I may be having a brain freeze, but I am unsure of the interpretation of the commercial pilots requirements. See 61.129 https://www.govinfo.gov/content/pkg/CFR-2010-title14-vol2/pdf/CFR-2010-title14-vol2-sec61-129.pdf It says that the applicant must have 20 hours of training in the areas of operation listed in 61.127(b) (1) https://www.gleim.com/aviation/faraim/?leafNum=61.127 In there it lists specifically that the applicant must have 10 hours of instrument training. Most folks applying for the commercial have an instrument rating. So, does that mean one needs 10 hours more, specifically done for the training for the commercial rating ? I would not think so, but the rule specifically states 20 hours of training in the areas listed for 61.127b which is for the commercial. Similarly, must the cross countries be done during training for the commercial, or does what one have in his log count ? Again, I think older hours count, but the requirements for the cross country are specifically listed under the 20 hours of training for the commercial section. It also references the areas where one must receive and log ground and flight training for the commercial, and one of those areas is high altitude operation. I get the ground training, but the reg says ground and flight training. I've never heard of someone having to go to high altitude for a commercial sign off and it would preclude the planes I know are used, but how does one get around the language of the rule that says ground and flight training ? Wonder if someone can clear this up. Thanks.