Commercial rating

[Fabio]

Hello
For my commercial rating for the night requirement, can I use some of the night time that I logged when I was a student pilot doing the night xcountry with my instructor?
I am pretty sure I can but I would like to hear others opinion.
Thx for the help

 

[tonycondon]

Definitely not the Night Dual XC. Must be post Private Certificate.

 

[Jim Carpenter]

As Tony said above, no. The only thing that time can count for is towards the 250 hour overall total requirement.

 

[midlifeflyer]

They are correct. Look at the regulation to understand why.

The commercial single night dual cross country is:

61.129(a)(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least -
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(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;​

"training on the areas of operation" is a magic phrase in the regulations governing certificate and rating training requirements. It has been consistently applied by the FAA to mean that the training for this certificate or rating is different than for your prior certificates and ratings. Even if the "area of operation" sounds the same, the FAA's view is that the commercial standard is higher, so it is different.

You can see the FAA's application of this philosophy specifically applies to your question in the 2010 Theriault Chief Counsel letter. It's far from the only one.