***Link*** :: [Hartzell 2010](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Hartzell-AOPA_2010_Legal_Interpretation.pdf) ***Description*** :: Training for [[IR]] does not automatically meet the instrument requirements of a [[CPL]] ***Author*** :: [[FAA Office of the Chief Counsel]] #### Key Quotes * Specifically, you questioned the statement in the interpretation that the training for an instrument rating under 14 C.F.R. §[[FAR 61.65 Instrument Rating Reqs|61.65]](e) does not meet the requirements for aeronautical experience to obtain a commercial rotorcraft certificate under 14 C.F.R. §[[FAR 61.129 CPL Experience Reqs|61.129]](c)(3)(i). * The interpretation dispels the notion that holding an instrument rating is, on it own, sufficient evidence that the applicant has fulfilled the aeronautical experience requirements for a commercial pilot certificate under §61.129. * We are merely clarifying the requirement that the applicant for a commercial pilot certificate provide evidence that they have met the requirements of §61.129. There is not an exact equivalence between the training required for an instrument rating under §61.65 and the aeronautical experience requirements under §61.129. #source #legal-interpretation