§ 61.129 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, <b>a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot</b> that consists of at least:
...
(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
(iv) <b>One cross-country flight of at least 2 hours in a single-engine airplane in night VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure</b>
why is it commonly held that the 250 hours flight time includes time built while working towards the private certificate? Where is the delineating phrase/words within 61.129(a)(3) [or (4) for that matter] that sets a different timing standard for requirements within (a)(3) [or (4) for that matter] versus the timing for requirements within (a) itself?
If someone can show me the "after completing the private pilot" or "time prior to private certificate does not count" which appears in 61.129(a)(3) but does not appear within 61.129(a) then I'll buy the "after private" logic.