What Sport Pilot Airplane Single-Engine Land (ASEL) “flight time” and “dual training” aeronautical experience can be applied to requirements for a Private Pilot ASEL certificate?

This is a two part answer and depends on the ratings held by the CFI you train with.

Part 1

If the CFI who provides the training is a Subpart H flight instructor (able to train private and sport pilots), all the training time in a Light Sport Aircraft (LSA) or heavier non-LSA CAN be applied to aeronautical experience towards a private pilot certificate.

Part 2

For an applicant being trained by CFI Sport Pilot Flight Instructor operating under Part 61 Subpart K:
20 of the total 40 hours “flight time” requirement may be applied to a private pilot certificate.

This can be the 10 hours of solo time before or after the a sport pilot certificate is issued and an additional 10 hours of “flight time” which can be solo time or dual training before the sport pilot certificate is issued plus solo and pilot time after a sport pilot certificate is issued.

The additional 20 hours of “dual training with an authorized instructor” flight time must be completed by a CFI Part 61 subpart H flight instructor (able to train private pilots).

This additional 20 hours “dual training with an authorized instructor” for private pilot typically includes the required:

    • 3 hours of night flight training per 61.109 A 2
    • 3 hours of instrument training per 61.109 A 3
    • 3 hours of preparation for the checkride per 61.109 A 4

That is 9 hours total with the additional 11 minimum hours of authorized instruction by CFI Part 61 Subpart H required would typically consisting of:

      • Additional time above the minimum 9 hours requirement above for night, instrument and checkride prep,
      • Towered airspace operations, radio communications and ATC light signals (at towered airports),
      • Navigation systems and radar services (VOR, DME….),
      • Items listed in 61.107 (b) (1)

In summary, for an applicant trained for a Sport Pilot certificate by a CFI Sport flight instructor, 20 hours of the required 40 hours “flight time” can be applied to a private pilot certificate. Typically it would take an additional 20 hours of dual training, anyway, for the night, instrument, towered airspace operation/communications,VOR/DME radio navigation, and checkride preparation after a Sport Pilot certificate is obtained.

Information for this explanation was derived from an interpretation prepared by Paul Greer, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the General Aviation and Commercial Division (AFS-800) and the Light Sport Aviation Branch (AFS-610) of the Flight Standards Service in a letter dated July 24, 2009 of which the highlights starting on page 3 last paragraph are:

Although flight training provided by a flight instructor with a sport pilot rating and airplane, rotorcraft, glider, or lighter-than-air category aircraft privileges CANNOT be credited toward the flight training requirements for a Private Pilot certificate, the FAA notes that solo flight training obtained in pursuit of the Sport Pilot certificate may be credited toward the solo flight training requirements for the Private Pilot certificate, provided any requirements for that flight time to be obtained in a specific category and class of aircraft are met. Additionally, flight time obtained in a certificated aircraft prior to the issuance of a Private Pilot certificate, regardless of whether that flight time was obtained prior to, or after, the issuance of a Sport Pilot certificate may be credited toward the flight time requirements for
the issuance of the private pilot certificate.

An applicant for a Private Pilot certificate may therefore use flight training provided in accordance with this interpretation to meet the applicable aeronautical experience requirements specified in § 61.109 for the issuance of a private pilot certificate.

If you have additional questions regarding this matter, I’ve been advised you are free to contact the Assistant Chief Counsel, Regulations Division (AGC-200) at your convenience at (202) 267-3073.

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