Originally Posted by
Twin Wasp
61.65
(a) General. A person who applies for an instrument rating must:
(1) Hold at least a current private pilot certificate, or be concurrently applying for a private pilot certificate, with an airplane, helicopter, or powered-lift rating appropriate to the instrument rating sought;
How you can get to the 50 hours x-country and 40 hours instrument instruction before you get to PVT minimums is beyond me. I seem to recall at one time there was guidance that the 3 hours instrument instruction for the PVT did not count towards the 40 required for the IR because the goals of the training were different. Not sure what the current take is on that.
Fly 50hrs PIC under solo XC endorsements and log the Instrument instruction accordingly.
I had a student solo at 16 and he took his Private on his 17th birthday and hit Instrument two days later.
And you are correct about the 3hrs Instrument requirement for the Private.