48.4 hours !?

Mark,

Good points on the need for spin training. The other thing that should
be included in the training requirement in the US for a commercial
rating is soaring training. I have seen it often where a pilot is
taught to fly the glider, but has no real world soaring training to
deal with lift and sink environments as well as decision making process
when you are not right over the airport. It is easy to fly a glider if
you take a three thousand foot tow, make a few turns and land again
without ever trying to keep the plane in the air. But are you ready to
handle adverse conditions? No, not when you get your commercial in a
total of 25 to 30 hours and need to meet the 100 flight requirement.

Tim