Commercial cross country requirements

[midlifeflyer]

As a question to you and all the other CFIs (@midlife flyer, @AggieMike, etc.) out there, how do you deal with students you perceive have an integrity problem? Or do you even go down that path?

I stopped doing primary training years ago (love it but can't handle the time commitment), but it can happen with everything from primary through recurrent. Fortunately it's not something I needed to deal with directly, but it really depends on how it manifests itself. There can be a tendency to rush to judgment based in very little evidence where even a little extra questioning and listening can show whether it really is an issue and, if so, how much. Same for solutions. They can range from informal counseling to saying goodbye to reporting (in extreme cases).

 

[midlifeflyer]

Unless I misunderstood the original question, the guy made a long XC with some kids -- which I would argue is functionally the same as being solo since they are only providing distractions, nothing to "helping" the pilot.

Let's explore that. Make the definition one of whether the passenger has the capacity to help the pilot. How many extra regulations, interpretations, and guidance will that require? At what age does a child become a helper? Is 3 fighting in the back ok but one in the front who is 5 and able to hold your charts and pass them to you verboten? How about adults? What if they sit in the back? Make it an Angel Flight with an ill adult and a caretaker in the back, neither of which is in a position to help. You can fly with your spouse, but only if you have just had a big fight and aren't speaking to each other.

Whether it really needs to be solo at all is a good question (I think it is based on an ICAO commercial requirement but if I recall correctly ICAO does not require it be solo). But once we accept that it's ok that someone who wants a commercial certificate may actually have to go on yet another flight to meet a solo requirement , the FAA's definition of "solo" is clear, to the point, without much room for legitimate interpretation.

 

[EvilEagle]

sigh....

It will require 1 regulation. The pilot should use judgement to determine if any passengers were assisting to the point of it not being a "solo" flight. (or something similar) Again, I'm suggesting that the FAA should let pilots use JUDGEMENT (which is a requirement to be a pilot) to determine if the people onboard are helping or if the flight could be considered "solo". Turns out, very few things in an airplane are black and white (what's the definition of a "good" landing?). I've flown with plenty of instructors and ATPs alike that were of absolutely zero help, simply having them onboard does not "help" make. Sure, FAA regulations are written in black and white and - again- I'm not saying that you can interpret them differently. I'm suggesting that it would be better to introduce some judgement into the process.

Of course someone could "just go on another flight" - that's not really what we are talking about though, right? I'm pretty sure we've beat it to death from the OP's question that the regs have no wiggle room for solo. We've been bantering back and forth about the intent / silliness / need for the rule to be black and white.

 

[MauleSkinner]

It will require 1 regulation. The pilot should use judgement to determine if any passengers were assisting to the point of it not being a "solo" flight.

Given that there are no other regs that allow a pilot to determine whether or not he met a training standard, and the number of applicant busts I have where the pilot is seemingly unaware of exceeding a testing/checking standard until I point it out (and quite frankly, most have no idea what the standards are), I can’t imagine FAA considering this to be a good idea.

YMMV, but maybe that’s a significant dividing point between military and civilian pilot trainees.

 

[RussR]

sigh....

It will require 1 regulation. The pilot should use judgement to determine if any passengers were assisting to the point of it not being a "solo" flight.

Seriously? How would that even be workable? Given your military and civilian experience, I am sure you have worked with many people of varying levels of "judgment". I know a guy who flies a Cherokee, willingly taking off into low IFR with freezing air temperatures. He has been asked about it, but in his judgment, it's safe enough. I think most would disagree.

Also, that doesn't account for the fact of help not being available, even if not used. I find that comfort blanket is a very real thing for many people. Meaning, a commercial applicant takes his ATP-rated, airline pilot, CFI uncle along for the flight. The uncle literally says nothing for the entire flight. That still doesn't mean the pilot could have made the flight without the presence of that other pilot. Just knowing that "he can bail me out if I get in trouble" can take a lot of stress off a person, and result in them making different choices. In this case, maybe it's because the pilot isn't comfortable flying by themselves. Is that what we want of a Commercial Pilot?

 

[midlifeflyer]

sigh....

It will require 1 regulation. The pilot should use judgement rather than an objective standard to determine whether the pilot meets a requirement if any passengers were assisting to the point of it not being a "solo" flight. (or something similar) Again, I'm suggesting that the FAA should let pilots use JUDGEMENT (which is a requirement to be a pilot) to determine if the people onboard are helping or if the flight could be considered "solo". Turns out, very few things in an airplane are black and white (what's the definition of a "good" landing?).

That's hysterically funny.

 

[midwestpa24]

The pilot should use judgement to determine if any passengers were assisting to the point of it not being a "solo" flight. (or something similar) Again, I'm suggesting that the FAA should let pilots use JUDGEMENT (which is a requirement to be a pilot) to determine if the people onboard are helping or if the flight could be considered "solo".

Then the instructor that endorses the candidate would have to judge the passengers, then the DPE. The FSDO and eventually FAA legal would have to weigh in on judgement. In aviation you need an objective standard. The last thing we need is the FAA using their judgement. Just look at the ATF.

Plus let's face it, people have a tendency to judge things in the way that best benefits them.

 

[Jim K]

Well, right now the candidate is exercising judgement whether or not to write the name of his atp uncle in his logbook.

 

[EvilEagle]

Man, you guys must be a blast at parties....

Given that there are no other regs that allow a pilot to determine whether or not he met a training standard, and the number of applicant busts I have where the pilot is seemingly unaware of exceeding a testing/checking standard until I point it out (and quite frankly, most have no idea what the standards are), I can’t imagine FAA considering this to be a good idea.

YMMV, but maybe that’s a significant dividing point between military and civilian pilot trainees.

So what you are saying is that he/she can be trusted to declare they are solo (where he/she could lie about it) but can't be trusted to determine the kind of passenger they have along with them because they could lie about it? C'mon man.... This just doesn't employ common sense IMO.

Maybe it is a difference between mil & civilian. You guys are quickly talking me out of ever doing much civ instruction with this discussion.

Seriously? How would that even be workable? Given your military and civilian experience, I am sure you have worked with many people of varying levels of "judgment". I know a guy who flies a Cherokee, willingly taking off into low IFR with freezing air temperatures. He has been asked about it, but in his judgment, it's safe enough. I think most would disagree.

Also, that doesn't account for the fact of help not being available, even if not used.....(clip)

You had two separate ideas there:

1) Agreed, the Cherokee driver is demonstrating poor judgement. Are you implying that the act of flying solo and passing the checkride gives the pilot a newfound sense of capability and judgement? So the day before the checkride, we can't trust them to fill out a logbook correctly but the day after they can take people up for hire?

I know of an instructor pilot/DPE that took off in his Baron in 0/0 and killed 5 people. How does that factor in?

Saying that pilots don't have good judgement so we shouldn't allow them to use judgement is just a head-in-the-sand approach. Do you think that same Cherokee pilot couldn't just as easily find a DPE that doesn't know him or his background, then give them a bogus logbook, pass the checkride and become a commercially licensed pilot? Of course he could. At some point we have to call it good based on what the applicant says happened.

YGBFSM if you think a person should be allowed to fly people for a sightseeing charter but they can't be trusted to know whether the person riding with them were providing help to them as a pilot.

2) The placebo of having someone along could make a difference. That's the first reasonable (IMO) argument I've heard for the requirement.

That's hysterically funny.

Is it as funny as thinking the FAA would put the effort in to inquire about whether someone was actually solo for one particular long XC before they went to their checkride? That too, is hysterically funny.

**break break**

This whole discussion is a S A D look at how the members our society view each other. I really fear for the future of our country and certainly for GA. Maybe you guys are right, you can't trust anyone to do anything. With that mindset, how can any pilot ever be allowed to decide when they should go flying? How can they determine if they have had enough rest, if they are really as current on emergency procedures as they should be, if the XC was really that well planned? Where is the line guys?

We are talking about someone who is already a licensed pilot and allowed to basically do whatever they want, right? Apart from self policing, a FR every other year and the odd ramp check... honestly: how often are crappy pilots approached by the FAA other than when they have accidents? Exceedingly rare in my experience.

It's no wonder people dread doing BFR's. If every instructor has the same attitude that the average pilot can't be trusted to use judgement... why are we giving them certificates in the first place?

 

[RussR]

So much to respond to in that post, I'm not sure even where to get started. So I'll respond this way.

You want to make the "solo" requirement up to the judgment of the pilot. Okay. What about the 50 nm XC requirement? A XC that's 49 nm is almost as far, and probably accomplishes the same things as a 51 nm XC, so if the pilot thinks it's good enough, in his judgment, should it be allowed?

How about the 10 night landings at a towered field? Kind of a silly requirement anyway (in my opinion), but it's there. If I think 5 is enough for me, can I just make the judgment that I've done enough?

Come on now. This is not a "mil vs civ" difference. You have standards in the military that leave no room for judgment. Thousands of them.

I think it was General Patton who said "If you can't get them to fly solo when they should fly solo and fly 50 nm XC's when you tell them to fly 50 nm XC's, how are you going to get them to die for their country?"

It's no wonder people dread doing BFR's. If every instructor has the same attitude that the average pilot can't be trusted to use judgement...

Do they dread Flight Reviews? I'm not aware of that, where do you get that idea from? I have many clients that come back to me repeatedly and even more often than required, so I'd have to guess I'm doing something right.

 

[MauleSkinner]

YGBFSM if you think a person should be allowed to fly people for a sightseeing charter but they can't be trusted to know whether the person riding with them were providing help to them as a pilot.

I don’t think somebody without a Commercial certificate should be allowed to fly charters.

 

[midlifeflyer]

I guess @EvilEagle and I just have different views of whether, once we accept there is going to be a standard, it should be objective or subjective. We'll have to agree to disagree.

I'm not sure what "fun at parties" means. No idea how arguing against objective training and testing standards in favor of personal whim is any more fun to the non-aviator cocktail crowd. Personally, I try to tell funny stories rather than discuss regulatory issues so I guess you hang out with different people than I do.

 

[EvilEagle]

So much to respond to in that post, I'm not sure even where to get started. So I'll respond this way.

You want to make the "solo" requirement up to the judgment of the pilot. Okay. What about the 50 nm XC requirement? A XC that's 49 nm is almost as far, and probably accomplishes the same things as a 51 nm XC, so if the pilot thinks it's good enough, in his judgment, should it be allowed?
<clip>
Come on now. This is not a "mil vs civ" difference. You have standards in the military that leave no room for judgment. Thousands of them.

Do they dread Flight Reviews? I'm not aware of that, where do you get that idea from? I have many clients that come back to me repeatedly and even more often than required, so I'd have to guess I'm doing something right.

That's an interesting point; we have to have a structure (rules) for required tasks in order to get a new certificate. I think we can all agree on that. Maybe it's my bias from so much solo time. I admit, being solo makes absolutely zero difference to me personally. I usually feel like an extra wheel when I'm flying with someone else. After 2500+ solo fighter hours and another 1500+ solo GA hours maybe I'm just calloused to the "challenges" of flying solo.

'Standards that have no room for judgement' you said. Yep, lots of those in aviation mil or civ. I suppose my issue with this one in particular is that some faceless bureaucrat in the FAA has made the judgement call for us all. The person who wrote that rule is saying that pilots can't decide whether the person riding with them is affecting them in a manner to be different than if operating solo. That person has judged this to be the case. It must just be the solo thing based on my experience. I don't take any issue with 50 sm (why SM, not NM?) or arbitrary numbers of other types. This discussion has opened my eyes that I have a blind spot when it comes to "solo" time and the seriousness that I give it. (personally, not professionally because rules are rules)

Apart from the placebo affect, do you really think that it's different to do a flight with someone who sleeps the entire time vs doing it solo? What if it were a guy taking a deceased person to the morgue? No snoring that way but still a person with the same inputs to the flight - flying the body would be solo and flying the sleeper wouldn't.

I'm glad you have guys that love to do FR's with you, that must mean you are giving good instruction. Bravo, we need more of that in GA for sure. Maybe it's just bad luck that I've overheard people talking about FR's. No one rants and raves about the good ones (which are probably most of them in GA) but they always moan about the "bad" ones. I haven't specifically asked a lot of people so I was probably inferring too much from some comments and threads that I've read lately. Or maybe you are just an awesome instructor and that's why people come back? Could be either or both.

I don’t think somebody without a Commercial certificate should be allowed to fly charters.

Agreed. I was trying to illustrate (poorly apparently) that the day you pass the commercial checkride, you could start flying charters the following day. This alleged XC with childredn could have been the last thing he/she did before doing the checkride. Passing the checkride doesn't bestow good judgement, if you had poor judgement the day before, you probably still have it.

I guess @EvilEagle and I just have different views of whether, once we accept there is going to be a standard, it should be objective or subjective. We'll have to agree to disagree.

I'm not sure what "fun at parties" means. No idea how arguing against objective training and testing standards in favor of personal whim is any more fun to the non-aviator cocktail crowd. Personally, I try to tell funny stories rather than discuss regulatory issues so I guess you hang out with different people than I do.

Agree to disagree. I don't think all standards - or even many standards - should be subjective. Where do we assign objective vs subjective? Not to get too philosophical. If it was completely objective - completely and totally out of the hands of the pilot - we couldn't allow them to fill out their own logbooks. Or if they did, they couldn't be used for proof that those events happened. How do you know for sure that your buddy going for his commercial certificate really did fly to that uncontrolled field 69 miles away and do two landings? What if he only did one but put two in the book? We already have subjectivity or the 'human element' in the process. Someone who would get help because they can't/won't make a XC successfully solo then log it as solo is the same type of person that would log 5 T&G's when they did 1. In practice, the entire logbook entry process could be considered subjective, even with a signature - the instructor could be unscrupulous or the student could just forge a signature.

This "solo" definition just bothers me; no one will ever convince me that person executing a long cross country in prep for a commercial certificate truly needs to be alone in the airplane to garner the necessary experience. Again, I'm willing to admit I'm likely biased. General aviation has so many up sides and travelling places is one of them. If I were king for a day, I'd encourage pilots to bring non-pilots with them on XC's to show them what GA offers (and maybe get a new student pilot out of the deal).

To be clear, I'm not saying that in practice people can just log whatever they want. If they were a student of mine, they follow the rules - even the silly ones.

My 'fun at parties' was just to keep it light. (thus the green smiley) This is definitely a 3 on 1 scenario and I was just adding some levity/good natured ribbing.

 

[midwestpa24]

That's an interesting point; we have to have a structure (rules) for required tasks in order to get a new certificate.

Thats really the way to look at it. The requirements were written from a training a new pilot from the ground up perspective. The idea being this might be their first solo trip of 250nm or more. When you do it from the perspective of an already experienced pilot such as you or I were, it almost seems silly. I know I thought it was, as was the 2 hr day/night dual XC, and even the 10 night solo landings at a towered airport. I had hundreds of hours and over 1,000 landings when I decided to "go back" and get my commercial. But when I looked back at all my landings, I had lots at night, lots at towered airports, lots solo even, but only one, one!, nighttime/solo/towered airport landing. So I jumped in the plane at twilight and proceeded to the nearest towered airport and banged out 10 (1 extra for good measure and to make it easier for the CFI and DPE to find) night landings. For those counting, that's a total of three flights I had to do to check the all the boxes for the commercial, plus 3 or 4 local dual flights to get brushed up on the required maneuvers. Compared to getting a Private or Instrument rating, that's not bad.

 

[MauleSkinner]

I was trying to illustrate (poorly apparently) that the day you pass the commercial checkride, you could start flying charters the following day. This alleged XC with childredn could have been the last thing he/she did before doing the checkride. Passing the checkride doesn't bestow good judgement, if you had poor judgement the day before, you probably still have it.

It could also be the flight home from a private pilot checkride.

(“Charters” are still a few hundred hours and another checkride after the commercial, btw.)

 

[RussR]

Thats really the way to look at it. The requirements were written from a training a new pilot from the ground up perspective. The idea being this might be their first solo trip of 250nm or more. When you do it from the perspective of an already experienced pilot such as you or I were, it almost seems silly.

Yes. This is a point that I address with all of my Commercial applicants, because most of them are aircraft owners, have flown all over the place for years, and the requirement seems silly.

But for each one of those, there are dozens of "pilot mill" applicants who have almost never been out of the local area. At the time of the solo cross country they may have less than 200 total hours, and all but the Private solos were with an instructor. So it is possible that prior to the Commercial solo XC, they have a total of 10.0 solo hours, with 5.0 solo XC time, the longest of which was just 150 nm away.

THAT's the reason for the "300 nm solo XC" in the Commercial requirements.

 

[MauleSkinner]

Maybe it's my bias from so much solo time. I admit, being solo makes absolutely zero difference to me personally.

Consider that a Commercial certificate requires around 15 solo hours, including the cross country were discussing here.

 

[EvilEagle]

I'm not saying they don't need to do XC's. You DEF need that skillset. It's just the solo part (that we've beaten to death) that irks me (in some situations).

 

[MauleSkinner]

I'm not saying they don't need to do XC's. You DEF need that skillset. It's just the solo part (that we've beaten to death) that irks me (in some situations).

Maybe you need to spend some time in civilian training to see the skill set and judgment level of the average commercial applicant.

 

[Velocity173]

So if I do the 300 NM with an instructor on board, are they allowed to assist me in any way?

 

[RussR]

So if I do the 300 NM with an instructor on board, are they allowed to assist me in any way?

Nope. Ballast CFI.

It's actually really, really hard for me to comply with this, as a CFI.

 

[Velocity173]

Nope. Ballast CFI.

It's actually really, really hard for me to comply with this, as a CFI.

Is there a CC letter that states as such or just assumed that the intent is not to assist in any way?

 

[RussR]

Is there a CC letter that states as such or just assumed that the intent is not to assist in any way?

I couldn't find a letter. May just be a popular opinion. But it makes sense - if it was actually a solo flight, the pilot would be on their own, so having the "ride-along CFI" correcting things and offering advice seems counter to the intent. Often, the process of seeing something go wrong and figuring it out yourself is way more valuable than a CFI just telling you what the problem is. (Safety permitting, of course. Obviously I'm not talking about "engine on fire" stuff here, more like "programmed the GPS wrong" or "dialed in the wrong AWOS frequency" kinds of stuff.)

But it is really hard for me to watch them unknowingly turn 90 degrees to their course (or some other obvious error) without saying anything.

I don't think there's anything prohibiting me from speaking, however (Hah, good luck with that!), so I do generally try to talk about something useful, but that is not directly related to the flight or PIC-like decisions. Since it's a Commercial applicant, a common thing is to have a discussion about Commercial pilot privileges and limitations - common carriage, holding out, Part 91 vs 135, etc.

 

[MauleSkinner]

Is there a CC letter that states as such or just assumed that the intent is not to assist in any way?

I couldn't find a letter. May just be a popular opinion. But it makes sense - if it was actually a solo flight, the pilot would be on their own, so having the "ride-along CFI" correcting things and offering advice seems counter to the intent. Often, the process of seeing something go wrong and figuring it out yourself is way more valuable than a CFI just telling you what the problem is. (Safety permitting, of course. Obviously I'm not talking about "engine on fire" stuff here, more like "programmed the GPS wrong" or "dialed in the wrong AWOS frequency" kinds of stuff.)

But it is really hard for me to watch them unknowingly turn 90 degrees to their course (or some other obvious error) without saying anything.

I don't think there's anything prohibiting me from speaking, however (Hah, good luck with that!), so I do generally try to talk about something useful, but that is not directly related to the flight or PIC-like decisions. Since it's a Commercial applicant, a common thing is to have a discussion about Commercial pilot privileges and limitations - common carriage, holding out, Part 91 vs 135, etc.

The reg says “performing the duties of pilot in command”, which for the purposes of the aircraft in question is basically “everything related to the flight”. But that’s an interpretation of the reg, so we’d probably need to go to the source to get any agreement.

IIRC, the NPRM discussed that...maybe @midlifeflyer or someone can point us to that.

 

[midlifeflyer]

IIRC, the NPRM discussed that...maybe @midlifeflyer or someone can point us to that.

If I recall correctly the long cross country was moved from the private solo cross country to the commercial in the 1997 Part 61 rewrite (the student tool was longer before then). I don't recall any extended discussion of why it was solo, but I'll check when I have a chance.

 

[Velocity173]

So if I’m reading 61.129 correctly, it would seem that either solo or flying with a CFI for the 300 NM XC is authorized. If the FAA’s intent is to have the pilot do this solo because it’s so important not to have any assistance, then why add the CFI option? Acting as PIC doesn’t mean no assistance and even if that’s the intent, that CFI is still there (insurance requirements) to make sure (assist) the flight goes as planned.

 

[midlifeflyer]

So if I’m reading 61.129 correctly, it would seem that either solo or flying with a CFI for the 300 NM XC is authorized. If the FAA’s intent is to have the pilot do this solo because it’s so important not to have any assistance, then why add the CFI option? Acting as PIC doesn’t mean no assistance and even if that’s the intent, that CFI is still there (insurance requirements) to make sure (assist) the flight goes as planned.

The CFI option was a nod to the reality that insurance companies have high time in type requirements to cover twins - far more than a non-rated pilot would have - combined by the fact that for most pilots, the commercial is the first multi rating.

 

[MauleSkinner]

If I recall correctly the long cross country was moved from the private solo cross country to the commercial in the 1997 Part 61 rewrite (the student tool was longer before then). I don't recall any extended discussion of why it was solo, but I'll check when I have a chance.

I was referring more to the role of the CFI on the “solo” flight.

 

[BrianNC]

If I recall correctly the long cross country was moved from the private solo cross country to the commercial in the 1997 Part 61 rewrite (the student tool was longer before then). I don't recall any extended discussion of why it was solo, but I'll check when I have a chance.

When I did my private pilot long solo it was a required 300NM (before '97. I didn't realize they had done that until I read what you wrote. I just assumed they reduced it to 150NM for some reason, but didn't realize they moved it to the commercial). I can't remember how long one of the legs had to be. I stopped my training for awhile and went someplace to finish it up, and my instructor hadn't put an endorsement in my logbook and had to do it again. Both of them ended up being over 400NM each.

 

[eman1200]

holy fkknuckles, this thread is still going??!!??

 

[midlifeflyer]

I was referring more to the role of the CFI on the “solo” flight.

Oh. Interestingly, no. I don't think it's mentioned as other than an insurance issue in the original, but in the 2009 amendment expanding the solo substitute to other categories, we find this (emphasis added).

Since the adoption of § 61.129, the FAA has learned that some operators of the other categories and classes of aircraft also have the same insurance policy restrictions. Many of these aircraft operators also believe solo provisions for commercial pilot certification-multiengine airplane rating is beneficial in teaching crew resource management (CRM). These provisions permit the training to be performed solo or with an instructor on board while the applicant is performing the duties of PIC in a multiengine airplane.​

 

[midlifeflyer]

When I did my private pilot long solo it was a required 300NM (before '97. I didn't realize they had done that until I read what you wrote. I just assumed they reduced it to 150NM for some reason, but didn't realize they moved it to the commercial). I can't remember how long one of the legs had to be. I stopped my training for awhile and went someplace to finish it up, and my instructor hadn't put an endorsement in my logbook and had to do it again. Both of them ended up being over 400NM each.

I did mine student solo under the old rule too. As I recall there was a single 50 NM leg included. I remember the flight better than my first solo..

 

[EvilEagle]

Maybe you need to spend some time in civilian training to see the skill set and judgment level of the average commercial applicant.

Maybe so. Although if it's as bad as you guys are making it out to be, I don't really see any upside to doing that.

 

[TimRF79]

Well, guess I should have made some stops on my recent 650NM trip....
Oh well....

 

[TommyG]

When I did my private pilot long solo it was a required 300NM (before '97. I didn't realize they had done that until I read what you wrote. I just assumed they reduced it to 150NM for some reason, but didn't realize they moved it to the commercial). I can't remember how long one of the legs had to be. I stopped my training for awhile and went someplace to finish it up, and my instructor hadn't put an endorsement in my logbook and had to do it again. Both of them ended up being over 400NM each.

That's when PPL long x country was a real x country. I still have my students to 250 to 300. Not this 150 mile garbage.