On Monday, January 27, 2020 at 4:45:54 PM UTC-8, jp wrote:
I've searched the FAA Legal Interpretation website for an answer but haven't found one I understand.

My question is:

Can any of the flight experiences that were used to qualify for a private pilot certificate be subsequently used in part or whole to satisfy the flight experience requirements for a commercial pilot certificate.

Or, must the flight experience requirements for a commercial pilot certificate occur after the applicant has acquired a private pilot certificate.

Thank you.

I agree that it may be an odd question but it's one that come up from time to time for us.

One issue is that the flight experience for the private certificate is likely done to a lower skill level (+/- 10 kts, etc.) while the flight experience for the commercial certificate is likely done to a higher skill level (+/- 5 kts, etc.). The whole thing makes my head hurt.