# Commercial Long XC Question (# of Airports)

Discussion in 'Pilot Training' started by Skid, Mar 18, 2019.

1. ### SkidPre-takeoff checklist

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"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."

For the above in bold, just curious if a flight starting at point A can be:

A --> B --> C --> A

Does that count as 3 points? or does it need to be:

A --> B --> C --> D --> A

My plan right now is to make this into somewhat of a fun overnight trip as follows:

Starting at point A, flying 200 miles to point B, flying an additional 70 miles to point C, stay the night, and fly all the way home 270 miles to point A.

Any issues with the above?

2. ### WalboyCleared for Takeoff

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No issues. Your plan is fine.

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3. ### LindbergEn-Route

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As long as C is more than 250 NM from A, that plan works.

4. ### KaiGywerPre-takeoff checklist

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Or B

5. ### LindbergEn-Route

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Or B what?

6. ### WannFlyEn-Route

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B is greater than 250 nm

7. ### LindbergEn-Route

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In the scenario he gave, B is no more than 200 NM from A and no more than 70 NM from C.

8. ### WannFlyEn-Route

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Never mind then. His first plan is still good. It’s still good if he doesn’t even return to A

9. ### ja_userPattern Altitude

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You gonna be solo?

10. ### KaiGywerPre-takeoff checklist

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Apparently my reading comprehension sucks today. Lol

11. ### PeterNSteinmetzLine Up and Wait

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Needs to be either solo or accompanied by a flight instructor who does nothing but observe (strange concession to part 141 schools with insurance requirements, apparently).

12. ### ja_userPattern Altitude

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well aware. Just always ask because a lot of people somehow think this means that they can take a passenger.
I don't know how 141 factors into this, but a person doing this in a non-solo rental can factor into it as well. Used to be Multi only, now apparently singles...

13. ### SkidPre-takeoff checklist

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Yep I'll be alone. Looking forward to the trip, going TPF -> SSI (lunch) -> HXD (beach, dinner, overnight) -> TPF. Haven't been to either of those airports and figured I'd live the life of luxury one last time in Hilton Head before I live the poverty life as a pilot.

14. ### EdFredTouchdown! Greaser!PoA Supporter

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I'm always hesitant to combine two days as a single trip since the dates of the flights are different.
61.51 says the date of the flight, not the dates of the flight.

I'd say that's since it's two separate dates, it's two separate flights.

15. ### WheelsPre-takeoff checklistPoA Supporter

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Doesn’t necessarily have to return to A but if he just goes A-B-C that doesn’t meet the total distance required. He has to go somewhere after C to get the total to 300nm.

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16. ### EdFredTouchdown! Greaser!PoA Supporter

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Because 141 schools bitched and moaned to the FAA that their students didn't meet insurance requirements for solo XC flights.

17. ### Juliet HotelCleared for TakeoffPoA Supporter

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I was thinking the same thing. If I do a multi-day trip and I get lazy with the logbook, I'll log the whole trip on one line (if I log it at all). But I'm no longer logging flights in pursuit of a certificate. I did my solo long XC for the commercial by going from NJ to FL. I stayed with my sister for a few days and flew back. The flight down was only going to require 1 fuel stop which would have meant landings at two airports. So instead of fueling up at the home airport in the morning, I flew 50 miles north, topped up there then flew to Florida. Logged the flight down on one line with landings are 3 points and all the mileage requirements met. The trip back was just one fuel stop and then home and logged on its own line. Left no room for argument that way.

18. ### EdFredTouchdown! Greaser!PoA Supporter

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I did a trip out west which spanned 12 days a bunch of stops and 4000nm+. As far as I was concerned each day was a separate flight. I think the DPE may have been like, "Wait, you had a commercial XC that had 21 stops and 12 days of flying? Yeah, I don't think that's a single flight." As it was my Commercial XC required us going to a map because he didn't recongnize the identifiers of FMN - BGD - 1K4 - OUN.

19. ### dmspilotEn-Route

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So if you takeoff before midnight and land after it's two flights?

20. ### EdFredTouchdown! Greaser!PoA Supporter

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Yeah, that's exactly what I said.

21. ### LindbergEn-Route

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So what's the difference between a flight and a leg?

22. ### EdFredTouchdown! Greaser!PoA Supporter

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To me a flight is when you are done flying for the day, or need a new line in the logbook. If I fly from A to B in N12345 and then get in N23456 and fly from B to wherever, that's 2 separate flights. I have days in my logbook where I've flown 3 or 4 different aircraft. All of those are different flights. Not legs.

If I fly from A to B, and sleep overnight, the next day is a different flight.

23. ### SkidPre-takeoff checklist

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This came up on another forum as well concerning the overnight thing, and if I recall it was mentioned in one of the FAA legal interpretations, but can't find it off hand. If I'm remembering right the number of days didn't (and shouldn't) factor into the equation when determining if a flight was considered cross country. In the above scenario if I flew to KHXD and the weather prevented me from returning until the next day or even a week after, I wouldn't expect that nullifies the entire flight from counting.

And as dmspilot said, if I departed TPF at 11:30pm, landed at SSI at 1am, then what? Would the next flight have to be logged using the next day's date, and the entire XC plan redone?

Since 61.129 doesn't specify same day I would think it would be good to log it as 2 entries in my logbook, and just bracket it with a note saying "Long XC" or something to that effect so its obvious.

You seem well versed in the regs though so I'm open to your interpretation if you have something that states otherwise, or how it should be logged appropriately.

Last edited: Mar 19, 2019
24. ### EdFredTouchdown! Greaser!PoA Supporter

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To me the staying overnight (or even 3 nights, or 3 years) sort of falls in line with the whole log time as soon as the wheels move. At idle, I have over 24 hours of fuel in my plane. If I taxi to the runway, idle for 24 hours and then fly 51nm away to an airport, according to the people that say, "as soon as you move you log the time" I should be able to log 24+ hours of cross country time, because "hey you moved for the purpose of flight." They counter that it's ridiculous, but why is 24 hours not OK, but 2 hours for a ground stop acceptable? For *ME* (and my students, or anyone I'm going to sign off) moving for the purpose of flight is the takeoff roll. Taxiing to the pumps is just that taxiing to the pumps. Taxiing to the run up area is for the purpose of taxiing to the runup area. Same for the going to the runway. So for me, flight time is wheels off the runway until I land, and clear the runway. Though I usually look at the time when shut down, and then round DOWN to the nearest 0.1 hour.

So for overnights or what not, If you have to get up, do flight planning, check the weather, etc... I call that a separate flight. Because hey, if 1 overnight is acceptable, why not 12, or staying somewhere for a year, then if you always fly the same plane for 3 years straight, why not just log all of those 3 years as one single flight, and have a 194 leg cross country that spans 30,000 miles?

I just look at it as trying to 'cheat' your way to hours or ratings.

25. ### dmspilotEn-Route

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You know what's obtuse? Making up your own interpretation of regulations, which differ from the interpretation everyone else uses, and then telling everyone else they're wrong.

Logically speaking, if the FAA wanted the definition of flight time to start at takeoff, then the definition would read "time that commences when an aircraft begins takeoff" instead of "time that commences when an aircraft moves under its own power for the purpose of flight".

Several chief counsel letters support taxi time as flight time, even when not followed immediately by takeoff:

Chief Counsel to James W. Johnson, June 2, 2000:
In our opinion, the logic and principles of the enforcement cases and our prior interpretation support the conclusion that FAA-required de-icing procedures are "preparatory to flight," and when the aircraft taxies under its own power from the gate to the de-icing pad, it is "for the purpose of flight." Thus, we further conclude that flight time starts at the moment when the aircraft taxies under its own power from the gate to the de-icing pad, and flight time continues until the moment the aircraft comes to rest at the next point of landing."

Chief Counsel to Randall C. Kania, April 29, 2004:
In this situation, flight time starts when the aircraft first taxies under its own power from the gate, continues through the period of delay when the aircraft returns to the gate and in which the pilot must remain on board, and ends at the moment the aircraft comes to rest at the point of landing at the destination airport.

Chief Counsel to Barry C. Lloyd, April 27, 2007:
As with fixed-wing aircraft, flight time in a helicopter commences the moment that it moves under its own power away from its parking place for the purpose of flight—whether departure is commenced by lifting off or taxiing.

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26. ### EdFredTouchdown! Greaser!PoA Supporter

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Oh, you want to trot out CC letters.

Fine...
*cough* McPherson *cough*

Great. I'll start logging 24 hours cross country flights that only go 51 miles. I'm absolutely justified in doing so, right?

Where did I say they were wrong? I have said if you accept 2 hours of sit and wait time, you HAVE to accept 24 hours of sit and wait time. But every time I mention that scenario, everyone screams no that's not acceptable. SO why is 2 hours OK, and 24 hours of idle time not OK?

I get it. You want to half ass things. Be my guest. I hold myself and my students to a higher standard.

Last edited: Mar 19, 2019
27. ### dmspilotEn-Route

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Making an effort to be objectively correct in the way that I do things is the opposite of half-assing. Meanwhile you can't even full-ass a debate without resorting to personal insults and attacks on my character.

28. ### EdFredTouchdown! Greaser!PoA Supporter

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And yet, you completely failed to address why idling for 24 hours is NOT OK, but idling for 2 hours is.

And how can you be objectively correct while using a CC letter that is a subjective interpretation as your stance?

29. ### LindbergEn-Route

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Oh, reductio ad absurdum. My fave.

But this isn't a logic problem or an answer you can reason your way to. @dmspilot is correct as to what the regs say. So if you taxi for the purpose of flight, and then wait for 24 hours, you can log it. If it comes up with the FAA, the question is not going to be an interpretation of the reg, but a factual question as to whether you were actually moving for the purpose of flight. The FAA requires a certain amount of flight time, and the FAA also defines flight time. No one's half assing anything, but you might be over achieving. The FAA could require 44 hours for a private or exclude taxi time if that's what it intended.

30. ### EdFredTouchdown! Greaser!PoA Supporter

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My question where's the acceptable cutoff? 2 hours? 4 hours? 8 hours? If no one is willing to put up a number, then ALL numbers have to be acceptable. If all numbers are NOT acceptable, then NO numbers can be acceptable, OR the FAA has to limit it. They have made hard number restrictions on everything else. 5 hours of XC here. 10 hours of solo there. Until the FAA puts a hard number on it, I will continue to take the stance that you are in fact 'cheating' when you sit on your ass on the ground and log time.

Back the OP:
I would not log the situation as proposed for the commercial XC. I would also not sign off a student for a check ride who did either. They can go find someone else who would. I'm sure you could you even pad it with with 2 extra hours of "flight time" at each stop and it's cool with everyone else here.

Last edited: Mar 19, 2019
31. ### kathLine Up and Wait

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"For the purpose of flight", just like "the definition of one flight across multiple days", is partly in the mind. Any attempt to write a regulation that encapsulates a human's "intent" or "mindset" in this way with numbers is going to be a pointless exercise. We might as well waste brain power trying to define the meaning of "flight instruction", or any number of other words in English that we all kind of agree have meaning to a reasonable person.

If I taxi to the gas pump, because I'm going to fill up and go fly, then I log it. (Getting fuel is an important part of the overall process of flight.)
If I get stuck at the hold short line for 2 hours waiting to take off, then I log it. (Exhibiting patience is also an important part of the overall process of flight.)
If I taxi to the gas pump, but am not planning to fly that day, then I *don't* log it.
If I fly somewhere and stop for lunch and then fly back, I log it as one flight, because during lunch the flight is not yet "over" in my mind.
If I fly somewhere and stop for the night, whether I log it as one flight or not depends on what's going on in my mind about it: do I go to sleep thinking of the flight as "over"? Sometimes yes, sometimes no.
If I deliberately run the engine for 24 hours and then fly for 5 minutes just to prove a pedantic point about the slipperiness of the English language, then I'm a jerk. And yes, a cheater. But not because of numbers. The numbers are not the point, nor are they a solution to cheating.

32. ### EdFredTouchdown! Greaser!PoA Supporter

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So I called my DPE buddy and he basically said, if you come to me for a check ride and I see flights in your logbook that don't make sense time-wise and you haven't documented a satisfactory explanation like you were performing maneuvers during the flight, or the route of flight was not direct, he was not going to administer the check ride. You can find someone else who will accept that or get a letter from the FAA forcing me to accept that. He said they did have one renter (before he was a DPE) that would rent a 172, fly it to another airport <50nm away and then let it idle on the ramp for 2-3 hours (they had a wet and dry rate for rental) before flying back just so he could build time to 1500 hours. So there are people out there that exploit it.

His stance on the moving for the purpose of flight and what he would log is if it counted against duty time (penalty box at ORD, ground stop), then he'd log it. But if you were initiating the stoppage on purpose just to rack up the hours, not so much.

In regards to the overnight and the commercial XC, it's absolutely acceptable, and he's OK with it. Now if you vacation for 2 weeks before returning, it's iffy.

33. ### midlifeflyerFinal Approach

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Just because you can come up with something unreasonable does not make something reasonable invalid. True in aviation. True in life.

Can a student pilot do a go-around for practice at the the destination? Is the answer, "no, because he might do 3 hours of go-arounds" and

You are welcome to your "stance," but please don't take away my commercial and CFI certificates because my commercial solo took two days. I'm not even planning to tell a soloing student, "don't divert for sudden thunderstorms because I won't let you count the cross country."

34. ### midlifeflyerFinal Approach

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Exactly.

35. ### EdFredTouchdown! Greaser!PoA Supporter

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Go arounds aren't sitting on the ramp, it's actual flight time. I don't have a problem with time in the air being flight time. I have a problem with sitting on your ass time as flight time. Where did I say that diversions aren't allowable? My last student I signed off for a solo XC did just that because he wouldn't make it back by dark. (He diverted from the diversion I gave him). I actually took that into account when signing him off on the flight. But if I have a student that starts a XC and doesn't make it 50nm away, I'm not allowing that as XC time because he attempted it. Still gotta complete it.

36. ### midlifeflyerFinal Approach

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I thought it was pretty central to your comment that if there is not stated number, then no numbers are valid and your posts about not allowing any overnights on a cross country. If you can't stop and spend the night before continuing, why can you stop and spend the night for thunderstorms or it being to dark? It's still an overnight. And if your position is that since the FAA hasn't given a number of hours than no number is valid, the overnight you okayd goes against your own policy.

At least that's what you seemed to say a number of times.

I'm still trying to figure out the "sitting on your ass" part.

37. ### WannFlyEn-Route

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Um what? Few months back I went KFAR-KFSD-KOMA-KALO stayed there overnight, came back KFAR the next day.... are you saying it’s not a valid commercial XC?

38. ### TCABMCleared for Takeoff

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So intent matters, and arbitrary rules don’t is what I understand your DPE buddy is to have said.

If that’s the case, does that change any of your philosophy regarding when you start ‘counting’ flight time for your students?

Ethically speaking, of course.

39. ### SkyDog58Touchdown! Greaser!PoA Supporter

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I seem to recall people referring to around the world efforts such as Amelia Earhart's as a flight, not flights. Does that change anyone's perception?

40. ### WheelsPre-takeoff checklistPoA Supporter

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It was a valid commercial XC as soon as you landed at KALO, the return to KFAR was immaterial no matter what day it occurred on.

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