FAA issues legal interpretation that clarifies that instrument training for commercial rating must be completed in a helicopter or helicopter simulator.

14 CFR 61.129(c)(3)(i) requires a person applying for a commercial pilot certificate with a rotorcraft category and helicopter class rating to, in part, obtain at least five hours of training “on the control and maneuvering of a helicopter.  Although the regulation states that this training “may be performed in an aircraft, full flight simulator, flight training device, or an aviation training device.”  This legal interpretation clarifies that if the training occurs in a helicopter, or with a device or simulator that replicates a helicopter, that training may count towards the five hours of instrument aeronautical experience required under 14 CFR  61.129(c)(3)(i). However, instrument training performed outside of a helicopter and without a flight simulator, flight training device, or aviation training device that replicates a helicopter cannot count towards the five hours of instrument aeronautical experience that is required under 14 CFR 61.129(c)(3)(i).