ago.

Especially in Europe where most airports close early so knocking off a 150nm night flight (departure @ sunset+1hr not sunset+30mins) involves putting the instructor up in a hotel for the night (as I well know :) ).

It would be a problem if it was extended to other stuff, because it would make a mockery of the FAA's explicit acceptance of non-US training with non-US instructors.

Ultimately it would make it impossible to get a standalone US PPL on the basis of UK PPL training done say 10 years previously (which is standard practice in the USA, otherwise you would have to log 40hrs out there). This kind of stuff would make US training deeply unattractive and would hit the US training industry because a large bit of that business involves making use of previously acquired logbook entries.

You don't go to the USA to do say an FAA CPL/IR having burnt all your previous logbooks first :) (if you want to burn your old logbooks, you do the JAA CPL IR ;) ).

I was once offered, by an FAA CFII, (but did not pursue due to unrelated reasons) combining the FAA PPL night flying logbook time with the 250nm IFR x/c which is required for the IR, and doing it all in a single flight. In principle I can't see why that would not be legal - if one already holds another PPL which makes the VFR portion legit in the relevant airspace, etc.

[englishal]

I had an IR before the CPL so it was a non issue. In fact because I had a private ME/IR prior to the CPL ME IR then I didn't even have to shoot an approach in the ME aeroplane during the CPL ME flight test to get instrument privileges.