Combine 250nm IR XC with Commerical 2 hour XCs?

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triple111

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triple111
Was having a discussion today with an instructor whether this is possible to combine one of the flights from 61.129 with the 250nm IR XC.

61.65(d)(2)(ii)

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

(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;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.

61.129(a)(3)(iii) and (iv)

(3) 20 hours of training on the areas of operation listed in § 61.127(b)(1) of this part that includes at least -

(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;

(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and

Both are training flights, I don't see why it would be an issue? Is there an interpretation letter available?
 
While not explicitly stated when I asked my instructor the same question I was told no, that the 2 hour commercial cross country needed to be VFR.
 
Grum.Man said:
While not explicitly stated when I asked my instructor the same question I was told no, that the 2 hour commercial cross country needed to be VFR.
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That same instructor probably believes the 3 hours of PPL instrument training dont count towards IR either :D I could see a point being made that you couldn't do the 300nm and 250 combined (solo/bored instructor vs training) but I've heard of people combining the ones I mentioned.
 
Grum.Man said:
While not explicitly stated when I asked my instructor the same question I was told no, that the 2 hour commercial cross country needed to be VFR.
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Might have been back when that was the rule. The commercial duals used to have to be VFR. If not, your instructor may have been living in the past ;)
 
Good luck with that. Which 61.127(b)(1) items are you going to try to log that you were doing while on the required IFR XC?
 
Seeing as how the commercial ACS specifically states in the area of cross country planning that it’s a VFR flight plan I would say doing it under the hood would not qualify.
 
Grum.Man said:
Seeing as how the commercial ACS specifically states in the area of cross country planning that it’s a VFR flight plan I would say doing it under the hood would not qualify.
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The ACS defines what the examiner is to look for on a checkride. It does not redefine the regulatory training requirement which was changed in 2009, specifically to allow it to be done IFR and qualify for both. This is from the Federal Register Final Rule discussing the reason for the change:

Previously, § 61.129 required one cross country flight in day VFR conditions and one cross country flight in night VFR conditions. Since establishing these cross country training requirements at the commercial pilot certification level, the FAA has received requests from several pilot training schools that we allow flights to be performed under IFR conditions. According to the schools, most applicants for commercial pilot certification-airplane rating and some applicants for the helicopter rating are enrolled in an instrument rating course at the same time they are undergoing their commercial pilot certification training.​
 
midlifeflyer said:
The ACS defines what the examiner is to look for on a checkride. It does not redefine the regulatory training requirement which was changed in 2009, specifically to allow it to be done IFR and qualify for both. This is from the Federal Register Final Rule discussing the reason for the change:

Previously, § 61.129 required one cross country flight in day VFR conditions and one cross country flight in night VFR conditions. Since establishing these cross country training requirements at the commercial pilot certification level, the FAA has received requests from several pilot training schools that we allow flights to be performed under IFR conditions. According to the schools, most applicants for commercial pilot certification-airplane rating and some applicants for the helicopter rating are enrolled in an instrument rating course at the same time they are undergoing their commercial pilot certification training.​
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Well there you have it, end of discussion.
 
Walboy said:
I would have said the training would have to be under VFR too. How do you keep up with these changes? Thanks for pointing out the reference.
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For instructors, who really need to know this, keeping up (a) is part of their job description and (b) tends to be covered in CFI courses. If one subscribes to one of the FAR/AIM republications, major changes are usually discussed. And, of course, they are discussed in aviation magazine articles and online forums like this one. I'm pretty sure this change was discussed when it wasdone more than 10 years ago and I know the removal of the VFR requirement has been discussed a number fo times since .

Walboy said:
To me, daytime and nighttime conditions as written in 91.129 IMPLY VFR but clearly that's not the case.
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That's an interesting comment. Now you have me curious. What do you see in the words of the day and night dual cross countries which suggests a VFR limitation? Are you talking the extra step that "day" and "night" have no relevance to an IFR flight?

Be careful of adding words to requirements. This one is similar to the folks who think every leg of a cross country must be >50 NM in order to count.
 
My commercial qualifying cross country flight was a combination of day and night IFR. It never occurred to me or anyone else in my training chain that it should be done only in VFR conditions.

I started out late at night and flew until morning the next day. One leg was almost five hours. :confused:
 
Walboy said:
Yes, that's my thinking. If IFR is acceptable, why then the references to day and night? I suppose I'm biased because my commercial cross country training was done prior to 2009.
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I'm not sure I'd say biased. Maybe just inferring something based on prior experience (when the rule was different) BTW, I got mine before 209 too - I didn't have any dual cross country requirement.

FIFY:
Walboy said:
I guess I could envision this conversation:

DPE: Mr. CFI, why did you let your student complete the dual cross countries under IFR conditions?
CFI: Gee, Mr. DPE, it's because 91.129 didn't say you can't.
DPE: Well Mr. CFI, why do you think the words daytime conditions and nighttime conditions were included?
CFI: Gee, I dunno Mr. DPE. It's something I saw on the internet. Maybe because one has to be done during the day and one has to be done at night, just like it says?
DPE: Mr. CFI, you should know the FAA doesn't use words unnecessarily, use some common sense. Now go retrain your student and then reschedule.
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The DPE is the one who would need the retraining.
 
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