Cross-country time

Thanks, all. Really interesting reading.
I guess what I most want is to avoid a show-down with a DPE on check-ride day. No fun.
If the rule is not clear, then I think the best thing for me to do is a) get a complex endorsement and b) until then, not log time cross-country time unless I am flying a plane for which I am rated and endorsed. Not to mention insurance.
It changes whether or not I want to fly with a friend, or be a bit more single-minded about building time.
I sure like that M20J...

Again, thank you!
 
AnnaG said:
Thanks, all. Really interesting reading.
I guess what I most want is to avoid a show-down with a DPE on check-ride day. No fun.
If the rule is not clear, then I think the best thing for me to do is a) get a complex endorsement and b) until then, not log time cross-country time unless I am flying a plane for which I am rated and endorsed. Not to mention insurance.
It changes whether or not I want to fly with a friend, or be a bit more single-minded about building time.
I sure like that M20J...

Again, thank you!
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First, the rule is perfectly clear: You can log the time regardless of endorsements.

Second: Don't let that stop you from getting your Complex...I did my HP and Complex in 2.0 hours in a retract 182, so it's not that huge of an investment.
 
It's fine to fly your friend's M20J without the complex endorsement so long as your friend is acting as PIC. You can log PIC time while you're sole manipulator of the controls since you're rated for ASEL and a type rating isn't required. You'd have to be sole manipulator from start to finish, however, if you want to count it as xc time (and landing more than 50nm away too).

Insurance is another issue.
 
AnnaG said:
Thanks, all. Really interesting reading.
I guess what I most want is to avoid a show-down with a DPE on check-ride day. No fun.
If the rule is not clear
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The rules in this area are clear and have been clear for decades. It is clear, for example, that:

  • A pilot may log PIC time when sole manipulator of the controls of an aircraft for which the pilot has the applicable aircraft ratings (and that endorsements are not ratings)
  • A pilot may not log PIC in an aircraft for which the pilot does not have the applicable aircraft ratings, unless solo (with the proper endorsements)
  • Regardless of the PIC issue, in order to log cross country time toward a certificate or rating, the pilot logging it must have been the sole manipulator on the whole flight, especially including the takeoff and landing.

The problem is that, despite extensive discussion over the past 10 years or so on the internet, there remains a cadre that either (a) don't know it (b) can't get their heads around the concept that "logging" and "being" PIC has separate rules or (c) don't like it and will not accept it.

If your time qualifies and the Examiner doesn't accept it, I agree that the path of least resistance is not to have a showdown about it.
 
midlifeflyer said:
It doesn't matter if the guy writing the explanation for the Federal Register preamble said "log PIC time" instead of "credit as PIC time." And the reg says:

==============================
(g) An applicant for a combined private pilot certificate with an instrument rating may satisfy the cross-country flight time requirements of this section by crediting:
(1) For an instrument-airplane rating or an instrument-powered-lift rating, up to 45 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor; or
(2) For an instrument-helicopter rating, up to 47 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor.
==============================
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It doesn't make sense to allow 45/47 hours of cross-country time for an instrument rating and then turn around and disallow the very same hours for the commercial which are required to be "logged" PIC cross-country hours.

midlifeflyer said:
As the Chief Counsel's office once said about the contents of the Federal Register when there is no language of the regulations conflicts (one of my favorite FAA regulatory errors):
==============================
Preambles to final rules serve two purposes; they explain the reasons for adopting the new rule, including responses to public comments, and they provide interpretive guidance on operation of the rule. However, when the rule and the preamble conflict, the rule controls.
==============================
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Ron Levy said:
Regardless of how you read it, the FAA Chief Counsel has written unreservedly "when the rule and the preamble conflict, the rule controls".

And I now see Mark beat me to it on the Keller letter.
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So, we all agree the preamble explains "the reasons for adopting the new rule". The bone of contention is whether the rule and preamble are in conflict. If they are not, then students can log the dual hours as PIC cross-country time while working toward a combined license/rating because the preamble plainly says so. I think the rule is in agreement because the phrase "by crediting... up to 45 hours of cross-country flight time" refers to the grant of permission to log it (dual) as PIC time which isn't otherwise allowable for student pilots. A similar exception exists when a student applicant is taking a flight test. Pass or fail, the applicant is the PIC and can log it as such even though 61.51 says nothing about that scenario either (under type of piloting time).

dtuuri
 
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dtuuri said:
It doesn't make sense to allow 45/47 hours of cross-country time for an instrument rating and then turn around and disallow the very same hours for the commercial which are required to be "logged" PIC cross-country hours.




So, we all agree the preamble explains "the reasons for adopting the new rule". The bone of contention is whether the rule and preamble are in conflict. If they are not, then students can log the dual hours as PIC cross-country time while working toward a combined license/rating because the preamble plainly says so. I think the rule is in agreement because the phrase "by crediting... up to 45 hours of cross-country flight time" refers to the grant of permission to log it (dual) as PIC time which isn't otherwise allowable for student pilots. A similar exception exists when a student applicant is taking a flight test. Pass or fail, the applicant is the PIC and can log it as such even though 61.51 says nothing about that scenario either (under type of piloting time).

dtuuri
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I won't argue with your personal viewpoint but the Chief Counsel opinions on the logging of "performing the duties" under other sections where it appears for PIC credit toward other certificates and ratings suggest a different answer than yours.

My personal view of the "reason" for the rule is the series of "no double-dip" opinions by both the old FAQ and later Chief Counsel opinions saying a pilot cannot credit student pilot times toward advanced ratings, such as the instrument rating. 61.65(g) is there to permit a pilot to work on both the private certificate and instrument rating at the same time.
 
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dtuuri said:
So, we all agree the preamble explains "the reasons for adopting the new rule". The bone of contention is whether the rule and preamble are in conflict.
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So which subparagraph of 14 CFR 61.51(e) do you think agrees with what you say the preamble says, i.e., the one that allows a Student Pilot to log PIC time while an instructor is in the airplane?
 
midlifeflyer said:
My personal view of the "reason" for the rule is the series of "no double-dip" opinions by both the old FAQ and later Chief Counsel opinions saying a pilot cannot credit student pilot times toward advanced ratings, such as the instrument rating.
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What's "no double-dip" mean? What "student pilot time" doesn't count toward advanced ratings, especially the instrument?

The logging of flight time isn't usually a subject I have interest in and don't follow these threads very closely. I believe logbooks should reflect the truth and since they don't anymore (difference between logging and acting) I'm usually content to let the chief counsel simmer in its own juices.

dtuuri
 
dtuuri said:
What "student pilot time" doesn't count toward advanced ratings, especially the instrument?
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The "3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments" in 61.109 for Private do not count towards the "15 hours [which] must have been received from an authorized instructor who holds an instrument-airplane rating" required by 61.65 for the IR even though they do count towards the "Forty hours of actual or simulated instrument time" for the IR. Likewise, the dual XC's required by 61.109 for PP do not count for the dual XC's required for CP by 61.129.
 
Ron Levy said:
So which subparagraph of 14 CFR 61.51(e) do you think agrees with what you say the preamble says, i.e., the one that allows a Student Pilot to log PIC time while an instructor is in the airplane?
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There's no logbook police that raid your house in the middle of the night to see what times you've entered in which columns. You only need to have a record of certain items listed in 61.51 that you can use to demonstrate currency or qualifications for certificates and ratings. I don't see why you can't organize the record to suit yourself as long as you don't misrepresent the times.

The question becomes not which logbook columns support the combined license, but whether those dual cross-country hours logged/credited toward the combined license also count for the commercial. The preamble indicates such time is better than solo/PIC time, so logically (theirs, not mine) it should count. I don't know if that question has been officially answered.

Fundamentally, I don't see any difference between the rationale that allows private pilots to log PIC time when they aren't acting as such and student pilots doing the same while working toward a combined rating and using the time for higher certificates.

dtuuri
 
midlifeflyer said:
The problem is that, despite extensive discussion over the past 10 years or so on the internet, there remains a cadre that either (a) don't know it (b) can't get their heads around the concept that "logging" and "being" PIC has separate rules or (c) don't like it and will not accept it.

If your time qualifies and the Examiner doesn't accept it, I agree that the path of least resistance is not to have a showdown about it.
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In the real world, path of least resistance may need to be tendered with wisdom, but on the internet, how do you expect the OP to earn his/her stripes without said showdown?:D
 
warthog1984 said:
Just bring a copy of the Hermann letter with you on exam day- it spells it out clearly.
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Yep, it's always a good idea to show up an examiner before an examination. :no: We all react so positively when someone proves we are wrong.

Reminds me of the lawyer who repeatedly told the judge during a trial without jury - "you can't find that way!"
 
Talk to the DE first, before you start training. Ask him if its possible. Hes the one that is going to approve or disapprove your hours, training and signoff.
 
Ron Levy said:
The "3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments" in 61.109 for Private do not count towards the "15 hours [which] must have been received from an authorized instructor who holds an instrument-airplane rating" required by 61.65 for the IR even though they do count towards the "Forty hours of actual or simulated instrument time" for the IR.
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Agreed, it's been that way for at least 47 years. The time does count (toward the 40).

Ron Levy said:
Likewise, the dual XC's required by 61.109 for PP do not count for the dual XC's required for CP by 61.129.
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I can see the commercial training requirement should be additive, since the skill requirements are more advanced. The combined license cross-country time also is advanced training, so I think the FAA intends for it to count. Should it count as both PIC and dual training? Don't they let private pilots count PIC time they logged with an instructor? Frankly, I regret entering this discussion--it's making the room spin.

dtuuri
 
dtuuri said:
I can see the commercial training requirement should be additive, since the skill requirements are more advanced. The combined license cross-country time also is advanced training, so I think the FAA intends for it to count.
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You may think that, but the rules say otherwise, and as the Chief Counsel said, "the rules control".

Should it count as both PIC and dual training? Don't they let private pilots count PIC time they logged with an instructor?
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I'm not getting into what should be, only what is, and the regs are clear on this point -- Student Pilots do not log PIC time in airplanes unless they are the sole occupant. Beyond that, Part 11 of the FAR's is available for you to suggest a change to those regs.
 
Ron Levy said:
You may think that, but the rules say otherwise, and as the Chief Counsel said, "the rules control".

I'm not getting into what should be, only what is, and the regs are clear on this point -- Student Pilots do not log PIC time in airplanes unless they are the sole occupant. Beyond that, Part 11 of the FAR's is available for you to suggest a change to those regs.
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I don't agree with you. The word "not" only appears once in 61.51 and doesn't prohibit the logging of any time in any way. That's all I'm saying on this.

dtuuri
 
dtuuri said:
I don't agree with you. The word "not" only appears once in 61.51 and doesn't prohibit the logging of any time in any way. That's all I'm saying on this.

dtuuri
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Sigh. Take it up with the Chief Counsel.

http://www.faa.gov/about/office_org...helicopters - (2013) legal interpretation.pdf

...answering "no" to the question " May the applicant log as PIC time that time spent performing the duties of pilot in command with an instructor on board in accordance with § 61.51?"

(Yeah I know, you'll find a way to pin dance the opinion to fit it in with your personal view so the reference is really for everyone but you)
 
midlifeflyer said:
Sigh. Take it up with the Chief Counsel.

http://www.faa.gov/about/office_org...helicopters - (2013) legal interpretation.pdf

...answering "no" to the question " May the applicant log as PIC time that time spent performing the duties of pilot in command with an instructor on board in accordance with § 61.51?"

(Yeah I know, you'll find a way to pin dance the opinion to fit it in with your personal view so the reference is really for everyone but you)
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I really thought I was through here, but then you accused me of "pin dancing" (grrr...). All I can say is if anybody else reads that reference it'll probably bore them as much as I was. So, let me quickly quote the answer they gave to the question you cited with my highlights:
Section 61.l29( c)(4) permits a pilot to credit a maximum of 10 hours of flight time performing the duties of pilot in command with an instructor on board toward the pilot-incommand flight time required by § 61. 129(c)(2). As such, the remaining 25 hours of pilot-in- command flight time in helicopters required by § 61. 129(c)(2) must meet the pilot-in-command logging requirements in § 61.51(e).​
So you see, they do allow logging of the dual received as PIC time up to the limit stated. Only the remaining hours need to meet 61.51(e).

dtuuri
 
dtuuri said:
I really thought I was through here, but then you accused me of "pin dancing" (grrr...). All I can say is if anybody else reads that reference it'll probably bore them as much as I was. So, let me quickly quote the answer they gave to the question you cited with my highlights:
Section 61.l29( c)(4) permits a pilot to credit a maximum of 10 hours of flight time performing the duties of pilot in command with an instructor on board toward the pilot-incommand flight time required by § 61. 129(c)(2). As such, the remaining 25 hours of pilot-in- command flight time in helicopters required by § 61. 129(c)(2) must meet the pilot-in-command logging requirements in § 61.51(e).​
So you see, they do allow logging of the dual received as PIC time up to the limit stated. Only the remaining hours need to meet 61.51(e).

dtuuri
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I'm going to hire myself out as a soothsayer.

And the reason this doesn't apply?

==============================
Your second question concerns how the pilot performing the duties of PIC with an authorized instructor may log flight time. Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received. The pilot can log the time to meet the requirements of § 61.129(a)(4) and log total flight time. Section 61.51(e) prescribes the requirements for logging PIC time. The pilot could log PIC time under § 61.51(e)(1)(i) if the pilot has a private pilot certificate with the appropriate ratings for the aircraft. Otherwise, the pilot cannot log PIC time[/B]. None of the other § 61.51(e) logging provisions are applicable to your scenario. However, § 61.129(a)(4) permits crediting of the time toward the 100 hours of PIC time required for the commercial pilot certificate under § 61.129(a)(2). The logbook entry should accurately reflect the provision under which the flight time is logged.
==============================
2014 Kuhn Interpretation
 
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fpKxUd3.png
 
midlifeflyer said:
"Because this flight time is a substitute for solo flight time, the pilot is not receiving instruction and therefore cannot log this time as dual instruction received." ==============================
2014 Kuhn Interpretation
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Am I supposed to believe the FAA, despite what this law clerk says, thinks a student pilot with an instructor onboard is not receiving instruction? And that the CFI "not giving it" can't sign the student's logbook stating so?

dtuuri
 
dtuuri said:
Am I supposed to believe the FAA, despite what this law clerk says, thinks a student pilot with an instructor onboard is not receiving instruction? And that the CFI "not giving it" can't sign the student's logbook stating so?

dtuuri
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You're supposed to read both the regulations and the interpretation, which does NOT apply to Student Pilots taking training for Private Pilot. This interpretation is specific to the situation in 61.129 involving a pilot "performing the duties of pilot in command in a single engine airplane with an authorized instructor on board" in furtherance of the solo requirements for Commercial Pilot, and only for the solo requirements for Commercial Pilot. This exception has absolutely nothing to do with a Student Pilot working on a concurrent PP/IR.

And it's not a "law clerk" saying this, it's signed by an Assistant Chief Counsel of the FAA speaking for the FAA Chief Counsel.
 
Ron Levy said:
This exception has absolutely nothing to do with a Student Pilot working on a concurrent PP/IR.
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You're addressing the wrong person, I didn't invoke this.

To refresh, post #5 (Shawn) was about the the FSDO saying a private pilot could log PIC time toward required cross-country time while taking dual. I expressed an opinion that would only be allowed if the applicant was working toward a "combined private and instrument". From there the discussion has moved to whether that same time could be used toward a commercial certificate and whether the time could be listed in the PIC column of the applicant's logbook.

The above reference is supposed to be proof of an over-all posture by the FAA regarding what time can go in what column in a pilot's logbook. I, myself, don't see how it relates to the combined license and instrument rating, but am willing to play along. Surely the FAA knows that the student-licensed pilot flying 45 hours of cross-country time with an instructor sitting next to him or her is receiving instruction while they work on an instrument rating at the same time as a private license.

dtuuri
 
AnnaG said:
I'm a fairly recent Private Pilot, just starting my instrument training under Part 91.

The question I have relates to the 50-hour cross-country time requirement. And specifically, to this:

If I am flying with another pilot (not an instructor) in a complex single-engine (Mooney) and he "gives" me the cross-country PIC time - can I use that time as part of my cross-country requirements?

What I can't figure out is whether I can officially log time in a complex aircraft, even though I am not rated for that aircraft?

Or do I need to stick to my trusty 172 for all of my log-able cross-country flight time?
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Make sure that the cross-country time logged is going to an airport that is at least 50 nautical miles from your original departure point.

You can actually log any flight time as cross-country if you land at another airport, even if that airport is only 3 miles from where you took off. However, only cross-country time logged when traveling to an airport 50+ nm will actually count towards a rating (such as the 50 hours required for Instrument or Commercial).
 
I'm done responding to dtuuri, who makes inaccurate statements and then says "You're addressing the wrong person, I didn't invoke this" when someone points out the errors in his statements.
 
DMD3. said:
Make sure that the cross-country time logged is going to an airport that is at least 50 nautical miles from your original departure point.

You can actually log any flight time as cross-country if you land at another airport, even if that airport is only 3 miles from where you took off. However, only cross-country time logged when traveling to an airport 50+ nm will actually count towards a rating (such as the 50 hours required for Instrument or Commercial).
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That's all true for Pvt/IR in Airplanes, but not all other Certificates/Categories/Classes. Please see the FAA's official definitions of "cross-country" (all seven of them) in 14 CFR 61.1 for details.
 
Ron Levy said:
I'm done responding to dtuuri, who makes inaccurate statements and then says "You're addressing the wrong person, I didn't invoke this" when someone points out the errors in his statements.
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I've said nothing inaccurate and made no errors. Get lost.

dtuuri
 
You said a pilot "performing the duties of PIC" with an instructor on board for PIC credit toward a certificate or rating without having the appropriate aircraft ratings may log it as PIC time. That is incorrect.
 
midlifeflyer said:
You said a pilot "performing the duties of PIC" with an instructor on board for PIC credit toward a certificate or rating without having the appropriate aircraft ratings may log it as PIC time. That is incorrect.
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My comments were on a combined pvt/inst trainee. That would mean a student pilot and student certificates don't have "appropriate aircraft ratings". I cited the preamble, which is also where the chief counsel goes when they interpret rules, where logging such "instructor onboard" time as PIC cross-country is approved. For this I got pilloried. Then I've been asked to suspend disbelief and accept that the FAA won't allow advanced students to simultaneously log dual with this PIC time while working toward the combined rating because "they aren't receiving instruction". I've also been told that some people's interpretation of the "combined rule" invalidates the preamble language even though my own interpretation of the same rule is in harmony with it, so somehow mine gets trumped. I've been scolded that the logbook rule prohibits logging of cross-country PIC time with an instructor onboard (who is surely giving instrument instruction) even though the rule only uses enabling language, i.e., under certain circumstances time "may" be logged as PIC and not prohibitive language like under certain circumstances time "may not" be logged as PIC.

All of this, mind you, on a subject I find revolting. Nobody would be allowed to lie to their logbooks if I were king. If you aren't a real PIC, you shouldn't be able to claim you are even if the real PIC lets you steer the plane for awhile.

dtuuri
 
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dtuuri said:
My comments were on a combined pvt/inst trainee. That would mean a student pilot and student certificates don't have "appropriate aircraft ratings". I cited the preamble, which is also where the chief counsel goes when they interpret rules, where logging such "instructor onboard" time as PIC cross-country is approved. For this I got pilloried. Then I've been asked to suspend disbelief and accept that the FAA won't allow advanced students to simultaneously log dual with this PIC time while working toward the combined rating because "they aren't receiving instruction". I've also been told that some people's interpretation of the "combined rule" invalidates the preamble language even though my own interpretation of the same rule is in harmony with it, so somehow mine gets trumped. I've been scolded that the logbook rule prohibits logging of cross-country PIC time with an instructor onboard (who is surely giving instrument instruction) even though the rule only uses enabling language, i.e., under certain circumstances time "may" be logged as PIC and not prohibitive language like under certain circumstances time "may not" be logged as PIC.

All of this, mind you, on a subject I find revolting. Nobody would be allowed to lie to their logbooks if were king. If you aren't a real PIC, you shouldn't be able to claim you are even if the real PIC lets you steer the plane for awhile.

dtuuri
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Unfortunately, that which you wish were true isn't true, and as a result, your statements based on what you wish was true are incorrect as far as FAA legality is concerned.
 
Ron Levy said:
Unfortunately, that which you wish were true isn't true, and as a result, your statements based on what you wish was true are incorrect as far as FAA legality is concerned.
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I've made no statements based on "what I wish was true." Go away.

dtuuri
 
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