There's a kicker in all this.
There are a series of answers in the Part 61 FAQ that indicates an FAA policy to =not= permit any Student Pilot experience to be used to meet later requirements. The theory is that task that are done "on the areas of operation" for one certificate, although similar, are =not= the same as the tasks for the other. In simple terms, the "short field landing" required for the Private is not the same as the "short field landing" for the Commercial.
Here's an example:
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QUESTION 1: Must the training specified in § 61.129(a)(3) be accomplished after a private certificate is acquired and the decision was made to start commercial training?
ANSWER 1: Ref. § 61.123(e)(1) and (f); YES. The training must be accomplished after getting a private pilot certificate FIRST. And also look at the words of § 61.123(h). We didn't specify the category and class of the rating, it only requires the applicant hold a private pilot certificate first.
§ 61.123(e) states: Receive the required training and a logbook endorsement from an authorized instructor who:
(1) Conducted the training on the areas of operation listed in § 61.127(b) of this part that apply to the aircraft category and class rating sought; and
(2) Certified that the person is prepared for the required practical test.
Properly endorsed training per § 61.123 would certainly seem to indicate someone has made a decision to start commercial training.
§ 61.123(f) states: Meet the aeronautical experience requirements of this subpart that apply to the aircraft category and class rating sought before applying for the practical test;
An applicant cannot use pre-private pilot training to also be used to meet the commercial training requirement. The applicant must FIRST hold a private pilot certificate. Remember the "building-block" concept of training.
QUESTION 2: Can the solo experience as a student pilot be used to be eligible for the private pilot certificate requirements also be used for commercial requirements if they meet those as required by § 61.129(a)(4)?
ANSWER 2: NO. Like the dual training, the solo (training) for the private certificate applies to that certificate only. An applicant who FIRST holds a Private Pilot Certificate could use POST private pilot certificate aeronautical experience that meets requirements of § 61.129(a)(4) acquired before formally starting commercial training as long as it is documented in a logbook or training record and the aeronautical experience was actually SOLO.
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