***Link*** :: [Oord 2018](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Oord-AOPA_2018_Legal_Interpretation.pdf) ***Description*** :: Clarification that instrument training intended for both [[IR]] and [[CPL]] must be logged appropriately. ***Author*** :: [[FAA Office of the Chief Counsel]] #### Key Quotes * while training can and may meet the requirements of both paragraphs, simply holding an instrument rating or having completed training for an instrument rating cannot be automatically assumed to meet the training required under § [[FAR 61.129 CPL Experience Reqs|61.129]] * To allow for training time to count towards both § [[FAR 61.65 Instrument Rating Reqs|61.65]](e) and§ [[FAR 61.129 CPL Experience Reqs|61.129]](c)(3)(i) in cases where it meets the requirements of both, as stated in the [[Hartzell 2010|letter to Ms. Kristine Hartzell dated December 17, 2010]], that time must be logged consistent with § [[FAR 61.51 Pilot Logbooks|61.51]] and documented in a manner that demonstrates the time counts towards the commercial pilot certificate and ratings. #source #legal-interpretation