Logging of Cross-Country Time by Multiple Pilots, Draft Letter to Chief Counsel

[tlglenn]

I just posted this to the red board: http://forums.aopa.org/showthread.php?p=627380. I referred to some previous threads on the red board:

So, this issue came up in http://forums.aopa.org/showthread.php?t=34138 where I referenced another thread http://forums.aopa.org/showthread.php?t=12834 regarding the logging of cross-country time by more than one pilot e.g. safety pilot.

I am going to write the chief counsel a letter (the asst. CC for regulations already told me she'd have one of her staff look at it). Here's a draft (attachments A and B can be found in the second thread I mentioned above):

I wrote the FAA Western Pacific regional counsel requesting an opinion on the logging of cross-country time (see attachment A). The log number was GL-05-2-19. I received a response on March 28, 2006 from Monroe P. Balton (see attachment B). I posted my question and the legal opinion on the Aircraft Owners and Pilots Association (AOPA) web forum. The resulting discussion prompted me to forward this to your office.

I did make an error in my question when I stated: "I've seen legal interpretations stating that safety pilots cannot log cross-country (x-c) time..." and Mr. Balton noted my error when he wrote: "I am not aware of any interpretation that precludes a safety pilot from logging cross-country time." I was thinking of John Lynch's withdrawn FAQs when I wrote my statement.

There were several statements on the web forum including:
1) The legal opinion stated: "There is no legal definition of 'cross-country time.'" A response was: "14 CFR 61.1(b)(3)."
2) The legal opinion stated: "Flight Standards requires a landing before the flight time can be logged as cross-country, except for the military rated pilot". A response was: "You'll find that exception in 14 CFR 61.1(b)(3)(vii). However, you'll also find it in 14 CFR 61.1(b)(3)(vi) for anyone logging the time to meet ATP XC experience requirements..."
3) One person was surprised at, "...a Regional Counsel deferring to Flight Standards on the application of a regulation!"

In addition, I'm aware of other scenarios involving two pilots on a flight i.e. two pilots taking turns manipulating the controls.

Therefore, I am requesting a formal opinion from the chief counsel's office to the following questions:
Two pilots are sharing a flight. The characteristics of the flight are such that if only a single pilot was the sole manipulator of the controls during the entire flight then that pilot could log it as a cross-country flight (I am not referring to a specific definition of cross-country). If the two pilots were to take turns being sole manipulator of the controls then could both pilots log their individual flight times as cross-country (using the same definition of cross-country that the single pilot would use)? Would it matter which pilot executed the takeoff and which pilot executed the landing (keeping in mind that one definition of cross-country doesn't require a landing)? Would it matter which pilot was acting as pilot-in-command (PIC)? Suppose one pilot is acting as safety pilot to allow the other pilot to accumulate simulated instrument time. How would that affect the logging of cross-country time? Again, would it matter who executed the takeoff, executed the landing, or which pilot was acting as PIC? Would the current certificate level (i.e. sport, recreational, private, commercial, ATP) of a pilot matter? Would the desired certificate level being pursued by a pilot matter?

In addition, some definitions of cross-country hinge on the location of the, "Original point-of-departure." Is it permissible for a pilot to use a, "Repositioning flight" to change the original point-of-departure? For example, a pilot plans a flight from A to B to C to A. Neither B or C is a sufficient distance from A to meet the requirement that the pilot wishes to meet. The pilot notes, however, that either B or C is a sufficient distance from E to meet the desired requirement. So, the pilot flies from A to E and logs it in his or her logbook. Then the pilot flies from E to B to C to A and logs that as a separate flight in his or her logbook. Is the repositioning flight from A to E permissible to change the original point-of-departure for the second flight? If not, what could the pilot do to make it permissible e.g. wait overnight at E, pick-up or drop-off a passenger or cargo at E, have another pilot be sole manipulator between A and E for all or part of the flight, have another pilot be the acting PIC between A and E, etc.?

Comments or suggestions before I send this off?

 

[EdFred]

Be a bit more clear with what you are asking.

 

[Ted]

I would agree, it's a little unclear. It looks to me like you're asking if two pilots sharing a flight can both log time if they're on a cross-country, and then it looks like you're asking under what specific conditions they can log, and what exactly they can log. Giving scenarios to answer seems less clear to me.

It seems somewhat ambiguous and definitely a gray area. If nothing else, when I've flown with friends (including before I started flight training, and I am still a ways away from my PPL), I'm frequently told "Keep a look out for traffic." To me that makes me something of a safety pilot, although I can't log the time.

Please let us know what response you get once it's sent out and you hear back - I will be very interested!

 

[Eamon]

Cross country time is really any flight that leaves the airport pattern. It also means nothing really.

What you need to ask is when can it count for what..... Like.....

135.243 asks for 100 CC time. Can that time be as a safety pilot?

I would say no.


You can log every flight you make out of the pattern as CC time in your log book if you want, but that doesn't mean that the total number in that line will be good for what you need it for.

 

[jpflys]

I also think you need to break down questions at the end, so they can give a specific answer to EACH (as they like to do)

 

[kevin47881]

I would recommend using bullet points for each question. The middle paragraph is very difficult as it has multiple questions. Moreover, the A to B to... statement/question is difficult to follow. Consider bullet points for these items also.

My advise is worth every penny you paid

 

[MauleSkinner]

I would recommend specifying what type of two-pilot operation you are talking about...safety pilot? ACTING as PIC while a non-current pilot is flying the airplane? Flying a 757 that requires two pilots and pretty much throws out any definition of "sole manipulator of the controls" to start with? Flight instruction?

Obviously, if pilots are curious enough to write the Chief Counsel to find out if they can log cross-country, it's probably cross-country that applies to something...state what you want this cross-country time interpretation to apply to. "Additional certificates or ratings such as commercial (61.something), instrument rating (61.something else), ATP (61.something else yet), VFR or IFR 135 requirements (135.something)...

Don't be so vague in your question that the answer does no good. You're asking a very broad question that may have multiple answers, just like what counts as "cross-country" for a certificate or rating depends upon which certificate or rating you're talking about.

Fly safe!

David

 

[SkyHog]

No offense, but the letter is way too wordy. You would be more effective to just say:

"I would like to know if two pilots can log cross country time while one is using a view limiting device."

Its a lot more precise. These guys are busy, and there's no reason for them to have to read a bunch of words that essentially process into that one sentence.

 

[JimNtexas]

Please don't send that letter. There are two outcomes, either they will ignore it in which case you've wasted a stamp, or they'll try an answer it, and the answer will add yet more regulations to flying, as if we needed any more.

But if you must ask the question (to which I suspect you can't stand the answer) please understand that there are no rules about what anyone can 'log'. You can 'log' anything you want, including MS flight sim time, bicycle time, or time sitting on the john.

Off the top of my head there are cross country experience requirements for private, commercial, and ATP certificates. Limit your question to the experience requirements that interest you.

 

[Greg Bockelman]

No offense, but the letter is way too wordy. You would be more effective to just say:

"I would like to know if two pilots can log cross country time while one is using a view limiting device."

Its a lot more precise. These guys are busy, and there's no reason for them to have to read a bunch of words that essentially process into that one sentence.

We are talking LAWYERS here Nick. They LIVE for words. The more the better. The more convoluted and confusing the better. That is what keeps them in business.

 

[etsisk]

oops - see below!

 

[Dwight B. Van Zanen]

Cross country time is really any flight that leaves the airport pattern. It also means nothing really.

What you need to ask is when can it count for what..... Like.....

135.243 asks for 100 CC time. Can that time be as a safety pilot?

I would say no.


You can log every flight you make out of the pattern as CC time in your log book if you want, but that doesn't mean that the total number in that line will be good for what you need it for.

For the IR it asks for 50 hours CC as PIC time. If you can log it as CC and you can log it as PIC while Safety Pilot, I am not sure why it would not count. Perhaps you can explain that. I did not have any time like that for my IR, so the issue did not come up. It does seem to conflict with the purpose a little, though the purpose of the 50 hours is not entirely clear. Not required for a Part 141 school anyway, as I understand it.

 

[etsisk]

I would hope that you would focus first on having them clarify the basic definition of xc time (as used for training purposes). As Ron Levy wrote, on another thread:

"(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."

Send the FSDO a letter (with a cc: to the Regional Counsel's office) detailing the conversation [I had a convo with the FSDO where they said you have to have an initial leg of >50nm] and requesting a written answer signed by the Regional Counsel (or the Chief Counsel's Office) which says that 14 CFR 61.1(b)(3)(ii) (quoted above) means "THE FLIGHT MUST INCLUDE ONE LEG OF MORE THAN 51nm LENGTH FROM THE ORIGINATING AIRPORT." That should fix the problem.

THEN ask 'em about safety pilots. But we need to know the definition - 'cause the FSDOs think the reg means you HAVE to have an initial leg of more than 50 nm. And the regs say otherwise.

 

[taters]

I would hope that you would focus first on having them clarify the basic definition of xc time (as used for training purposes). As Ron Levy wrote, on another thread:



THEN ask 'em about safety pilots. But we need to know the definition - 'cause the FSDOs think the reg means you HAVE to have an initial leg of more than 50 nm. And the regs say otherwise.

for the Private Pilot certificate (see FAR 61.109(b)(2)):
Dual cross-country: no restrictions. Solo cross-country: more than 50nm from the point of departure.

for the Instrument rating (see FAR 61.65(e)(1)):
more than 50nm from the point of departure.

for the Commercial certificate (see FAR 61.129(b)(3)(ii):
more than 50nm from the point of departure.

for the ATP certificate (see FAR 61.155(b)(2)):
no restrictions

 

[etsisk]

no, we UNDERSTAND the distances - but the question is, do you have to have a LEG of that distance for the thing to qualify? FAR says you have to have a LANDING at a point more than 50nm from departure (for inst.). But you could do that with a series of flights to airports 15 miles away from each other, till you got to number 4, which would be 60nm from the point of departure. You've flown 60 miles away, right? FSDO says it's NOT xc, because you don't have a LEG of more than 50 nm. FAR doesn't say anything about requiring a LEG of >50 nm. There's the rub.

 

[poadeleted20]

If you're going to ask this question of the Chief Counsel's office (via the RC), I'd keep it simple, but within the parameters of John Lynch's response when I asked that question back when the Part 61 FAQ file was "official policy." Suggest the following:

A question has arisen about the logging of Cross-Country time by a pilot acting as SIC. Previous guidance on this issue provided by AFS-800 in the Part 61 FAQ file has been declared "no longer official," leaving the question open at this time. Request a legal opinion on the following scenarios, all including a landing more than 50 nm from the original point of departure.

1. Two Private Pilots, both rated in the aircraft, are flying together. One is acting as PIC and sole manipulator while wearing a vision restricting device. The other is acting as SIC safety pilot as required by 14 CFR 91.109(b). May the SIC safety pilot log the time as "cross country" pilot time applicable under 14 CFR 135.243(b)(2) as well as second-in-command flight time?
2. Two commercial pilots, both qualified in their positions, are acting as PIC and SIC as required by regulations for a flight made under Part 135. The PIC is the sole manipulator of the controls. May the SIC pilot log the time as "cross country" pilot time applicable under 14 CFR 135.243(b)(2) as well as second-in-command flight time?
3. An ATP and a commercial pilot, both qualified in their positions, are acting as PIC and SIC as required by regulations for a flight made under Part 121. The PIC is the sole manipulator of the controls. May the SIC pilot log the time as "cross country" pilot time applicable under 14 CFR 135.243(b)(2) as well as second-in-command flight time?

Thank you.
/s/ You
Address
Phone number

That should do it. If you want to add other scenarios (such as trading sole manipulator duties), add them in equally succinct fashion. Note that outside of flight training from an instructor, there is no requirement in Part 61 in which XC time other than as PIC matters. The only place I can find in any regs in which that SIC XC time might have applicability would be the Part 135 reg cited above.

 

[Dwight B. Van Zanen]

I would hope that you would focus first on having them clarify the basic definition of xc time.....But we need to know the definition - 'cause the FSDOs think the reg means you HAVE to have an initial leg of more than 50 nm. And the regs say otherwise.

This seems to be wide open for local FSDO mis-interpretation. When the XC question is asked, a lot of issues need to be addressed. Like:

1. The XC that goes to 3 or 4 airports, with one near the middle that is at least 51 NM from the point of origin for the flight. Based on the rule, if ANY airport is over 50 NM from the point of origin, the whole flight is XC.

2. The XC that involves a flight 40 NM north, 80 NM south, 40 NM north to point or origin. In this case NO airport is more than 50 NM from the point of origin, even though one leg is 80 NM. In this case, if you log two flights - one 40 NM north that is not XC for positioning, and a second that IS clearly XC that has a new point of origin with an initial leg of 80 NM, that second flight seems to meet the requirements with no problems. Including adding a second XC 40 NM leg to the initial 80 NM leg that clearly meets the XC requirements. Are the skills any different? Perhaps if any leg is over 50 NM the whole flight ought to count as XC? But the rule does not say that now.

3. And then the issue of, if they say the initial leg needs to be at least 51 NM, ask them why. A 60 NM out, with a 40 and a 30 NM leg back; vs a 40 and a 30 NM legs out, and a 60 NM leg back. I don't see that the navigation skills needed are any different. In fact, the 40 + 30 legs out, and 40 + 30 legs back are all same same. Using the airport as a checkpoint, vs landing at the airport to terminate a leg - the only real difference is you log another landing and get a little more pattern experience.

4. Other issues?

 

[Maxmosbey]

I am going to fly to an airport that is 46.7nm away from my home airport, to get some dutch letters. So suppose I want to take advantage of this flight to log cross country time. Can I take a somewhat circuitous route there and back, so that it equals 50nm. For example, can I take a little trip around town, before I head out for the destination airport, or can I just fly to a predetermined point four miles further out when I leave the pattern before I take up my course?

I guess that I am asking somewhat the same question as DBVZ.

MAX

 

[tonycondon]

max, a landing has to be made more than 50 miles away from departure, no s turning allowed

 

[Maxmosbey]

max, a landing has to be made more than 50 miles away from departure, no s turning allowed

OK, so how about if I fly over to Boone and have coffee with Dave (10.7nm), then fly from there to Pella (56.2nm). Then I fly home (46.7nm). Is that whole trip then a cross country by definition?

 

[tonycondon]

no, you would have to log it as follows:
AMW-BNW - non cross country (repositioning flight)
BNW-PEA-AMW - cross country

Im sure if im wrong Ron or some of the other FAR wizards will correct me

 

[Dwight B. Van Zanen]

no, you would have to log it as follows:
AMW-BNW - non cross country (repositioning flight)
BNW-PEA-AMW - cross country

Im sure if im wrong Ron or some of the other FAR wizards will correct me

Looks right to me. And all you need to do is land, no coffee required.

 

[Greg Bockelman]

no, you would have to log it as follows:
AMW-BNW - non cross country (repositioning flight)
BNW-PEA-AMW - cross country

Im sure if im wrong Ron or some of the other FAR wizards will correct me

Not Ron, but I do think you are wrong. If it comes down to a determination, I believe the feds will not count AMW-BNW as a reposition. They will count AMW as the ORIGINAL point of departure, and PEA isn't far enough to count.

The FAR's make reference to the original point of departure, and that would be Ames.

 

[Maxmosbey]

Looks right to me. And all you need to do is land, no coffee required.

Probably not required, but I can't see landing over there and not stopping in.

 

[tonycondon]

i probably wouldnt argue with that Greg. In the zillions of threads before on this subject i recall some mention of a 'repositioning' option, but i do remember there being some contention on what qualifies and what does not.

 

[Maxmosbey]

Considering my plans for the future, I think I'll just run over to get the dutch letters, and call it mission accomplished. I was just wondering how it worked. Thanks..

 

[tonycondon]

yea max, i dont think it will hurt you any to not have the few hours of cross country time, and you'll have a good time in pella.

 

[poadeleted20]

The issues discussed have never been adjudicated by the FAA Chief Counsel's office. However, AFS-800 has said in the Part 61 FAQ file what they intended the rules to mean when they wrote them, and AGC-200 tends to give that great weight in their interpretations unless the legal reading of the rule directly contradicts that intent (e.g., the use of the clearly-defined word "rated" in the regulation on when you can log sole-manipulator time in the PIC column of your log book).

In the issue of whether you can count any part of the 40N-80S-40N flight as XC time for Pvt/IR/Comm, AFS-800 said:

As per § 61.1(b)(3)(ii)(B ), the rule requires for private pilot certification in an airplane, each cross country must be “. . . (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” Emphasis added: “a point of landing.” Meaning, you can land as often as you want, but one of the landings must be more than 50 nautical miles from the original point of departure.


As for the repositioning issue, AFS-800 said:

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.

Under that interpretation, the 40N-80S-40N scenario would not include "a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure." Note that they specifically included the word "original" in that reg. As that would be unnecessary if "repositioning" flights were to be allowed, the intent of the rule seems clear enough to me.

Whether the FAA Chief Counsel's office will come up with a different interpretation from AFS-800's stated intent is anyone's guess, but unless/until they do, I strongly recommend that people use the above-stated no-longer-official guidance in choosing what to log as XC time for Pvt/IR/Comm. Yes, it is possible that repositioning as discussed above may someday be endorsed by AGC-200, but I think it unlikely, and you could spend a lot of money on flights which don't count. OTOH, if you take the more conservative approach and don't consider "repositioning," you are guaranteed that your flight will count.

That said, I don't think there's any wriggle-room in the "straight-line distance" part -- if you want to go somewhere 46.7nm away and have the flight count, do a touch-and-go at another airport at least 3.4nm beyond your intended full-stop destination.

 

[Dwight B. Van Zanen]

Not Ron, but I do think you are wrong. If it comes down to a determination, I believe the feds will not count AMW-BNW as a reposition. They will count AMW as the ORIGINAL point of departure, and PEA isn't far enough to count.

The FAR's make reference to the original point of departure, and that would be Ames.

The determination is made on a flight by flight basis. Not day by day. No limit to the number of flights you can have in a day. Flight schools where I am do this all the time. Relocate the plane and pilot with one flight, so that a subsequent flight will qualify as an XC. It is a matter of how you log it. If you log it as one flight, the first repositioning leg starts the flight and is the "original point of departure" for that flight. If you log it as two flights, you have an "orginal point of departure" for each flight. No problems. The wording is because for an XC you could have 5 legs all less than 50 NM. But to qualify you need to get at least 50 NM from some "original point of departure" for what you log as an XC, and you would never do it if each leg were another separate flight. So they let you assemble an XC with short legs.

 

[poadeleted20]

The determination is made on a flight by flight basis. Not day by day. No limit to the number of flights you can have in a day. Flight schools where I am do this all the time. Relocate the plane and pilot with one flight, so that a subsequent flight will qualify as an XC. It is a matter of how you log it. If you log it as one flight, the first repositioning leg starts the flight and is the "original point of departure" for that flight. If you log it as two flights, you have an "orginal point of departure" for each flight. No problems. The wording is because for an XC you could have 5 legs all less than 50 NM. But to qualify you need to get at least 50 NM from some "original point of departure" for what you log as an XC, and you would never do it if each leg were another separate flight. So they let you assemble an XC with short legs.

Based on what AFS-800 has said in the past, I don't think they would agree that your flight schools are doing it the way AFS-800 wanted it done when AFS-800 wrote that reg. AFS-800's statements suggest that they think there is one, and only one, "original point of departure" on training flights, and that point is where the pilot and aircraft started together, whether on that day or a prior day. Whether AGC-200 would find those schools' practice acceptable or not based on a legal interpretation of the reg as written is so far unknown, but personally, I don't think it's worth the risk in order to save 10 or 20 miles of flying. Caveat Aviator.

 

[nosehair]

Dual cross-country: no restrictions.

Did no one see this? As far as I can determine, the definitiion of Cross-Country in 61.1 includes a landing more than 50 nm, and the requirements for PP certification say 3 hours of CC training. That looks like at least 3 hours with at least two landings (1 day and 1 night) at points more than 50 nm. for dual CC training.

 

[poadeleted20]

Did no one see this? As far as I can determine, the definitiion of Cross-Country in 61.1 includes a landing more than 50 nm, and the requirements for PP certification say 3 hours of CC training. That looks like at least 3 hours with at least two landings (1 day and 1 night) at points more than 50 nm. for dual CC training.

Pretty close. There are actually seven different definitions of XC in that section, but the one that concerns folks going for their Private, IR, or Commercial in an Airplane is the one that says "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 that applies to both training ("dual") and solo flights used to meet 61.109, 61.65, and 61.129. One of the "gotchas" on the long 3-approach IFR XC for 61.65(d)(ii)(3) is forgetting to do at least a touch-and-go at one of the other airports more than 50nm from the OPD -- if it's all low/missed approaches at the outlying airports (i.e., that line in the log says "1" in the landings column), it doesn't meet the regulatory requirement.

That said, it's possible to have only one dual landing out beyond 50nm for PVT -- do a day dual XC out, and a night dual XC back (or vice versa, if you like overnights). However, I personally prefer that my trainees get at least two day dual XC's before first solo XC, so that point is moot for my students.

 

[tonycondon]

i do the day out, night back thing fairly regularly, as i like to have my students fly me to my hometown for some good Pizza. I always do at least one other XC with them dual though before signing off for Solo XC.

 

[Dwight B. Van Zanen]

Based on what AFS-800 has said in the past, I don't think they would agree that your flight schools are doing it the way AFS-800 wanted it done when AFS-800 wrote that reg. AFS-800's statements suggest that they think there is one, and only one, "original point of departure" on training flights, and that point is where the pilot and aircraft started together, whether on that day or a prior day. Whether AGC-200 would find those schools' practice acceptable or not based on a legal interpretation of the reg as written is so far unknown, but personally, I don't think it's worth the risk in order to save 10 or 20 miles of flying. Caveat Aviator.

Now we get into what the meaning of "is" is. In this case, what is a "training flight"? I don't recall if I had any XC time like this in my book for the PP. I did not for the IR. I do know both the CFII's noted that the distance was for the flight, and to log accordingly. Two different flight schools that train a lot of folks, and the log book reviews seem to pass muster with the flight examiners. And it meets the letter of the regulation. If it was a problem I would have thought something would have changed years ago. Perhaps a different FSDO would have another interpretation? Or, the flight examiners have not noticed over these many years? I don't know. Not a question I want to ask, and get an answer I may not like. I have no plans to fly professionally, so at this point I am in the "no one cares" group for what I log or don't log.

 

[poadeleted20]

In this case, what is a "training flight"?

A flight in which time is logged in the "training received" column, and which is planned to be used to meet the requirements for an FAA pilot certificate/rating. And I don't think that's a particularly obscure meaning.

the log book reviews seem to pass muster with the flight examiners.

I don't put much stock in what individual examiners say about the regs unless they're someone like Frank Phillips, who is a retired FAA counsel. I've seen a lot of examiners pass on things which the Chief Counsel says are unacceptable, and decline stuff the Chief Counsel says is kosher.

And it meets the letter of the regulation.

Is that your opinion or the Chief Counsel's? If it isn't the latter, it doesn't have any legal weight.

Perhaps a different FSDO would have another interpretation?

FSDO's aren't permitted to make interpretations. They have to ask the FAA Chief or Regional Counsel for that. It's when they start "rolling their own" that things get fouled up.

I have no plans to fly professionally, so at this point I am in the "no one cares" group for what I log or don't log.

No problem there, but for us instructors, it matters not only what is on our logs, but what is in our students' logs.

 

[Maxmosbey]

-- if you want to go somewhere 46.7nm away and have the flight count, do a touch-and-go at another airport at least 3.4nm beyond your intended full-stop destination.

That solution came to me today. It seems like the logical approach to the issue. But let me ask you to clarify something, are you saying that you only have to reach a destination that it over 50nm from the departure airport? In other words, do you have to have a leg of the cross county over 50nm, or do you just have to get 50nm from home? In layman's terms please..

 

[Dwight B. Van Zanen]

A flight in which time is logged in the "training received" column, and which is planned to be used to meet the requirements for an FAA pilot certificate/rating. And I don't think that's a particularly obscure meaning.

No, its not. But it does not rule out more than one training flight, one after the other, one not XC and the second an XC. And meeting the letter of the rule is my reading of the plain language, apparently the same reading as the CFI's I talked to. I am not arguing with you. Just saying it looks like it fits the rule. And until we see a ruling that says it does not, and the examiners (here) are accepting the time, I would be inclined to count it. But, as you said, it would be simpler and safer to just go a little farther to an airport that leaves no doubt - a little more distance and a little more time and no chance of it being excluded by someone with your interpretation. But sometimes the situation just happens, not as any kind of manipulation of the rule.

Here is an example:

I fly 20NM south to go to an airport with an avoinics shop to get some work done, or perhaps to get my VOR test done at a VOT. I then start a flight to an airport 60 NM north to meet a friend for lunch. Then about 40 NM south again back to the home drome. (it happens we use a shop about 20 NM south) Two or perhaps three flights, none a training flight. At least two distinct purposes for flying. But if I log the second and third legs as an XC going for lunch, it could be counted for XC as PIC time. If I log them all as one "flight" it is not XC at all. If I log them as three separate flights the second one could be a 60 NM XC. According to how the plane language of the rule reads anyway. The FAA seems to take into account the "purpose" of the flight when dealing with a common purpose issue regarding compensation.

If this situation comes up, I would likely log something as XC due to the 60 NM leg. Someone disputes that, fine. I don't need the XC time for anything. It is my log. I can't see how it violates any rules to log it that way.

 

[Dwight B. Van Zanen]

That solution came to me today. It seems like the logical approach to the issue. But let me ask you to clarify something, are you saying that you only have to reach a destination that it over 50nm from the departure airport? In other words, do you have to have a leg of the cross county over 50nm, or do you just have to get 50nm from home? In layman's terms please..

Ron should respond, but that is the central issue. The plain language is you need to land somewhere at least 50 NM from origin. The rule DOES NOT specify a 50 NM leg. They know how to do that when that is what they mean, as for the long XC where a minimum leg length IS specified. From that it is reasonable to conclude you can have more than one leg as long as you land somewhere at least 50 NM from the origin of that flight, to count it as XC.

As the side issue above, I contend that is also why the language includes the wording, "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" Otherwise, if you have multiple legs, you may NEVER get more than 50 NM from the point of departure for each individual leg, and it could look like none of it would qualify. "Original" just allows building a 50 NM XC with short legs.

But Ron has been doing this a long time. His opinion is usually safe, if perhaps a little conservative on this issue.

 

[Skip Miller]

The plane language is you need to land somewhere at least 50 NM from origin. The rule DOES NOT specify a 50 NM leg.

Just to point out the absurdity to those who do not parse the FARs for fun, it is perfectly legal to fly from your home drome to an airport 50.1+ miles from home, return, and spend the next three hours doing TnGs at home. All that time, including your home drome TnGs counts as x-c time.

Now the intent of the reg is to have students gain x-c experience and the last 3 hours of this flight as stated does nothing to fill that corner of your experience bag. But it is legal.

-Skip

 

[poadeleted20]

That solution came to me today. It seems like the logical approach to the issue. But let me ask you to clarify something, are you saying that you only have to reach a destination that it over 50nm from the departure airport? In other words, do you have to have a leg of the cross county over 50nm, or do you just have to get 50nm from home? In layman's terms please..

As the regulation says, the flight must include a landing (that's "a," which is singular) at a point more than 50nm from the original point of departure. That's all. You can land as many times at as many different places between the OPD and the point over 50nm away as long as you do make that landing (T&G or FS) more than 50nm from the OPD. If you do that, the entire flight counts towards your XC requirements for PP/IR/CP in an airplane. Individual leg length is not an issue.

Note that just "get[ting] 50nm from home" isn't enough -- overflights don't count. You must make a landing somewhere more than 50nm from the OPD for the flight to count for this purpose (the rules are different for ATP).