IFR students building cross-country time

[noahfong]

Hello all,

I've not been a fan of this idea that many aspiring IFR students are doing to build their 50 hours of required cross-country (PIC) time:
1. pair up
2. one flies under the hood and other is safety pilot
3. fly somewhere > 50nm.
4. switch roles on return trip.
5. both logs PIC cross country time
6. splits costs

The only reason I don't like it is that it seems hokey. But, I've heard others object based on legality and the definition of cross-country flight:
Cross-country time means -

(i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight

(A) Conducted by a person who holds a pilot certificate;

(B) Conducted in an aircraft;

(C) That includes a landing at a point other than the point of departure; and

(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under § 61.101 (c), time acquired during a flight -

(A) Conducted in an appropriate aircraft;

(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and

(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

Their argument is that whoever flies must conduct a landing in order for the leg to count as a cross-country. IOW, only the person who performs the landing can log that leg as cross-country.

Is their argument valid? Is there a definitive interpretation? Seems, to me, there is room to interpret that whoever performs the landing is not material. Just that the aircraft needs to land.

 

[RingLaserGyroSandwich]

I don't think that only the person at the controls during landing gets credit. The flight needed to include a landing that met some criteria, sure. The regulations don't specify who is controlling the plane at that moment. I do agree the overall method is sketchy, but I don't think your argument holds.

 

[Rgbeard]

The #1 EASIEST way to log XC time is to simply grab a pen and start writing.

That’s about as legit to me as what was described above.

 

[benyflyguy]

This is a great description of what has been done and is legit to continue.
I guess at first glance without really looking at the regs it is kinda odd, what are your concerns?

 

[Salty]

One lands at the 50 mile airport and one lands back home. That’s two cross countries. What’s the issue?

 

[KaiGywer]

Only the person flying logs XC and landings. The safety pilot logs PIC and total time only. And the safety pilot will log at least 0.2-0.3 less than the flying pilot as only time under the hood can be logged by the safety pilot.

 

[noahfong]

One lands at the 50 mile airport and one lands back home. That’s two cross countries. What’s the issue?

The argument I'm getting from other cfis is the definition for xcountry is not just 50nm but conducting the landing as well. Therefore the pilot not flying cannot log xcountry since (s)he did not perform the landing. I, personally, don't see it a problem...so why I'm reaching out for views.

 

[noahfong]

This is a great description of what has been done and is legit to continue.
I guess at first glance without really looking at the regs it is kinda odd, what are your concerns?

I happen to believe it legit. Just want to be sure cuz a lot of cfis don't think so. The reason I think it's hokey is I don't think this way provides real xcountry flying experience.

 

[noahfong]

Only the person flying logs XC and landings. The safety pilot logs PIC and total time only. And the safety pilot will log at least 0.2-0.3 less than the flying pilot as only time under the hood can be logged by the safety pilot.

This is what I'm hearing. What is your reasoning?

 

[Salty]

The argument I'm getting from other cfis is the definition for xcountry is not just 50nm but conducting the landing as well. Therefore the pilot not flying cannot log xcountry since (s)he did not perform the landing. I, personally, don't see it a problem...so why I'm reaching out for views.

You said landing singular. I said landings plural. If one pilot lands at the remote airport and the other lands back at home, then it’s 2 cross countries. Technically, if you don’t land at the remote airport it’s not even one cross country.

 

[MauleSkinner]

I happen to believe it legit. Just want to be sure cuz a lot of cfis don't think so. The reason I think it's hokey is I don't think this way provides real xcountry flying experience.

If you think it’s hokey, don’t do it.

 

[RussR]

This is what I'm hearing. What is your reasoning?

The FAA answered it pretty clearly in the 2009 Gebhart interpretation:
https://www.faa.gov/about/office_or...ps/2009/Gebhart_2009_Legal_Interpretation.pdf

"Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight."

 

[FlyBoyAndy]

I really do not understand this post. What am I missing?

 

[MauleSkinner]

I really do not understand this post. What am I missing?

Most aspiring pilots hate flying, and therefore want to do as little of it as possible.

 

[Salty]

Most aspiring pilots hate paying for flying, and therefore want to do as little of it on their own dime as possible.

FTFY

 

[RussR]

I really do not understand this post. What am I missing?

1. Instrument Rating requires 50 hours of XC.
2. Two pilots get together to build that time.
3. One pilot flies the plane under the hood, the other is safety pilot.
4. Both log PIC (there is long-standing precedence that this can be okay depending on the agreement between pilots) to build time.
5. Both log XC to build XC time.
6. This cuts their cost in half.

Except, everything is okay in that list EXCEPT #5. Both cannot log XC time, due to the FAA Chief Counsel document I posted above. @noahfong agrees with this but was looking for some legal basis.

 

[MauleSkinner]

FTFY

And in the process do as little flying as possible.

 

[Rgbeard]

If six pilots pile in a 6-place airplane, and all think about flying it, while one or two actually control the flight, perhaps all six could log PIC for the XC, as well as other pilots/friends that heard about the flight?

Seems as if it’s a great way to share costs and have a wildly under-prepared batch of magenta pilots.

 

[FlyBoyAndy]

1. Instrument Rating requires 50 hours of XC.
2. Two pilots get together to build that time.
3. One pilot flies the plane under the hood, the other is safety pilot.
4. Both log PIC (there is long-standing precedence that this can be okay depending on the agreement between pilots) to build time.
5. Both log XC to build XC time.
6. This cuts their cost in half.

Except, everything is okay in that list EXCEPT #5. Both cannot log XC time, due to the FAA Chief Counsel document I posted above. @noahfong agrees with this but was looking for some legal basis.

So you're saying if I fly 100nm to a destination and then my buddy fly's back to our field, we cannot log 100nm cross country each?

 

[Rgbeard]

So you're saying if I fly 100nm to a destination and then my buddy fly's back to our field, we cannot log 100nm cross country each?

Yours is legitimate and not how the I perceive the OP is intending it.

 

[noahfong]

The FAA answered it pretty clearly in the 2009 Gebhart interpretation:
https://www.faa.gov/about/office_or...ps/2009/Gebhart_2009_Legal_Interpretation.pdf

"Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight."

Exactly the kind of info I was hoping for. Thank you!

 

[RussR]

So you're saying if I fly 100nm to a destination and then my buddy fly's back to our field, we cannot log 100nm cross country each?

That is fine.

The OP's scenario is where there is, say, a 2-hour out and 2-hour back XC, with pilot and safety pilot switching at the halfway point, and both logging 4 hours of XC PIC. That's not legit.

The whole goal with this scenario is to save money. In your scenario, if they split costs, each pilot is paying for half of the trip, and is getting to log half the time. That's not saving money. In the OP's scenario, they would be splitting the cost but each logging the whole time. In other words, getting the time at half price. But it's not legit to get XC time this way.

 

[noahfong]

So you're saying if I fly 100nm to a destination and then my buddy fly's back to our field, we cannot log 100nm cross country each?

Some people are saying they can log 200 each. I'm checking out how legit that is. Thanks to RussR, we know the faa says it's not.

 

[noahfong]

That is fine.

The OP's scenario is where there is, say, a 2-hour out and 2-hour back XC, with pilot and safety pilot switching at the halfway point, and both logging 4 hours of XC PIC. That's not legit.

Correct. Thanks, Russ.

 

[SkyDog58]

Most aspiring pilots hate flying, and therefore want to do as little of it as possible.

It often does seem that way from reading many of the posts on here. Logging flight time should be looked at as fun, not a chore to be endured. Otherwise, GTFO.

 

[Lindberg]

If six pilots pile in a 6-place airplane, and all think about flying it, while one or two actually control the flight, perhaps all six could log PIC for the XC, as well as other pilots/friends that heard about the flight?

Seems as if it’s a great way to share costs and have a wildly under-prepared batch of magenta pilots.

The regulations are actually pretty clear on this, and there might even be a sticky thread on it here on this forum.

 

[midlifeflyer]

This is what I'm hearing. What is your reasoning?

A series of FAA Chief Counsel letters saying so.

 

[EdFred]

A series of FAA Chief Counsel letters saying so.

And the regs.

 

[Mxfarm]

And in the process do as little flying as possible.

that’s why we buy fast planes w/buttons to push

 

[RingLaserGyroSandwich]

The irony is part 141 totally avoids this problem. I didn’t need to meet the 50 hour requirement.

 

[RussR]

The irony is part 141 totally avoids this problem. I didn’t need to meet the 50 hour requirement.

The "problem" of acquiring useful real-world experience?

 

[midlifeflyer]

And the regs.

As someone else correctly pointed out the reg says "time acquired during flight" meeting certain requirements, none of which are that the pilot logging it is the sole manipulator of the controls the entire time.

That was a policy-based interpretation. In contrast, both the flying pilot and the nonflying pilot in a Part 135 2-pilot crew may log cross country time under the same reg.

 

[RingLaserGyroSandwich]

The "problem" of acquiring useful real-world experience?

More the problem of paying for it. You can definitely argue this isn't an actual "problem" (experience is good) although the big difference between Part 61 and Part 141 here does seem a bit odd.

 

[EdFred]

As someone else correctly pointed out the reg says "time acquired during flight" meeting certain requirements, none of which are that the pilot logging it is the sole manipulator of the controls the entire time.

That was a policy-based interpretation. In contrast, both the flying pilot and the nonflying pilot in a Part 135 2-pilot crew may log cross country time under the same reg.

Cross-country time means -
(i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight -
(A) Conducted by a person who holds a pilot certificate;
(B) Conducted in an aircraft;
(C) That includes a landing at a point other than the point of departure; and
(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

I guess I read the regulation a bit more strictly:

"Conducted by a person."
Not "...a person, or persons, or crew..."

Also: How does a person who never touches the controls perform a landing?

 

[RingLaserGyroSandwich]

I've done cross country flights where my CFI never touched the controls and I believe he logged it as cross country.

 

[EdFred]

I've done cross country flights where my CFI never touched the controls and I believe he logged it as cross country.

I don't log landings my students do as a CFI. No landing, no XC, unless being used for ATP (and I still don't log non-landing flights over 50 as XC) I put in the notes that it was an XC for a student, but I don't log it as such. Just PIC as allowed by 61.51(e)(3)

 

[Lindberg]

As someone else correctly pointed out the reg says "time acquired during flight" meeting certain requirements, none of which are that the pilot logging it is the sole manipulator of the controls the entire time.

That was a policy-based interpretation. In contrast, both the flying pilot and the nonflying pilot in a Part 135 2-pilot crew may log cross country time under the same reg.

That distinction makes sense though. A non-flying pilot may only log time if he's required to be there. A safety pilot under part 91 is only required when the pilot flying is under the hood. Unless he's landing under the hood, the safety pilot isn't required then. And he can't log anything during that time.

 

[RussR]

Cross-country time means -
(i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight -
(A) Conducted by a person who holds a pilot certificate;
(B) Conducted in an aircraft;
(C) That includes a landing at a point other than the point of departure; and
(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

I guess I read the regulation a bit more strictly:

"Conducted by a person."
Not "...a person, or persons, or crew..."

Also: How does a person who never touches the controls perform a landing?

I think the alternate way to read this (I don't agree with it, but I think this is what's being done by some) is that the flight WAS conducted by A PERSON (in an aircraft, included a landing, etc). It may not have been me, but it was definitely a person doing it, and the whole flight did qualify as a cross-country flight. And since as a safety pilot I was a necessary part of it given the hood-wearing going on, and I am able to log PIC, I should be able to log it as XC too, since it was a XC flight.

I don't think that's a totally unreasonable literal interpretation, BUT I also am happy with the FAA's interpretation that it does NOT count as XC for the safety pilot. I think that counting it as XC for the safety pilot defeats the whole intent of the XC requirement - since the safety pilot could literally just stare out the window and have no idea where they're going until they get there. Not exactly building valuable experience.

 

[Salty]

I still don't understand why one pilot doesn't fly the way out and land 50 miles xc done. Then the other flies the way back and lands 50 miles xc done. Within any interpretation of the rules, and doesn't cost a penny more.

I'm confused.

 

[EdFred]

I think the alternate way to read this (I don't agree with it, but I think this is what's being done by some) is that the flight WAS conducted by A PERSON (in an aircraft, included a landing, etc). It may not have been me, but it was definitely a person doing it, and the whole flight did qualify as a cross-country flight. And since as a safety pilot I was a necessary part of it given the hood-wearing going on, and I am able to log PIC, I should be able to log it as XC too, since it was a XC flight.

I don't think that's a totally unreasonable literal interpretation, BUT I also am happy with the FAA's interpretation that it does NOT count as XC for the safety pilot. I think that counting it as XC for the safety pilot defeats the whole intent of the XC requirement - since the safety pilot could literally just stare out the window and have no idea where they're going until they get there. Not exactly building valuable experience.

However, you aren't logging PIC (or at least not as allowed by regulation) while the landing is taking place. So for that time period you are logging nothing. Can't log, landing didn't happen (for you), no landing (for you), no XC (for you).

I still don't understand why one pilot doesn't fly the way out and land 50 miles xc done. Then the other flies the way back and lands 50 miles xc done. Within any interpretation of the rules, and doesn't cost a penny more.

I'm confused.

Because they can only log 1/2 the XC time. They are trying to double dip.