Meaning of "Directed Routing" Under FAR 61.65

[SoCal 182 Driver]

FAR 61.65(d)(2)(ii)(A) provides that one of the qualifications for an instrument rating is that the pilot have "a flight of 250 nautical miles along airways or by directed routing from an air traffic control facility."

I had an interesting discussion today with a fellow IFR student and our CFII about the definition of "directed routing" in the context of calculating the miles in a cross-country flight. We could not find any official FAA guidance on what this phrase means. So, does anyone have any insight on how this phrase is defined in the context of calculating miles in a cross-country flight for purposes of meeting this qualification?

Thanks!

 

[Sluggo63]

I think it’s a catch-all to prevent penantry. Like you plan your cross-country on airways, then ATC sends you direct from one NAVAID to another. This way some sea lawyer doesn’t come along and say “your cross-country doesn’t count because you weren’t on an airway for the ATC directed part.

 

[SoCal 182 Driver]

I think it’s a catch-all to prevent penantry. Like you plan your cross-country on airways, then ATC sends you direct from one NAVAID to another. This way some sea lawyer doesn’t come along and say “your cross-country doesn’t count because you weren’t on an airway for the ATC directed part.

That was exactly our discussion. What happens when someone plans a cross-country, with departures, approaches, etc., that equals 250+ miles, but then ATC vectors the pilot off the airways, like in a situation you mention, where the instruction is to fly from Navaid to Navaid? Does the mileage spent under ATC control, but off airways, approaches, etc., count toward the 250 miles?

 

[Groundpounder]

That was exactly our discussion. What happens when someone plans a cross-country, with departures, approaches, etc., that equals 250+ miles, but then ATC vectors the pilot off the airways, like in a situation you mention, where the instruction is to fly from Navaid to Navaid? Does the mileage spent under ATC control, but off airways, approaches, etc., count toward the 250 miles?

"I'd like to stay on my filed route, please".

 

[SoCal 182 Driver]

"I'd like to stay on my filed route, please".

But let’s say you don’t do that, and get vectored. How does the vectoring off-airway impact the mileage?

 

[dmspilot]

But let’s say you don’t do that, and get vectored. How does the vectoring off-airway impact the mileage?

Depends on whether the vector makes your flight shorter or longer. The distance that counts is the actual distance you fly.

 

[SoCal 182 Driver]

Depends on whether the vector makes your flight shorter or longer. The distance that counts is the actual distance you fly.

That was the position I took during the conversation. Do you have any authority for that proposition?

 

[midlifeflyer]

That was exactly our discussion. What happens when someone plans a cross-country, with departures, approaches, etc., that equals 250+ miles, but then ATC vectors the pilot off the airways, like in a situation you mention, where the instruction is to fly from Navaid to Navaid? Does the mileage spent under ATC control, but off airways, approaches, etc., count toward the 250 miles?

One reason to create the 250 based on point to point distances.

 

[dmspilot]

That was the position I took during the conversation. Do you have any authority for that proposition?

What other position is there?

 

[SoCal 182 Driver]

What other position is there?

That time/mileage spent being vectored didn't count towards the 250...

 

[dmspilot]

That time/mileage spent being vectored didn't count towards the 250...

Why wouldn't it count?

 

[midlifeflyer]

That time/mileage spent being vectored didn't count towards the 250...

I'm with @dmspilot on this one.why wouldn't

"250 nautical miles ... directed routing from an air traffic control facility"

not count toward

"a flight of 250 nautical miles along airways or by directed routing from an air traffic control facility"?

 

[Groundpounder]

But let’s say you don’t do that, and get vectored. How does the vectoring off-airway impact the mileage?

Who cares? No one is going to scrutinize it that closely.

 

[SoCal 182 Driver]

Who cares? No one is going to scrutinize it that closely.

Also a position I took during the discussion.

 

[SoCal 182 Driver]

I'm with @dmspilot on this one.why wouldn't

"250 nautical miles ... directed routing from an air traffic control facility"

not count toward

"a flight of 250 nautical miles along airways or by directed routing from an air traffic control facility"?

I don't disagree, but our CFII seemed to think that time/miles spent on the actual approach or SIDS departure, and/or time/miles spent being vectored, didn't count toward the 250.

 

[Clip4]

Aren’t all IFR flights in controlled airspace as directed by ATC?

 

[luvflyin]

Let’s see what a DPE thinks. @Ryan F. , you still around here?

 

[Larry in TN]

Aren’t all IFR flights in controlled airspace as directed by ATC?

No.

There are significantly portions of the globe that have uncontrolled airspace up to very high altitudes. I've operated from an airport, FJDG, above which the floor of controlled airspace is FL245.

There used to be large areas of uncontrolled airspace in the CONUS but they are almost all gone now.

 

[SoCal 182 Driver]

Let’s see what a DPE thinks. @Ryan F. , you still around here?

This whole discussion came up in the context of my friend getting signed off for his check ride tomorrow. Our CFII was questioning whether his cross country, which was signed off by another CFII, met the mileage requirements. The DPE who is doing the check ride said that he thought the mileage was sufficient, but that ultimately it was up to the current CFII to make that determination and sign him off for the check ride.

 

[Lindberg]

I don't disagree, but our CFII seemed to think that time/miles spent on the actual approach or SIDS departure, and/or time/miles spent being vectored, didn't count toward the 250.

This language is in contrast to other cross-country-experience requirements where the distance is measured over a "straight-line distance," i.e., irrespective of your actual route of flight. For this cross-country, the distance is measured along your route of flight, as long as it is "along airways or by directed routing from an air traffic control facility." It's not clear what basis your CFII has for his position that portions of your route where you're vectored by ATC don't count, since that's the opposite of what the regulation says.

ETA: Is he perhaps reading "directed" as "direct"?

 

[SoCal 182 Driver]

It's not clear what basis your CFII has for his position that portions of your route where you're vectored by ATC don't count, since that's the opposite of what the regulation says.

You're preaching to the choir! One of my main arguments was that the statute's plain language is "directed" by ATC. You, as the pilot, have set out a flight plan along airways that totals 250(+) miles. Any deviation from that because ATC has "directed" you to do so should still count, IMHO. After all, isn't being vectored by ATC part of what happens in IFR flight? Why should vectoring not count as part of the 250 miles?

ETA: Is he perhaps reading "directed" as "direct"?

At one point, I thought this was the case, and pointed out that the language was "directed."

 

[Clip4]

No.

There are significantly portions of the globe that have uncontrolled airspace up to very high altitudes. I've operated from an airport, FJDG, above which the floor of controlled airspace is FL245.

There used to be large areas of uncontrolled airspace in the CONUS but they are almost all gone now.

I agree, but where have you flown in controlled airspace that wasn’t ATC directed. Even when cleared as filed you have been directed to follow your flight plan routing.

 

[Mongoose Aviator]

Is it possible the CFII is using this as an excuse and has another unstated reason for not wanting to provide the sign-off?

 

[SoCal 182 Driver]

Is it possible the CFII is using this as an excuse and has another unstated reason for not wanting to provide the sign-off?

Not that I'm aware of. the CFII called and scheduled the check-ride, everything appeared good-to-go, and then this issue came up when she did a final review of the log book. The student's former CFII signed-off the cross-country, and the current CFII was questioning the mileage calculations.

 

[Larry in TN]

I agree, but where have you flown in controlled airspace that wasn’t ATC directed. Even when cleared as filed you have been directed to follow your flight plan routing.

It's not controlled airspace but IFR aircraft are operating there and it is not controlled by ATC.

 

[Pinecone]

Hmmm, so according to this CFI the first and last part of my flight on Monday would not count as my clearance was, "Cleared to XYX via Radar Vectors to ABCDE then as filed...."

And at the end, they cleared me Direct to ABC then Direct to DEF. Not to mention the mid flight direct to LMN that cut 20 minutes off the time enroute.

 

[luvflyin]

I don't disagree, but our CFII seemed to think that time/miles spent on the actual approach or SIDS departure, and/or time/miles spent being vectored, didn't count toward the 250.

Strange logic. I'd be inclined to ask her what color the sky is in her world. Yeah yeah, snarky. But coming from a CFII?? So is she gonna do it? Not let him go for the check ride until he does a cross country according to her interpretation?

 

[SoCal 182 Driver]

So is she gonna do it? Not let him go for the check ride until he does a cross country according to her interpretation?

After lots of back-and-forth, the DPE agreed it was OK, but left the ultimate decision to the CFII. She finally agreed to sign him off. He went yesterday for the check-ride. They started late (2:45 pm). and the oral exam was 2+ hours. He passed the oral, but they decided to discontinue and do the flight portion on another day.

 

[luvflyin]

After lots of back-and-forth, the DPE agreed it was OK, but left the ultimate decision to the CFII. She finally agreed to sign him off. He went yesterday for the check-ride. They started late (2:45 pm). and the oral exam was 2+ hours. He passed the oral, but they decided to discontinue and do the flight portion on another day.

Glad to see she's seen the light.

 

[Pinecone]

Also, look at the intent. The intent is for the student to do a longish flight IN THE SYSTEM. With may include actually flying the route that they got from clearance delivery or one that includes many reroutes.

My only concern would be if the gave you reroutes that you ended up with 249 NM. I would plan the trip such that the airport is more than 250 nm away, no way to get routed to less than 250 NM.

 

[Ryan F.]

Interesting conversation. @luvflyin yes, I'm still here!

Here's what we're talking about, from 14 CFR 61.65(d). We need to look at both (ii) and (ii)(a).

"(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves -
(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;"
​

Parsed simply, the requirements: file an IFR flight plan. Fly under IFR. Fly 250nm either along airways or by directed routing from an air traffic control facility.

Essentially, this accounts for the possibility of random routing or vectors from ATC while flying under IFR, vs. simply sticking to the airways. One thing that's patently clear is that it's 250nm - period. It can't be 249nm. Burden of proof is on the applicant to show that 250nm was achieved.

The simple way to do this is to select great-circle routes which add up, between airports, to >=250nm, with due respect given to the definition of cross-country flight. It's an open and shut discussion between applicant and evaluator. Incidentally, this is also what I recommend when feasible.

Otherwise, the applicant needs to demonstrate that the 250nm requirement was met. I have been involved in these situations from time to time. Usually, they're able to provide a flight planned route that shows >250nm.

Hope this helps.

 

[midlifeflyer]

Essentially, this accounts for the possibility of random routing or vectors from ATC while flying under IFR, vs. simply sticking to the airways. One thing that's patently clear is that it's 250nm - period. It can't be 249nm. Burden of proof is on the applicant to show that 250nm was achieved.

The simple way to do this is to select great-circle routes which add up, between airports, to >=250nm, with due respect given to the definition of cross-country flight. It's an open and shut discussion between applicant and evaluator. Incidentally, this is also what I recommend when feasible.

Otherwise, the applicant needs to demonstrate that the 250nm requirement was met. I have been involved in these situations from time to time. Usually, they're able to provide a flight planned route that shows >250nm.

Hope this helps.

Exactly.

also...

Also, look at the intent.
The intent is for the student to do a longish flight IN THE SYSTEM. With may include actually flying the route that they got from clearance delivery or one that includes many reroutes.

This.

I cringed at some comments suggesting rejecting shortcuts so the well planned 250.1 NM airway flight doesn't get shortened by a shortcut or, heaven forbid, being cleared direct! The dual cross country is the one and only requirement for the rating that has even a hint of a real IFR flight. Don't shortchange it.

 

[RussR]

Exactly.

also...

This.

I cringed at some comments suggesting rejecting shortcuts so the well planned 250.1 NM airway flight doesn't get shortened by a shortcut or, heaven forbid, being cleared direct! The dual cross country is the one and only requirement for the rating that has even a hint of a real IFR flight. Don't shortchange it.

I agree to not shortchange this most valuable of flights, but the couple times that I have had students fly a less-than-250nm-point-to-point IFR XC was specifically because certain airports presented certain approaches that worked into training objectives I had for them. For example, one flight had one airport with a DME arc into a LOC-only approach, followed by a relatively quick setup into an ILS approach into a Class C airport. Then back home it was a VOR approach. Point-to-point distance to these two airports and back to home was only 237.7 nm, but for the training value offered, I felt it was appropriate. And that DME arc, missed, and hold certainly added well more than 13 nm to the flight distance, not to mention the vectors for the VOR back home.

And I can't remember if ATC offered us shortcuts to that first airport, but if they did, I would have rejected them. Yes, I want to fly the DME arc even if you can give us vectors, that's the point of the exercise.

Of course, with GPS track logging, and ADS-B, the distance is easily proven. Even flightaware gives a "total distance flown", like this from a recent flight of mine (not an IFR training XC flight):

 

[NealRomeoGolf]

I agree to not shortchange this most valuable of flights, but the couple times that I have had students fly a less-than-250nm-point-to-point IFR XC was specifically because certain airports presented certain approaches that worked into training objectives I had for them. For example, one flight had one airport with a DME arc into a LOC-only approach, followed by a relatively quick setup into an ILS approach into a Class C airport. Then back home it was a VOR approach. Point-to-point distance to these two airports and back to home was only 237.7 nm, but for the training value offered, I felt it was appropriate. And that DME arc, missed, and hold certainly added well more than 13 nm to the flight distance, not to mention the vectors for the VOR back home.

And I can't remember if ATC offered us shortcuts to that first airport, but if they did, I would have rejected them. Yes, I want to fly the DME arc even if you can give us vectors, that's the point of the exercise.

Of course, with GPS track logging, and ADS-B, the distance is easily proven. Even flightaware gives a "total distance flown", like this from a recent flight of mine (not an IFR training XC flight):

View attachment 115631

I rejected direct on my XC IR training flight because I wanted to fly the arc. The controller was dumbfounded.

 

[midlifeflyer]

I agree to not shortchange this most valuable of flights, but the couple times that I have had students fly a less-than-250nm-point-to-point IFR XC was specifically because certain airports presented certain approaches that worked into training objectives I had for them. For example, one flight had one airport with a DME arc into a LOC-only approach, followed by a relatively quick setup into an ILS approach into a Class C airport. Then back home it was a VOR approach. Point-to-point distance to these two airports and back to home was only 237.7 nm, but for the training value offered, I felt it was appropriate. And that DME arc, missed, and hold certainly added well more than 13 nm to the flight distance, not to mention the vectors for the VOR back home.

And I can't remember if ATC offered us shortcuts to that first airport, but if they did, I would have rejected them. Yes, I want to fly the DME arc even if you can give us vectors, that's the point of the exercise.

Of course, with GPS track logging, and ADS-B, the distance is easily proven. Even flightaware gives a "total distance flown", like this from a recent flight of mine (not an IFR training XC flight):

View attachment 115631

It's a little easier these days when we can pull up a track log to show an examiner if the question comes up. And, if we are within a few miles of the 250 doing direct, chances are it's not going to be an issue. I didn't have the luxury of tracking and we did 256 point to point to point. OTOH, I thought I had something pretty valuable with a real missed off an NDB approach to an island airport.

 

[RussR]

It's a little easier these days when we can pull up a track log to show an examiner if the question comes up. And, if we are within a few miles of the 250 doing direct, chances are it's not going to be an issue.

Not directed at you, but this idea comes up every so often, that "proof" may be needed that you flew more than 250 nm (or met any other training requirement for any other rating). If, on the flight I mention, the DPE had said "these airports are only 237 nm apart. You say that you flew more than 250 nm due to the arc and vectors, but I'm not going to accept it unless you can prove it", that seems inappropriate. There is a student and a CFI attesting in writing (the logbook) that it met the requirements, just like for every other flight in there. What more proof should be needed? Without tracking, there is no "proof" that we actually did any approaches, or even did the flight at all, or even did any other flight in the logbook. Literally 90-something percent of my hours and flights cannot be proven in any way. The "honor system" either works or it doesn't (especially when it involves two people agreeing).

Now, it would be fair for the DPE to ask "These airports are 237 nm apart. How does this meet the requirement?" If the applicant doesn't have an answer, that's a problem, and maybe the flight didn't meet the requirements after all. But if the applicant says "well we flew this DME arc, which as you can see adds 10 nm more than a direct routing, and on this other approach we were vectored to final, which given the location of the FAF required us to fly at least 8 nm past the airport and then back, so it adds up to at least 261 total miles", then that should be good enough.

I can conceivably see a scenario where the airports are only 51 nm apart, but you fly a very circuitous route to get there via some airways that take you well more than 250 nm total. This could actually be a pretty good training scenario, with an intended destination a more "normal" distance away, but then you turn around for "weather" and "divert" to land at the 51 nm airport. I actually kind of like this idea.

 

[RussR]

While I'm ranting, I never did like this clause in 61.65:

(B) An instrument approach at each airport;

I remember some discussions years ago, maybe on the red board, about this. This simple statement can cause problems with flights that are totally (IMO) within the spirit and intent of the regs, though not the exact wording.

For example, you are based at an airport with no instrument approaches. You cannot do this IFR XC country flight starting and ending at your home airport, because even if you flew three approaches at other airports, you didn't fly one at your home airport, therefore you didn't fly "an instrument approach at EACH airport". Personally, if I was a DPE, I'd find this acceptable and clearly following the intent of the regs. But maybe that's why I'll never be a DPE... Yes, you could "reposition" the aircraft to the first airport with an approach, but to me that seems like silly and unnecessary gamesmanship, and taking pedantry to the extreme.

As another example, you buy a plane in a far-off state and take a CFII along to get the IFR XC done on the way back. Great training opportunity, right? You hop all the way across the U.S., flying many, many approaches, both simulated and actual in real weather. But oops, you stopped for fuel at one airport with no approaches because the fuel price was good. Surprise, the flight doesn't count! Maybe you can creatively divide the long flight up into a few shorter "flights" and find some combination that works, but should you have to? I don't think so.

Yes, it was argued before that neither of my scenarios above would count for the IFR XC. I find this ridiculous.