Commercial Rating X-C requirements

[jdwatson]

There are 3 X-C flights required for the Commercial Rating: (FAR 61.129)

0) Solo X-C
> 300NM with landings at 3+ points
one of which is 250NM straight from point of departure.

1) Dual Day VFR
> 2 hours in day VFR
straight line > 100NM from point of departure in class

2) Dual Night VFR
> 2 hours in night VFR
straight line > 100NM from point of departure in class

Do the VFR flight needs to be 2 hours out and 2 hours back ? Or a total of 2 hours ? Could one fly 1 hour to an airport 100nm+ away, eat lunch and then fly back and have it count ?

 

[Greebo]

Do the VFR flight needs to be 2 hours out and 2 hours back ?

No.

Or a total of 2 hours ?

Yes.

Could one fly 1 hour to an airport 100nm+ away, eat lunch and then fly back and have it count ?

Yes. You can log it as one flight simply as a round-robin like MTN - AGC - MTN - just don't try to include the hour lunch in the total. HOBBS Time only

 

[wsuffa]

There are 3 X-C flights required for the Commercial Rating: (FAR 61.129)

0) Solo X-C
> 300NM with landings at 3+ points
one of which is 250NM straight from point of departure.

1) Dual Day VFR
> 2 hours in day VFR
straight line > 100NM from point of departure in class

2) Dual Night VFR
> 2 hours in night VFR
straight line > 100NM from point of departure in class

Do the VFR flight needs to be 2 hours out and 2 hours back ? Or a total of 2 hours ? Could one fly 1 hour to an airport 100nm+ away, eat lunch and then fly back and have it count ?

The duals need to be a total of at least 2 hours flying time each with a destination of >100 miles from the point of departure. No reason you can't fly an hour to an airport 120 miles away, have lunch & refuel the plane, then fly back.

 

[EdFred]

Total of 2 hours.

Here's a better one. Can 1 flight count as both? Say a 5 hour flight, no stops. 2.5 hours day, 2.5 hours night.

Or how about this? I flew during the day to an airport over 100 miles away, but it only took an an hour and some change. So I know that's out for the day dual However, that night, I flew from that airport to a different airport, and then back to where I originally started in the day time. It took 3 hours. Can I count that?

What is "the original point of departure" ?

 

[wsuffa]

Total of 2 hours.

Here's a better one. Can 1 flight count as both? Say a 5 hour flight, no stops. 2.5 hours day, 2.5 hours night.

Or how about this? I flew during the day to an airport over 100 miles away, but it only took an an hour and some change. So I know that's out for the day dual However, that night, I flew from that airport to a different airport, and then back to where I originally started in the day time. It took 3 hours. Can I count that?

What is "the original point of departure" ?

I would call the original point of departure where you started in the morning. There's some latitude.

However, since we don't know the conditions under which you took the rest of the flight (dual, weather, etc.), can't tell if it counts.

Though it's not a binding legal opinion, you should check out the John Lynch FAQ on the FAA's AFS-800 site.

 

[EdFred]

I would call the original point of departure where you started in the morning. There's some latitude.

However, since we don't know the conditions under which you took the rest of the flight (dual, weather, etc.), can't tell if it counts.

Though it's not a binding legal opinion, you should check out the John Lynch FAQ on the FAA's AFS-800 site.

It was night dual in VFR conditions, but was conducted under IFR.

 

[Ed Guthrie]

It was night dual in VFR conditions, but was conducted under IFR.

Pzzzt. No good. It was flown in VMC conditions but it was an IFR flight. The commercial x-country flights must be flown under VFR.

 

[Ed Guthrie]

There are 3 X-C flights required for the Commercial Rating: (FAR 61.129)

0) Solo X-C
> 300NM with landings at 3+ points
one of which is 250NM straight from point of departure.

This may be stating the obvious, but since no one else mentioned it: This flight could be done anytime. IOW, if you have a flight meeting this requirement somewhere in your logbook then you are good to go. If you have one such flight you need not do this again just because you now want a commercial certificate.

 

[poadeleted3]

This may be stating the obvious, but since no one else mentioned it: This flight could be done anytime. IOW, if you have a flight meeting this requirement somewhere in your logbook then you are good to go. If you have one such flight you need not do this again just because you now want a commercial certificate.

The "solo" part does not exclude non-pilot passengers, does it? IOW, the 324 nm each way trip I just completed does not count because I had Cathy and Sean with me, does it?

 

[Ed Guthrie]

The "solo" part does not exclude non-pilot passengers, does it?

I'm afraid solo does indeed me alone, as in no one else with you.

IOW, the 324 nm each way trip I just completed does not count because I had Cathy and Sean with me, does it?

I am afraid it does not count as a solo x-country. However, as a consolation prize it does count as x-country flight time.

 

[jdwatson]

And not so obvious, it is my understanding that one needs to have at least their private pilot's license complete before it counts towards the commercial rating.

 

[wsuffa]

And not so obvious, it is my understanding that one needs to have at least their private pilot's license complete before it counts towards the commercial rating.

I think the rule reads "training to the requirements of the commercial" requirements. Generally, I understand that to mean that the cross-countries you did to meet your Pvt requirements can't be used for the commercial training cross-countries.

However, if you are IFR-rated, you don't need to do the 10 hours of instrument training separately for the Commercial. The IFR rating counts.

 

[AirBaker]

I'm afraid solo does indeed me alone, as in no one else with you.

Oh, who's going to know. They're not pilots... you flew the airplane there.

I think having a GPS coupled autopilot is more cheating than a non-pilot passenger.

Just my opinion.

 

[wsuffa]

Oh, who's going to know. They're not pilots... you flew the airplane there.

I think having a GPS coupled autopilot is more cheating than a non-pilot passenger.

Just my opinion.

Is it really that tough to book a plane for an afternoon and just go knock off the requirement solo????? I thought we LIKED to fly...

 

[Greebo]

The "solo" part does not exclude non-pilot passengers, does it? IOW, the 324 nm each way trip I just completed does not count because I had Cathy and Sean with me, does it?

What Ed said - unfortunately solo means solo solo - the ratings of the other people in the plane don't matter - it has to be 1 soul on board, max.

 

[bstratt]

An easy way to take care of the dual is find an airport 2 hrs away - fly there late afternoon with instructor - have dinner - fly back at night. You get both X-C's out of the way at once.

P.S. try to do the night X-C during ST not DT... it's a pain waiting until 9:00pm for night to fall when in the winter you can take off at 4:00pm.

 

[EdFred]

Pzzzt. No good. It was flown in VMC conditions but it was an IFR flight. The commercial x-country flights must be flown under VFR.

Then what are "VFR conditions"? 61.129 says "in VFR conditions" not "under VFR."
For the instrument ratings in 61.65 it lists all references as "under IFR."

What then, are "VFR conditions" ?

 

[Greebo]

Then what are "VFR conditions"? 61.129 says "in VFR conditions" not "under VFR."
For the instrument ratings in 61.65 it lists all references as "under IFR."

What then, are "VFR conditions" ?

Flights which are flown under Visual Flight Rules, vs. under Instrument Flight Rules. In other words - Flight Following is ok - IFR Routing and approaches no - the navigation portion of the XC is entirely up to you for the commercial XC and under IFR you're being given navigation direction by ATC.

If you fly IFR in VMC you are not flying VFR. VFR must be in VMC (legally), IFR doesn't have to be.

 

[bstratt]

I started a thread on this subject on the AOPA webboard last spring when I was undertaking my Commercial requirements. I remember there were a few instructors that in my view expanded on the requirement by interpreting "under VFR conditions" to mean by dead reckoning/pilotage. In other words they turned off all electronic navigation aids for this two hour course. Thankfully my instructor didn't.

 

[EdFred]

Flights which are flown under Visual Flight Rules, vs. under Instrument Flight Rules. In other words - Flight Following is ok - IFR Routing and approaches no - the navigation portion of the XC is entirely up to you for the commercial XC and under IFR you're being given navigation direction by ATC.

If you fly IFR in VMC you are not flying VFR. VFR must be in VMC (legally), IFR doesn't have to be.

Then why does 61.129 not say "under VFR"? If it said "under VFR" I wouldn't squabble one bit. But it says "VFR conditions." I'm looking outside, and it's clear and a million. Yes, it's VMC, and to me that is "VFR conditions". Bad wording. 61.129 should say "under VFR" if they want you to fly it under VFR"

 

[Ed Guthrie]

And not so obvious, it is my understanding that one needs to have at least their private pilot's license complete before it counts towards the commercial rating.

You can find a few foot stompers who will claim that (John Lynch being one of those), but AFAIK there is no basis in the FARs for that statement. The actual FAR:

§ 61.129 Aeronautical experience.
(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.


Most folks read "on the areas of operation listed" and somehow see a commercial certificate specific requirement or purpose which isn't actually there. 61.127(b)(1) is a list of topics specific to the commercial certificate completion. No more, no less. That list makes no statement as to required timing for accomplishing the listed topics. Anyone who believes they see a specific timing requirement in either 61.129 or 61.127 (other than it must be completed before applying for the commercial certificate) should send a letter to their Regional Counsel or the FAA Chief Counsel for clarification. IOW, the English words just aren't there to support their claim.

 

[jdwatson]

Does the same thing apply to the Dual VFR flights ? If a pilot had flown a day & night 2hr+ 100nm+ X-Cs as a student pilot, they would also count towards their commercial rating ?

 

[jdwatson]

If a pilot that holds a Commercial certificate as ASEL, then added AMEL would they have to also fly the X-C (solo & dual) again in the multi-engine plane ?

I guess the question this time is, does ASEL or AMEL X-C time count for each other ?

 

[Jeff Oslick]

Does the same thing apply to the Dual VFR flights ? If a pilot had flown a day & night 2hr+ 100nm+ X-Cs as a student pilot, they would also count towards their commercial rating ?

I think they would count toward the commercial rating. I believe, but don't know for certain, that this requirement was added to the commerical rating requirements explicitly because some pilots, myself included, obtained their PP certificates before the current student pilot standards were in place. (There was no 2hr/100nm requirement for the dual X-C flights, and no night dual X-C requirement at all). When I went for my commercial in 2003, I had to go "backwards" and get these dual X-C flights in my log book. I did just as someone already mentioned - I flew out during late afternoon, and back at night. I also used this flight as my complex aircraft checkout, and for an FBO-required high-altitude airport checkout.

Jeff

 

[Ed Guthrie]

Does the same thing apply to the Dual VFR flights ? If a pilot had flown a day & night 2hr+ 100nm+ X-Cs as a student pilot, they would also count towards their commercial rating ?

Please allow me to answer a question with a question. First, here is the regulation:

§ 61.129 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, <b>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</b> that consists of at least:
...
(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—
(iv) <b>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</b>

(emphasis added in two sections)

So, the obvious question would be: If the night x-country dual must be completed post private pilot, then why is it commonly held that the 250 hours flight time includes time built while working towards the private certificate? Where is the delineating phrase/words within 61.129(a)(3) [or (4) for that matter] that sets a different timing standard for requirements within (a)(3) [or (4) for that matter] versus the timing for requirements within (a) itself?

If someone can show me the "after completing the private pilot" or "time prior to private certificate does not count" which appears in 61.129(a)(3) but does not appear within 61.129(a) then I'll buy the "after private" logic. Otherwise, I say folks are injecting interpretations not supported by the actual regulation's wording.

 

[gismo]

If a pilot that holds a Commercial certificate as ASEL, then added AMEL would they have to also fly the X-C (solo & dual) again in the multi-engine plane ?

I guess the question this time is, does ASEL or AMEL X-C time count for each other ?

I'd have to look in the FAR's to be sure but I think the answer to your first question is no. There is a different FAR that applied to additional ratings on the same commercial license, and AFaIK that one doesn't require class specific x/c flights.

 

[Ed Guthrie]

If a pilot that holds a Commercial certificate as ASEL, then added AMEL would they have to also fly the X-C (solo & dual) again in the multi-engine plane ?

In this example the pilot would need to comply with 61.63(c):

§ 61.63 Additional aircraft ratings (other than on an airline transport pilot certificate).

(a) General. To be eligible for an additional aircraft rating to a pilot certificate, for other than an airline transport pilot certificate, an applicant must meet the appropriate requirements of this section for the additional aircraft rating sought.
...
(c) Additional class rating. Any person who applies for an additional class rating to be added on a pilot certificate:
(1) Must have an endorsement in his or her logbook or training record from an authorized instructor and that endorsement must attest that the applicant has been found competent in the aeronautical knowledge areas appropriate to the pilot certificate for the aircraft class rating sought;

(2) Must have an endorsement in his or her logbook or training record from an authorized instructor, and that endorsement must attest that the applicant has been found proficient in the areas of operation appropriate to the pilot certificate for the aircraft class rating sought;

(3) Must pass the required practical test that is appropriate to the pilot certificate for the aircraft class rating sought;

(4) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought unless the person holds a a lighter-than-air category rating with a balloon class rating and is seeking an airship class rating and

(5) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, or airship rating at that pilot certificate level.

I guess the question this time is, does ASEL or AMEL X-C time count for each other ?

For the initial commercial certificate? No. Each section of the FAR requires that the x-country dual be in the category/class of aircraft for which the initial commercial certificate is sought. For example, for a COM/ASEL certificate, the regulations pertaining to x-country dual include the phrase "in a single-engine airplane".

 

[poadeleted20]

Total of 2 hours.

Here's a better one. Can 1 flight count as both? Say a 5 hour flight, no stops. 2.5 hours day, 2.5 hours night.?

If there are no stops (i.e., no landings), it isn't an XC flight for commercial aeronautical experience requirements -- gotta have a landing more than 50 nm away from the original point of departure. However, if you fly 2.5 out in the day, land, wait for "night" (i.e., after evening civil twilight), and fly 2.5 back, then back, that would fill both squares.

Or how about this? I flew during the day to an airport over 100 miles away, but it only took an an hour and some change. So I know that's out for the day dual However, that night, I flew from that airport to a different airport, and then back to where I originally started in the day time. It took 3 hours. Can I count that?

If you flew two hours from one airport to another at night, the night square is filled. If, the next day, you flew three hours from where you landed at night to another airport (the one you originally left from the previous day), then the day square is filled.

What is "the original point of departure" ?

Oy. Well, here's the official FAA Flight Standards Service statement on that:

ANSWER: Ref. § 61.129(b)(3)(iii)There is no definition of the term “original point of departure” in Parts 1 or 61 or any other FAA publication. Each situation is unique and a definitive definition of “original point of departure” that will cover all circumstances and situations is not practicable nor possible.



Departure for the purpose of conducting a “round robin” cross-country flight is a normal scenario where “original point of departure” and destination are the same. The “original point of departure” does not change with a new day or delay.



Other examples include:



1. The purpose of repositioning (emphasis: purpose of repositioning) the aircraft to another airport, to start a cross-country flight in order to meet the 250 nautical miles cross-country requirements of § 61.129(a)(4)(i).



2. A person departs the Los AngelesInternationalAirport on day 1 for the purpose of conducting a cross-country flight to the San JoseAirport (emphasis purpose of conducting a cross-country flight to the San JoseAirport) and remains overnight. On day 2, that person departs San JoseAirport for the purpose of conducting a cross-country flight to the Lake TahoeAirport (emphasis purpose of conducting a cross-country flight to the Lake TahoeAirport) and remains overnight. On day 3, that person departs Lake TahoeAirport for the purpose of conducting a cross-country flight to the Los AngelesIntl.Airport (emphasis purpose of conducting a cross-country flight to the Los AngelesIntl.Airport) for termination. Which airport is the “original point of departure?” All 3 airports would qualify as the “original point of departure.”



3. Now in a similar situation, but slightly different, a person departs the Los Angeles International Airport for the purpose of conducting a round-robin (without ever landing enroute) cross-country flight from the Los Angeles International Airport to the San Diego, CA 030° radial at 12 DME to the Yuma, AZ 350° radial at 10 DME and then returns to the Los Angeles Intl. Airport (emphasis purpose of conducting a “round-robin” cross-country flight). Which airport is the “original point of departure?” The Los AngelesInternationalAirport is the “original point of departure”. But this cross-country flight will not qualify for you applicants in pursuit of a private pilot certificate, commercial pilot certificate, or an instrument rating. However, if this flight were conducted by a pilot who already holds a commercial pilot certificate, the flight is creditable for the ATP certificate cross-country requirement.


Now, personally, I find this confusing and a bit contradictory, but that's the "official" FAA Flight Standards Service position. My personal position on the definition of "original point of departure" is that of Supreme Court Justice Potter Stewart in Jacobellis v. Ohio, 378 U.S. 184, 197 (1964) -- "I shall not today attempt further to define [what] I understand to be embraced within that shorthand description; and perhaps I could never succeed in intelligibly doing so. But I know it when I see it..."

 

[EdFred]

If there are no stops (i.e., no landings), it isn't an XC flight for commercial aeronautical experience requirements -- gotta have a landing more than 50 nm away from the original point of departure. However, if you fly 2.5 out in the day, land, wait for "night" (i.e., after evening civil twilight), and fly 2.5 back, then back, that would fill both squares.

Sorry - what I meant to say was a 5 hour straight line flight from say, Paducah, KY to ...uh....5 hours....single engine....Duluth, MN sounds about right. It becomes night somewhere around Dubuque, IA. 2+ hours of the flight were conducted in the day, and 2+ hours were conducted at night. Can that be counted towards both?

 

[bharris]

I have re-located my airplane flying it from Seattle to Dallas ADS in September 2000 and then flying it back to Seattle in the spring of 2001. The distance is about 1900 NM. I had at least one leg >250NM on each trip.

Would those solo relocation flights satisfy the daytime Solo XC requirement for Commercial?

 

[Ed Guthrie]

I have re-located my airplane flying it from Seattle to Dallas ADS in September 2000 and then flying it back to Seattle in the spring of 2001. The distance is about 1900 NM. I had at least one leg >250NM on each trip.

Would those solo relocation flights satisfy the daytime Solo XC requirement for Commercial?

Yes, provided you were alone in the aircraft.

 

[CFIse]

I started a thread on this subject on the AOPA webboard last spring when I was undertaking my Commercial requirements. I remember there were a few instructors that in my view expanded on the requirement by interpreting "under VFR conditions" to mean by dead reckoning/pilotage. In other words they turned off all electronic navigation aids for this two hour course. Thankfully my instructor didn't.

I wouldn't say I "expand the requirement" but people who arrive to do their Commercial VFR cross-countries have often just finished an instrument rating where they've done nothing but navigate with electronic aids.

Getting back to some basic pilotage is a good exercise for them, and you never know, one day they may find it useful!

 

[CFIse]

Does the same thing apply to the Dual VFR flights ? If a pilot had flown a day & night 2hr+ 100nm+ X-Cs as a student pilot, they would also count towards their commercial rating ?

Jeff - take my word for it, your local DE's want it post-private. We can argue about the number of angels on the head of that pin, but there you go

 

[CFIse]

If a pilot that holds a Commercial certificate as ASEL, then added AMEL would they have to also fly the X-C (solo & dual) again in the multi-engine plane ?

I guess the question this time is, does ASEL or AMEL X-C time count for each other ?

If you're adding the multi to an existing certificate all you need is an instructor endorsement.

 

[CFIse]

Oh, who's going to know. They're not pilots... you flew the airplane there.
QUOTE]

Well that's all good as long as you're not going on to obtain an ATP - in which case you're going to have a problem with the "good moral character" clause.

 

[Ed Guthrie]

If you're adding the multi to an existing certificate all you need is an instructor endorsement.

Two endorsements, actually, but who's counting.

 

[poadeleted20]

Sorry - what I meant to say was a 5 hour straight line flight from say, Paducah, KY to ...uh....5 hours....single engine....Duluth, MN sounds about right. It becomes night somewhere around Dubuque, IA. 2+ hours of the flight were conducted in the day, and 2+ hours were conducted at night. Can that be counted towards both?

Well, first, ain't too many airplanes can go that far with legal reserves. But let's say you're in a Cougar, which can, and you also have an adequate supply of piddle packs. I've never heard of this coming up, and it isn't addressed in the Part 61 FAQ file, so I think the only question would be whether the reg requires one flight or two, and the only way to find out would be to ask AFS-800. My concern would be that you haven't demonstrated the ability to start and end a flight in both day and night environments, so I would probably not go along with a student who wanted to do this.

 

[poadeleted20]

If you're adding the multi to an existing certificate all you need is an instructor endorsement.

The relevent reg is 61.63:

(c) Additional class rating. Any person who applies for an additional class rating to be added on a pilot certificate:
(4) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought unless the person holds a a lighter-than-air category rating with a balloon class rating and is seeking an airship class rating...

 

[EdFred]

My concern would be that you haven't demonstrated the ability to start and end a flight in both day and night environments, so I would probably not go along with a student who wanted to do this.

If I wanted to fly mine at like 55% power I think I can stay airborne for 7 hours or so. Not that I'd want to. Here's what I don't get with the 100nm cross country. Why 100 nm for the commercial? I did a few 50nm < cross countries < 100 nm both night and day in my primary training - VFR of course. If I can pilotage 75nm, that last 25 isn't going to get you lost. I've already demonstrated the ability to start and end a flight during the day and during the night. The funny thing is, I will have a 4,000nm VFR solo cross country next month - but I need to have a piddly 100 miler with a CFI?

 

[poadeleted20]

Why 100 nm for the commercial?

Can't say for sure, but my GUESS is that they are concerned that you may have neglected your basic pilotage skills since getting your Private, and they want to be SURE that Commercial pilots can get their paying passengers home even if the GPS quits.