It does matter what your hours are when you come in. If one already has 130 hours, then he only needs 120 more to complete the commercial under Part 61. This is the same as most of the Part 141 courses. Part 61 is better in that you can have fun flying however you want instead of having someone telling you what to do for every single flight. Part 61 doesn't have to be unstructured, if it feels that you are flying along aimlessly on every lesson then it is the fault of the instructor, not the fault of the regulations the training is conducted under.
I am sorry; you are right in that there is a small loophole which allows a course to be certified without meeting the minimum time requirements specified in FAR Part 141. However, this is rare and Comair is the first school I've heard of to take advantage of this.
It is likely that if cookmg decides to train under Part 141, then the commercial requirement will be 120 hours, which will put him at 250 hours by the time he's done anyway (unless the school accepts his previous time, then it would be minimum of 220). Might as well cut the red tape and train under Part 61.
FTDs around here are very cheap, from free to $20/hour at the most. If cookmg lives somewhere where he can have access to one as cheaply as this, it will save him quite a bit of money. I agree, however, that it really isn't valuable time from a standpoint of gaining knowledge and experience, but if he has trouble getting the flight time he needs then it is an economical way to do it.
It is unrealistic to expect a person won't be able to complete the commercial under Part 61 in 250 hours. Most people trouble getting enough time (250 hours) to meet the requirement. Most people who go over 250 do so willingly or on purpose.
172driver said:
Where you got that info about transferring time, I don't know.
141.77(c) "A student may be given credit towards the curriculum requirements of a course for previous pilot experience and knowledge, provided...
"(2) If the credit is not based upon (experience and knowledge from) a Part 141-approved training course, the credit given that student for the previous pilot experience and knowledge shall not exceed more than 25 percent of the curriculum requirements..."