Commercial question

[Dean]

On the 250nm VFR XC day and night, do those have to be done with a CFI? I have done a day VFR XC of that distance, but it was by myself. Will it count toward the requirement?

 

[midlifeflyer]

Read the requirement and you'll have your answer.

 

[flyingcheesehead]

On the 250nm VFR XC day and night, do those have to be done with a CFI? I have done a day VFR XC of that distance, but it was by myself. Will it count toward the requirement?

Your answer is in 61.129(a)(4)(i). Actually, it's in (a)(4).

Also, your question suggests a lack of understanding as to what is actually required. It looks like you're confusing the requirements of 61.129(a)(4)(i) with 61.129(a)(3)(iii) and 61.129(a)(3)(iv). I'd suggest you read all of 61.129 for clarification.

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

(4) 10 hours of solo flight in a single-engine airplane on the areas of operation listed in §61.127(b)(1) of this part, which includes at least—

(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

Remember, that's solo as in sole human occupant of the airplane. A trip with the family aboard doesn't count, for unknown reasons. FAA logic I guess.

 

[Dean]

Read the requirement and you'll have your answer.

I did, and the reason I asked was because I know someone who did his with his CFI, The long XC that is. I have done a 370nm trip with three stops and one leg was 254nm and was told that it wouldn't count.

 

[rmciottijr]

Remember, that's solo as in sole human occupant of the airplane. A trip with the family aboard doesn't count, for unknown reasons. FAA logic I guess.

I would say for the reason of cockpit management. If I need something like a freq. or a squawk code entered. I can ask my wife and bam she is putting it in the radio/transponder for me (if that is what I want her to do). So I can see why the FAA would want it to be a Solo flight.

Bob

 

[flyingcheesehead]

I did, and the reason I asked was because I know someone who did his with his CFI, The long XC that is. I have done a 370nm trip with three stops and one leg was 254nm and was told that it wouldn't count.

Dean,

Might there be some confusion as I noted between the dual and solo? Some folks do the dual XC's to a destination at least two hours away, stop for dinner, and then fly back at night to get both requirements handled.

The "long" one is strictly solo.

I'd suggest you take a FAR/AIM to the instructor who told you yours wouldn't count and ask him why not, after having him read the relevant section. If he doesn't come around, a talk with the chief pilot might be in order, especially if there's gonna be someone getting sent to a checkride without the proper requirements finished.

 

[gprellwitz]

The "long" one is strictly solo.

Presuming we're talking about single-engine commercial, this is true. If you're interested in multi commercial, there's another thread around talking about that.

 

[poadeleted20]

On the 250nm VFR XC day and night, do those have to be done with a CFI?

There is no such requirement. There are requirements for...

1. 300nm solo XC with a landing at least 250nm away (61.129(a)(4)(i)).
2. 2-hour day VFR dual XC with a landing at least 100nm away (61.129(a)(3)(iii)).
3. 2-hour night VFR dual XC with a landing at least 100nm away (61.129(a)(3)(iv)).

I have done a day VFR XC of that distance, but it was by myself. Will it count toward the requirement?

Insufficient data. Was it really solo (i.e., no live human being other than yourself aboard), or just without an instructor (i.e., with a non-pilot passenger). Was the total distance over 300 nm, or was it a 250nm one way trip without a return leg?

 

[poadeleted20]

I did, and the reason I asked was because I know someone who did his with his CFI, The long XC that is.

That would be correct, as the 300nm solo XC must be solo.

I have done a 370nm trip with three stops and one leg was 254nm and was told that it wouldn't count.

Was it flown solo? Was one of the landings more than 250nm from the original point of departure?

 

[SkyHog]

I still don't understand why there are dual xcs required for the commercial. As a Private Pilot, I can fly those cross countries anyways, what is the difference if there's a CFI on board or not?

 

[Steve]

FWIW, my dual comm x-c was flown at 1500' agl without reference to navaids, pilotage with a sectional only. The CFI was there to make sure I didn't turn on the nav (no gps way back then, loran was a high $ luxury).

I still don't understand why there are dual xcs required for the commercial. As a Private Pilot, I can fly those cross countries anyways, what is the difference if there's a CFI on board or not?

 

[Greg Bockelman]

I still don't understand why there are dual xcs required for the commercial.

Me either. I didn't have to do them in the dark ages when I did my commercial.

 

[EdFred]

Probably something to do with ICAO compliance so the US Commercial is the equivalent of a Euro-commercial.

 

[poadeleted20]

My guess is the FAA wants to be sure you can visually navigate XC to Commercial standards, which are tighter than Private standards, because as a Commercial Pilot, you may be called upon to do so with paying passengers.

 

[ScottM]

Where does it say that the solo 250NM XC has to be done under VFR?

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least—
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.
(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
(i) 10 hours of instrument training of which at least 5 hours must be in a single-engine airplane;
(ii) 10 hours of training in an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane rating, 10 hours of training in a seaplane that has flaps and a controllable pitch propeller;
(iii) One cross-country flight of at least 2 hours in a single-engine airplane in day VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One cross-country flight of at least 2 hours in a single-engine airplane in night VFR conditions, consisting of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
(v) 3 hours in a single-engine airplane in preparation for the practical test within the 60-day period preceding the date of the test.
(4) 10 hours of solo flight in a single-engine airplane on the areas of operation listed in §61.127(b)(1) of this part, which includes at least—
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and
(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

It definetly calls out VFR for the two dual XCs,

 

[poadeleted20]

Where does it say that the solo 250NM XC has to be done under VFR?

Other than the original poster, who was promptly informed of that misperception, who said it did? In any event, it's a 300nm solo XC, not 250nm, although most folks fly a 500nm trip by going out 250nm and then back.

 

[Ed Guthrie]

My guess is the FAA wants to be sure you can visually navigate XC to Commercial standards, which are tighter than Private standards, because as a Commercial Pilot, you may be called upon to do so with paying passengers.

Where do you find the completion standards (commercial, or private for that matter) for the x-country flight, other than distance and flight conditions? IOW, the completion standards you infer as being the FAA's reason simply don't exist. With respect to meeting x-country aeronautical experience requirements for a certficate or rating a flight is a flight so long as the flight condition (i.e. VFR or IFR) and distance criteria are met. Whether one bobs and weaves all over creation or holds to a heading/course and altitude as if on a rail, it all counts. FWIW, there may have been a correlation between the private x-country dropping from 300 nm to 150 nm and the commercial certificate picking up a longer x-country requirement, or there may have been some link to ICAO requirements, or there might be some other logic, but "be sure you can visually navigate XC to Commercial standards" wasn't the reason.

 

[gismo]

Where do you find the completion standards (commercial, or private for that matter) for the x-country flight, other than distance and flight conditions? IOW, the completion standards you infer as being the FAA's reason simply don't exist. With respect to meeting x-country aeronautical experience requirements for a certficate or rating a flight is a flight so long as the flight condition (i.e. VFR or IFR) and distance criteria are met. Whether one bobs and weaves all over creation or holds to a heading/course and altitude as if on a rail, it all counts. FWIW, there may have been a correlation between the private x-country dropping from 300 nm to 150 nm and the commercial certificate picking up a longer x-country requirement, or there may have been some link to ICAO requirements, or there might be some other logic, but "be sure you can visually navigate XC to Commercial standards" wasn't the reason.

Yeah, I thought the commercial was partly about understanding and using the aircraft's systems. I can't see anything that requires you to navigate by ground reference on the required XCs, even if there is such a requirement in the PTS.

 

[poadeleted20]

Where do you find the completion standards (commercial, or private for that matter) for the x-country flight, other than distance and flight conditions?

In the PTS:

Private (Area VII, Task A):

6. Verifies the airplane's position within three (3) nautical miles of the flight-planned route.
7. Arrives at the en route checkpoints within five (5) minutes of the initial or revised ETA and provides a destination estimate.
8. Maintains the appropriate altitude, ±200 feet (60 meters) and headings, ±15°.​

Commercial (Area VII, Task A):

6. Verifies the airplane's position within two (2) nautical miles of flight planned route.
7. Arrives at the en route checkpoints within three (3) minutes of the initial or revised ETA and provides a destination estimate.
8. Maintains appropriate altitude,​

​

±100 feet (30 meters), and headings, ±10°.​

Note the tighter standards for Commercial in all three elements -- cross-track tolerance, timing, and altitude/heading.

IOW, the completion standards you infer as being the FAA's reason simply don't exist.

What are the Practical Test Standards, then? How else does an instructor know what's good enough?

With respect to meeting x-country aeronautical experience requirements for a certficate or rating a flight is a flight so long as the flight condition (i.e. VFR or IFR) and distance criteria are met. Whether one bobs and weaves all over creation or holds to a heading/course and altitude as if on a rail, it all counts.

So, you would sign off an applicant for Private or Commercial who "bobb[ed] and weav[ed] all over creation" during a dual XC? Remember, the endorsement you sign says the applicant flies well enough to pass the practical test. How would you know about the applicant's XC nav skills unless you flew an XC or two with the applicant? I think that's all the FAA wants -- to make sure that every area/task is covered somewhere in the training.

Yes, I know the practical test doesn't cover night XC, but the CFI practical test doesn't include spins anymore, either. Yet, it's a required training event, as are night takeoffs and landings for PPL applicants, etc. In any event, the PTS's provide instructors with a clear definition of what the FAA considers the standards of performance expected of the holder of each certificate and rating.

...but "be sure you can visually navigate XC to Commercial standards" wasn't the reason.

Who in AFS-800 told you that? Note that I didn't say that's what they said -- it's a guess on my part, but a guess based on the PTS requirements.

 

[poadeleted20]

Yeah, I thought the commercial was partly about understanding and using the aircraft's systems.

"Partly" is correct.

I can't see anything that requires you to navigate by ground reference on the required XCs, even if there is such a requirement in the PTS.

There is most definitely such a requirement in the Commercial PTS -- Area VII, Task A:

1. Exhibits knowledge of the elements related to pilotage and dead
reckoning.
2. Follows the preplanned course by reference to landmarks.
3. Identifies landmarks by relating surface features to chart
symbols.
4. Navigates by means of precomputed headings, groundspeed,
and elapsed time.​

The subparagraphs of 61.129 requiring the two dual XC's do not specifically say you must navigate by ground reference, only that you fly the XC's "in ... VFR conditions." However, AFS-800 clearly stated in the no-longer-official FAQ file that they meant it had to be flown using pilotage and DR (just as is required in the PTS), and I have no reason to believe the FAA's position on this issue has changed. If you doubt that it is still required to do the two dual XC's using pilotage/DR, you should do as it says in the AFS-1 letter which de-officialized that FAQ file and ask your local FSDO for guidance.

Personally, I don't feel the necessity to ask the question, as I don't think there is any way for me to verify the applicant's preparedness to pass the Commercial Pilot PTS without doing it that way, but any instructor who doesn't feel that it is necessary to do that can ask their FSDO for the current position on this issue.

 

[Ed Guthrie]

In the PTS:

Ron, the PTS is the completion standard for the test. The PTS is not the completion standard with respect to whether or not the aeronautical experience can be applied towards the certificate requirements. You suggested that there are completion standards for the aeronautical experience. Once again, please cite your source for this claim.

What are the Practical Test Standards, then? How else does an instructor know what's good enough?

Let's be very clear on the ridiculous claim/inference that you made and are now arguing. You claim/infer that a student (be it private or commercial) must complete EACH AND EVERY HOUR OF TRAINING TO THE PTS STANDARDS OR THE TIME DOESN'T COUNT TOWARDS THE AERONAUTICAL EXPERIENCE REQUIRED. IOW, according to you, if the student flies an hour of ground reference training but the student doesn't hold PTS standards for the entire hour then the hour doesn't count towards the aeronautical experience requirements, or at least according to you any portion of the hour not flown to PTS standards doesn't count. That is indeed the ridiculous claim you have made. You stated that the commercial x-country aeronautical experience must be flown to commercial standards, as referenced in/by the PTS. Your claim is absolutely, totally, BS.

So, you would sign off an applicant for Private or Commercial who "bobb[ed] and weav[ed] all over creation" during a dual XC?

That isn't the question--not even close. The question at hand is whether or not those bobbing and weaving hours count towards the aeronautical experience. You apparently claim it doesn't. According to you the flight must be flown to commercial PTS tolerances. Hogwash. The time counts regardless of how well it was flown.

FWIW, the signatures on the 8710 and in the logbook state that the candidate is prepared to pass the test--but we aren't discussing being ready for the test--we are discussing the aeronautical experience requirements. The aeronautical experience stands on its own--it either occurred or it didn't—how well flown or how poorly flown is not a factor nor a criteria regarding whether it meets the aeronautical experience or not. IOW, despite your misinformation, there is no completion standard for any of it. The PTS has nothing to do with whether or not the aeronautical experience of, for example, a cross-country flight has been met. IOW, as I stated in my previous post, fly the distance under the right conditions and make the requisite landings and the x-country time is fulfilled--period.

 

[poadeleted20]

Ron, the PTS is the completion standard for the test. The PTS is not the completion standard with respect to whether or not the aeronautical experience can be applied towards the certificate requirements.

OK, then what do you use as the completion standard for whether or not a trainee is ready for the practical test? The issue here is not whether the time counts, but whether the trainee is ready for the test. If you don't evaluate those skills, and you don't have any standards for performance by which to determine whether the desired learning has occurred, how can you make that decision? For that reason, based on past written statements from within AFS-800, I have good reason to believe that AFS-800 was thinking along those lines when they put the "VFR conditions" line in that reg. Whether they worded it properly enough to legally require that it be done using DR/pilotage is beyond my ken (you can ask for an official legal interpretation if you want), but I know that was their intent when they wrote the reg, albeit possibly imperfectly.

You suggested that there are completion standards for the aeronautical experience. Once again, please cite your source for this claim.

Unless you can quote that alleged suggestion (accurately and completely, please), there is no need to do so, since I don't believe I ever said that.

Let's be very clear on the ridiculous claim/inference that you made and are now arguing. You claim/infer that a student (be it private or commercial) must complete EACH AND EVERY HOUR OF TRAINING TO THE PTS STANDARDS OR THE TIME DOESN'T COUNT TOWARDS THE AERONAUTICAL EXPERIENCE REQUIRED.

Again, you are putting words in my mouth. I never said any such thing. I said only that during the training process, the instructor must evaluate all areas/tasks and determine that the trainee can perform them at least to the relevant PTS standards. If you know of a way to evaulate an applicant's ability to navigate XC by DR/pilotage that without doing a cross-country flight navigating by DR/pilotage, I'd like to hear it.

IOW, according to you, if the student flies an hour of ground reference training but the student doesn't hold PTS standards for the entire hour then the hour doesn't count towards the aeronautical experience requirements, or at least according to you any portion of the hour not flown to PTS standards doesn't count.

Another false accusation -- I never said that.

That is indeed the ridiculous claim you have made. You stated that the commercial x-country aeronautical experience must be flown to commercial standards, as referenced in/by the PTS. Your claim is absolutely, totally, BS.

Since I never said that, your statement is the one that is hogwash.

That isn't the question--not even close. The question at hand is whether or not those bobbing and weaving hours count towards the aeronautical experience. You apparently claim it doesn't.

I never said that.

According to you the flight must be flown to commercial PTS tolerances.

The entire flight? No, but I do say that achievement of performance of all PTS areas/tasks to at least the PTS standards must be achieved before the training is complete.

The time counts regardless of how well it was flown.

I agree, and I never said otherwise.

FWIW, the signatures on the 8710 and in the logbook state that the candidate is prepared to pass the test--but we aren't discussing being ready for the test--we are discussing the aeronautical experience requirements.

You may be, but that is not what I was talking about. My point was merely to provide some insight into why the FAA wants those two dual XC's to be flown during commercial flight training, and why they want them flown using DR/pilotage.

At the end of the day, this is not so much about regulations as it is about instructor responsibility. You are free to do as you wish, but if you do not require your trainees to use DR/pilotage on those commercial dual XC's, and you do not demand performance to the standards of the Commercial PTS on those flights, I predict difficulties on the practical test for your trainees, with the potential for backlash from the FSDO if that becomes a trend for applicants you sign off. Choose wisely.

Ron Levy
33 years instructing
1 applicant failed

 

[midlifeflyer]

We'll be back to this exciting eposide of "The Adventures of Captain Ron and Mr Ed" after a word from our sponsors.

 

[Greg Bockelman]

We'll be back to this exciting eposide of "The Adventures of Captain Ron and Mr Ed" after a word from our sponsors.

LOL. I was thinking along the same lines.

 

[OnlyAnEgg]

Getting back to the original question, I think it has been established that the Commercial candidate must complete:
a) a SOLO x-c trip of more than 300 nm with three landings,
b) a night DUAL x-c training flight in VFR of more than 100 nm, and
c) a day DUAL x-c training flight in VFR of more than 100 nm

One supposes that the purpose of the dual flights is for training the candidate in good techniques of airplane handling, planning, and decision-making; but divining the purpose of FAA requirements is dicey at best. One also supposes that one purpose of the 300-nm solo is to assure us that the candidate can find their way across the state (or in some areas 2 or 3 states) and back w/o getting too lost. It may also give them some realistic experience in fuel management, I guess. But whatever the original reason, the experience requirements are what they are.
. And then after we complete the experience, we get the test - - unlike the order used by Mother Nature!

 

[poadeleted20]

Getting back to the original question, I think it has been established that the Commercial candidate must complete:
a) a SOLO x-c trip of more than 300 nm with three landings,
b) a night DUAL x-c training flight in VFR of more than 100 nm, and
c) a day DUAL x-c training flight in VFR of more than 100 nm

Note that the latter two flights must be more than 2 hours as well as going more than 100nm from the original point of departure -- do it in a Bonanza or a twin and the time requirement may be more restrictive than the distance requirement.