Does this flight count for the Comm 300/250NM long XC?

Ralph Aviles

Ralph Aviles

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Does this flight count for the Commercial 300NM/250NM leg long XC day long XC?

Flight: KDYB->KFLO->KVQQ->KSGJ
- Conditions: IFR, VMC, same day, no overnight, 4.7 hrs total
- Leg #1: 73 NM: KDYB->KFLO (Full stop, re-fuel)
- Leg #2: 261 NM: KFLO->KVQQ (Touch and Go)
- Leg #3: 32 NM: KVQQ->KSGJ (Full Stop, end of flight)
Total: 366 NM

Notes:
1) Under 61.129(a)(4)(i), I am interpreting Leg #2 (KFLO->KVQQ) to be the leg with 'at least 250 nautical miles from the original departure point' with a straight distance of 261 NM and KFLO as the 'original departure point'.

2) If the interpretation for 'original departure point' is for KDYB, the straight distance between KDYB-> is 188 NM.

Thanks for your opinion/expertise.
 
For the flight as described, KDYB is the original point of departure. So the flight as described does not meet the requirements, since no landing point is more than 250 NM away from DYB.

If you want to "reposition" to KFLO and then start a new flight from that point, fine, but then you'd need a third point anyway. Which could be a quick bounce at HEG or something like that if you wanted.

I suggest you pick different airports. Given that you specified a one-way flight, I assume you have a reason to fly from DYB to SGJ, and are trying to make it work for "credit". If that's true, then I'd suggest something like DYB VQQ OCF SGJ, that would meet the requirement.
 
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I’m confused about why you would consider the second airport in your flight as the “original departure point.” There are some places in the FARs that might be subject to interpretation, but I think this one is going to be hard to talk a DPE into accepting.

The rest of the trip looks fine. Maybe stop at 4J1 and log the KDYB-KFLO leg as a separate flight, so the one you use to qualify for the aeronautical experience requirement is KFLO-4J1-KVQQ-KSGJ.

Is there a reason you’re doing this IFR?
 
RussR said:
[...] KDYB is the original point of departure. So the flight as described does not meet the requirements, since no landing point is more than 250 NM away from DYB.

[...] I assume you have a reason to fly from DYB to SGJ, and are trying to make it work for "credit". If that's true, then I'd suggest something like DYB VQQ OCF SGJ [...]
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iamtheari said:
I’m confused about why you would consider the second airport in your flight as the “original departure point.” There are some places in the FARs that might be subject to interpretation, but I think this one is going to be hard to talk a DPE into accepting.

[...] Maybe stop at 4J1 and log the KDYB-KFLO leg as a separate flight, so the one you use to qualify for the aeronautical experience requirement is KFLO-4J1-KVQQ-KSGJ.

Is there a reason you’re doing this IFR?
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Thanks everyone. I will fly a different plan with the suggestions mentioned here.

Yes, my son lives in Summerville. I visit him once in a while.

No specific reason for filling IFR. But since I just got my IFR last September and since I will be requesting FF, I am thinking why not file IFR and exercise my IFR privileges. :)

Related question: I've heard and read two different views on whether you can bring a non-pilot passenger with you (aka wife). I've heard the argument that it has to be solo but have also heard that applies to non-licensed student pilots which cannot carry passengers. If that is the case, if you are a licensed pilot acting as PIC and fly with a passenger that it is not a CFI or pilot that could assist you will that be accepted?
 
Ralph Aviles said:
…Related question: I've heard and read two different views on whether you can bring a non-pilot passenger with you (aka wife)...
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You are working towards the Commercial knowledge and experience requirements. You should be focusing on where you can find the relevant regulatory guidance.

For both of your questions, it’s pretty straight forward in the FARs.
 
Ralph Aviles said:
Thanks everyone. I will fly a different plan with the suggestions mentioned here.

Yes, my son lives in Summerville. I visit him once in a while.

No specific reason for filling IFR. But since I just got my IFR last September and since I will be requesting FF, I am thinking why not file IFR and exercise my IFR privileges. :)

Related question: I've heard and read two different views on whether you can bring a non-pilot passenger with you (aka wife). I've heard the argument that it has to be solo but have also heard that applies to non-licensed student pilots which cannot carry passengers. If that is the case, if you are a licensed pilot acting as PIC and fly with a passenger that it is not a CFI or pilot that could assist you will that be accepted?
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61.51(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.
 
Ralph Aviles said:
I've heard the argument that it has to be solo
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That argument is a very common one. It is most clearly articulated in the actual regulation.

Ralph Aviles said:
but have also heard that applies to non-licensed student pilots which cannot carry passengers.
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This argument, on the other hand, requires that we first ignore the regulation. The FAA is very specific every time they write a regulation that is specific to student pilots.
 
Do a different flight and do it alone… nobody else in the plane. As a CFI, I would not sign off on that flight or a flight with any passengers as it does not meet the criteria in 61.129.
 
Ralph Aviles said:
Related question: I've heard and read two different views on whether you can bring a non-pilot passenger with you (aka wife). I've heard the argument that it has to be solo but have also heard that applies to non-licensed student pilots which cannot carry passengers. If that is the case, if you are a licensed pilot acting as PIC and fly with a passenger that it is not a CFI or pilot that could assist you will that be accepted?
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Where could you possibly be hearing (or reading) two different views on this? This regulation is possibly the clearest one in the book. Solo means solo. Any other definition is someone trying to purposely misconstrue the regulations to meet their own needs. If you've actually read somewhere that a non-pilot passenger is okay, I'd really like to see a link to that article or discussion.
 
iamtheari said:
I’m confused about why you would consider the second airport in your flight as the “original departure point.” There are some places in the FARs that might be subject to interpretation, but I think this one is going to be hard to talk a DPE into accepting.
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I have not assessed the plan, so this is general, not specific to the route.

One can reposition an airplane and begin a cross country there. One option here is to treat the DYB-FLO flight as separate from the cross country and begin the cross country at FLO. but then, it looks like he'd need another stop further away (or on the way back if it's a round robin) since the total would not exceed 300 NM.

Ralph Aviles said:
the leg with 'at least 250 nautical miles from the original departure point
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BTW, there is no requirement for a 250 NM "leg." Here's the words of the regulation (with emphasis):

not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point.
​
 
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RussR said:
Where could you possibly be hearing (or reading) two different views on this? This regulation is possibly the clearest one in the book. Solo means solo. Any other definition is someone trying to purposely misconstrue the regulations to meet their own needs. If you've actually read somewhere that a non-pilot passenger is okay, I'd really like to see a link to that article or discussion.
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One can always find two different views, even if it comes down to those who know vs those who are clueless.
 
DesertNomad said:
Do a different flight and do it alone… nobody else in the plane. As a CFI, I would not sign off on that flight
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I think you mean you would not sign off the 8710 in IACRA. There's no CFI signature required for a solo cross country flight by a private pilot.
 
DGlaeser said:
I don't see a problem...
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LOL! Other than not meeting the requirements?

I finally had a chance to look at the flight. Didn't need to get further than DYB → SJG only being 193.5 NM straight line, not the required 250.

There are simple options to fix that. One is to treat DYB-FLO as a repositioning flight and begin the cross country at FLO. FLO → SGJ is 266 NM. That covers the 250 NM requirement. Add two stops along the way.

But the use of the phrase "250 Nm Leg" in the question leads me to think there's a more basic misunderstanding of the requirements.
 
This is the regulations: 14 CFR 61.129(a)(4)(i)

One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and

If one were to stop reading at the end of the first sentence then @midlifeflyer is unquestionably correct. However, if one were to read the entire paragraph. the addition of the phrase "longest segment" would seem to imply that the word segment might apply to the prior sentence because otherwise it is superfluous.

Common rules of statutory construction would interpret the paragraph as whole and would lead to the conclusion that the word segment in the requirements for Hawaii is superfluous unless it also applies to the first sentence.

So, is Mark (@midlifeflyer) correct? I dunno.

A trip through the history of the regulation is needed to see if there is statutory history that might shed some light on this.

Edit: add quotes, add last sentence.
 
The "leg" comes from the former requirements.

In the past, the Commercial required a XC with 3 legs, one of which was a certain minimum distance and the total to be over some requirement. There was no requirement that any landing be YY distance from the origin. So you could have flown 75 NM one direction, 150 NM back over the original destination and continuing, then back to the origin.

IIRC, it was 300 total, one leg at least 150 NM.

With the current reg, you could fly a BUNCH of 25 NM legs, as long as you landed at least 250 NM away, and did a total of 300.
 
Pinecone said:
The "leg" comes from the former requirements.

In the past, the Commercial required a XC with 3 legs, one of which was a certain minimum distance and the total to be over some requirement. There was no requirement that any landing be YY distance from the origin. So you could have flown 75 NM one direction, 150 NM back over the original destination and continuing, then back to the origin.
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I think you are correct. The pre-1997 regulation called for

a minimum of three points, one of which is at least 150 nautical miles from the original departure point if the flight is conducted in Hawaii, or at least 250 nautical miles from the original departure point if it is conducted elsewhere​

The goal of the 1997 revision was primarily to meet ICAO requirements by increasing the total distance requirement. I've always suspected the use of "segment" in the Hawaii-specific part was a simple error. We don't see much in the way of required leg lengths. One is in the long student solo cross country requirements and it is extremely specific: "one segment of the flight consisting of a straight-line distance of at least 50 nautical miles between the takeoff and landing locations." (that very specific language is repeated in a number of regulations). I don't worry about it since I'm not doing it in Hawaii and the language without Hawaii is consistently used in other regulations (including the group of definitions of cross country in 61.1.

My opinion only, but I would be very surprised at a 250 NM leg requirement. That might preclude some airplanes, since it would not allow a fuel stop. But more importantly, it presents a potential danger. You are on your long solo cross country and encounter weather you feel uncomfortable with or maybe suspect a problem. Sorry, no diversion allowed to wait out the passing storm or have the airplane checked by a mechanic before continuing. Don't use your judgment. You must complete the mission to do it all in one leg, or you'll have to start all over. That kind get-thereitis built into the regulation would be sooooooo very contrary to the whole idea of a commercial certificate.
 
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midlifeflyer said:
I've always suspected the use of "segment" in the Hawaii-specific part was a simple error.
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Is there an FAA definition of "segment" somewhere? I can't find one in a quick search. But the IATA definition of "segment" allows for stops. Applying that definition, the usage makes sense as referring to the longest distance between any two airports on the route. This is also consistent with the ordinary definition of segment.
 
Lindberg said:
Is there an FAA definition of "segment" somewhere? I can't find one in a quick search. But the IATA definition of "segment" allows for stops. Applying that definition, the usage makes sense as referring to the longest distance between any two airports on the route. This is also consistent with the ordinary definition of segment.
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Not that I know of. Personally, I think "segment" is vague enough to accommodate either nothing between or something between (what is between the IF and the FAF in the intermediate segment of an approach?). I just look at how very specific the FAA is when it means a certain distance between takeoff and landing points and its absence in this regulation.
 
Again, thanks. Like I mentioned I just finish my IFR and now I am deciding whether to go for the CPL this year. I have not flown with any CFI yet. My research has been the innerweb, reading 14 CFR 61, talking to pilot friends and now POA. I can't recall where I read all. Perhaps I read segments of old regulations and personal opinions.

I am in the process of organizing my logbook to get a summary of where I am in terms of hours and requirements before I meet with a CFI. I recently transferred all data to MyFlightbook to calculate my Rating Progress. That is where I noticed something was off with this flight. It is obvious that my interpretation of 'original' and 'solo' is questionable. Thus, I want to avoid making mistakes that could delay or question my progress when I am ready to start.

I thought of all my flight 'legs' to have an 'origin' and a 'destination'. When I read 'from the original departure point' I was thinking about my flight 'leg #2' with FLO as my origin and VQQ as my destination. It did not occurred to me that the definition appears to be more basic and straightforward to mean from the 'FIRST' departure airport, DYB.

I am no expert in aviation rule so since the majority of people and/or CFI's appear to understand it is the 'FIRST' departure airport and that SOLO means one soul and one spirit with me and GOD as my passenger, I will follow that lead.
 
midlifeflyer said:
I've always suspected the use of "segment" in the Hawaii-specific part was a simple error.
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I'm not sure I agree that it was an error.

If it's an error and the intent is for the flight to go somewhere 150 nm away, then depending on where you are flying out of there are very limited options. Heck, if you're based out of Molokai PHMK, there are NO airports more than 150 nm away. And from some of the airports, getting to another airport 150 nm away would mean going to Kauai, which means crossing 64 nm of ocean in a single-engine airplane. Not great.

But if it's intentional and NOT an error, then it would likely just be a nod to practicality, allowing a flight to count as long as there is a 150-nm long segment somewhere in the flight. Which, given the limitations of the islands, seems a reasonable compromise. That means from Molokai/Lanai/Maui to Honolulu to Hilo and back would count (along with multiple other similar options), and be reasonably safe with an ocean crossing of "only" 26 nm.
 
RussR said:
I'm not sure I agree that it was an error.

If it's an error and the intent is for the flight to go somewhere 150 nm away, then depending on where you are flying out of there are very limited options. Heck, if you're based out of Molokai PHMK, there are NO airports more than 150 nm away. And from some of the airports, getting to another airport 150 nm away would mean going to Kauai, which means crossing 64 nm of ocean in a single-engine airplane. Not great.

But if it's intentional and NOT an error, then it would likely just be a nod to practicality, allowing a flight to count as long as there is a 150-nm long segment somewhere in the flight. Which, given the limitations of the islands, seems a reasonable compromise. That means from Molokai/Lanai/Maui to Honolulu to Hilo and back would count (along with multiple other similar options), and be reasonably safe with an ocean crossing of "only" 26 nm.
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I agree the 150 for Hawaii is intentional - as the realistic equivalent of the 250. The "error" I see if one interprets the 150 as the required distance between takeoff and landing points for a single leg.
 
Ralph Aviles said:
I thought of all my flight 'legs' to have an 'origin' and a 'destination'. When I read 'from the original departure point' I was thinking about my flight 'leg #2' with FLO as my origin and VQQ as my destination. It did not occurred to me that the definition appears to be more basic and straightforward to mean from the 'FIRST' departure airport, DYB.
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There's the error. With a pretty long history, the FAA considers a cross country "flight" to be mostly in the eye of the pilot. The most recent is this from 2009:

There is nothing in § 61.1(b)(3)(ii) or previous FAA interpretations dictating how separate flights must be logged. Accordingly, the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted. Section 61.1(b)(3)(ii) requires that the flight include a landing at a point other than the point of departure.​

My qualifying long commercial solo cross country was over the course of three days.

Go back to the regulation.

"One cross-country flight" - one flight not 6.
The "flight" must be "not less than 300 nautical miles total distance"
The "flight" must have "landings at a minimum of three points." Kind of precludes each landing point being a separate "flight," doesn't it?
Only "one of" the points of landing must be "a straight-line distance of at least 250 nautical miles from..."
"the original departure point." - where you decided the "flight" started.


Solo is even easier because it's in the Universal Rule of Logging Flight Time:

61.51(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.​

Be careful. You are working on your commercial certificate. The rules about what you can and cannot do with it are much more intricate.
 
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Repositioning the aircraft is fine. I did that because it worked out better for the airports involved. Full stop taxi back engine running at the airport of repositioning. Logged the reposition as its own entry in the logbook and specifically added in the comments "repositioning for next flight". My entire (solo) flight was going to be quite a bit longer than required. In case of anything unexpected, I wanted to get the requirements knocked out sooner during the flight. I made two landings at an airport close to the start of my flight. The third landing was at an airport far enough such that all requirements would be met at that point. Then I continued on to where ever it was that I was going. I logged the entire flight (not to include the initial reposition flight) for the commercial requirement.
 
midlifeflyer said:
I agree the 150 for Hawaii is intentional - as the realistic equivalent of the 250. The "error" I see if one interprets the 150 as the required distance between takeoff and landing points for a single leg.
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See, I don't think the 150 nm leg between takeoff and landing is necessarily an error. Now, I have no greater insight into this than anyone else, but to me it seems a reasonable compromise, intended or not:

"Okay, so we recognize they can't fly 250 nm away in Hawaii. But instead of making them all come to the mainland for training, how about as a compromise, we make it so they just have to have a 150-nm long leg between one of their takeoffs and landings? That gives them flexibility given the geography, but also requires a flight of some decent length. CONUS-based pilots get the benefit of the longer total distance, but CONUS pilots can stop every 10 nm if they want to while doing it. Hawaiian pilots can't go that far, so we'll make sure they have to have a long single leg in there to try to make up for it."
 
RussR said:
See, I don't think the 150 nm leg between takeoff and landing is necessarily an error. Now, I have no greater insight into this than anyone else, but to me it seems a reasonable compromise, intended or not:

"Okay, so we recognize they can't fly 250 nm away in Hawaii. But instead of making them all come to the mainland for training, how about as a compromise, we make it so they just have to have a 150-nm long leg between one of their takeoffs and landings? That gives them flexibility given the geography, but also requires a flight of some decent length. CONUS-based pilots get the benefit of the longer total distance, but CONUS pilots can stop every 10 nm if they want to while doing it. Hawaiian pilots can't go that far, so we'll make sure they have to have a long single leg in there to try to make up for it."
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So one 150 NM leg replaces 250 NM done in multiple legs? Hmmm. Maybe. Makes some sense. But I would still expect to see language similar to the "one segment of the flight consisting of a straight-line distance of at least [X] nautical miles between the takeoff and landing locations" used about 30 times elsewhere in Part 61.
 
Why do so many put so much effort into flying the bare minimum? Why rationalize and look for loopholes? Make your commercial x-c one where Leg 1 takes you 300+ miles. Push your limits - nothing great ever took place inside the comfort zone.
 
ateamer said:
Why do so many put so much effort into flying the bare minimum? Why rationalize and look for loopholes? Make your commercial x-c one where Leg 1 takes you 300+ miles. Push your limits - nothing great ever took place inside the comfort zone.
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Maybe he doesn’t want to spend the extra $100 doing a 600 nm XC vs a 500 nm XC.
 
midlifeflyer said:
I think you mean you would not sign off the 8710 in IACRA. There's no CFI signature required for a solo cross country flight by a private pilot.
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Yes, I would not sign the 8710 or make any logbook endorsements indicating he was prepared for the checkride.
 
ateamer said:
I guess for some people flying is just a chore instead of a passion.
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Not everyone is into the $200 hamburger. When you realize that people wanting a path to fly professionally are going to drop >$35,000 to get to CFI, wasted flight time is a luxury many cannot afford or don’t want to spend.
 
midlifeflyer said:
I think you are correct. The pre-1997 regulation called for

a minimum of three points, one of which is at least 150 nautical miles from the original departure point if the flight is conducted in Hawaii, or at least 250 nautical miles from the original departure point if it is conducted elsewhere​

The goal of the 1997 revision was primarily to meet ICAO requirements by increasing the total distance requirement. I've always suspected the use of "segment" in the Hawaii-specific part was a simple error. We don't see much in the way of required leg lengths. One is in the long student solo cross country requirements and it is extremely specific: "one segment of the flight consisting of a straight-line distance of at least 50 nautical miles between the takeoff and landing locations." (that very specific language is repeated in a number of regulations). I don't worry about it since I'm not doing it in Hawaii and the language without Hawaii is consistently used in other regulations (including the group of definitions of cross country in 61.1.
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Before that was a 3 leg with minimum leg length for each.

For Private, one was 50 NM legs. So a total of 150 NM.

OK, I found a 1991 FAR/AIM in my library:

Private required 10 hour XC, with a landing point 50 NM from point of origin. Plus one flight at least 300 NM with a landing point at least 100 NM away.

The Commercial was as you stated.

Apparently there was changes in 1987 for Part 61, as the 1991 version has some sections that are noted
"Until May 1, 1987."
 
ateamer said:
I guess for some people flying is just a chore instead of a passion.
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Make sense. Plan on a career doing something you don't like doing.

That is a recipe for success.
 
Clip4 said:
Not everyone is into the $200 hamburger. When you realize that people wanting a path to fly professionally are going to drop >$35,000 to get to CFI, wasted flight time is a luxury many cannot afford or don’t want to spend.
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100% Agreed. Everybody has their own unique financial and life situation.
 
Pinecone said:
Before that was a 3 leg with minimum leg length for each.

For Private, one was 50 NM legs. So a total of 150 NM.

OK, I found a 1991 FAR/AIM in my library:

Private required 10 hour XC, with a landing point 50 NM from point of origin. Plus one flight at least 300 NM with a landing point at least 100 NM away.

The Commercial was as you stated.

Apparently there was changes in 1987 for Part 61, as the 1991 version has some sections that are noted
"Until May 1, 1987."
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My long solo xc was 1990 - the long one. Then there was a major Part 61 and 141 revision in 1997.
 
DesertNomad said:
Yes, I would not sign the 8710 or make any logbook endorsements indicating he was prepared for the checkride.
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I wouldn't sign off on a checkride if a student didn't meet the requirements either. I wouldn't expect any CFI to knowingly do that.
 
midlifeflyer said:
There's the error. With a pretty long history, the FAA considers a cross country "flight" to be mostly in the eye of the pilot. The most recent is this from 2009:

There is nothing in § 61.1(b)(3)(ii) or previous FAA interpretations dictating how separate flights must be logged. Accordingly, the pilot may choose what is considered a discreet flight and what is merely a segment of a flight, and then log that time appropriately when the flight is conducted. Section 61.1(b)(3)(ii) requires that the flight include a landing at a point other than the point of departure.​

My qualifying long commercial solo cross country was over the course of three days.

Go back to the regulation.

"One cross-country flight" - one flight not 6.
The "flight" must be "not less than 300 nautical miles total distance"
The "flight" must have "landings at a minimum of three points." Kind of precludes each landing point being a separate "flight," doesn't it?
Only "one of" the points of landing must be "a straight-line distance of at least 250 nautical miles from..."
"the original departure point." - where you decided the "flight" started.


Solo is even easier because it's in the Universal Rule of Logging Flight Time:

61.51(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.​

Be careful. You are working on your commercial certificate. The rules about what you can and cannot do with it are much more intricate.
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@midlifeflyer - I love this, thank-you. You have beautifully articulated this and - I'm relieved to say - validated precisely how I implement this in MyFlightbook.
  • The way that you tell MyFlightbook it is "a flight" is by encapsulating it in a single entry. Multi day is fine (just use the date of the first flight). If you don't put them all into a single entry, it can still qualify, but MyFlightbook won't pick it up - you just need to explain it to your CFI and your DPE
  • 250nm from the FIRST airport, etc. What's fascinating about this is that you can have a flight that is A-B-C-D-E where B to E is 260nm, but all of B/C/D/E are less than 250nm from A (e.g., B is 30 miles due north of A and E is 230nm due south, and C/D are along the route from B to E). So ironically, this flight would not qualify and yet the *exact* same flight minus the "A-B" part (i.e., B-C-D-E) could in fact qualify. So be careful how you decide what your flight is!!!
  • I'm looking for one entry that has 3 landings, 300+nm
  • And yes, you have to be solo - only occupant of the aircraft. Obviously, I can't tell if you really were solo, but if you log solo and weren't then you were violating 61.51. (An interesting question: can you take your dog? I.e., does the occupant need to be human? Also, does "occupant" have to be a butt in seat? I'm guessing so - and that a pregnant pilot is not prevented from logging solo time. But AFAICT, "occupant" is not defined)
 
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