FAA Legal Clarifies XC Definition! (xpost!)

[etsisk]

In THIS thread from the red board, I was wondering about the FSDO's requirement that (for IR training requirements) a cross country flight MUST include ONE LEG that was greater than 50 nm from the original point of departure and included a landing greater than 50 nm from departure.

So I wrote FAA legal and asked them. Their response (this is the discussion section of the letter):

As noted above (14 CFR 61.1(b)(3)), cross country flight time is defined as time acquired during a flight that includes a point of landing that is at least a straight-line distance of more than 50 nm from the original point of departure, not the original point of any flight leg. There is no requirement that any specific leg must be 50 nm. Moreover, a cross-sountry flight may include several legs that are less than a straight-line distance of more than 50 nm from the original point of departure. Nevertheless, at least one leg of the cross-country flight, however long by itself, must include a point of landing that is at least a straight-line distance of more than 50 nm from the original point of departure (i.e. of the flight, not of that particular leg). (all emphasis is mine - ets)

Given the above analysis, the answer is each cross-country flight used to meet the aeronautical experience requirements under 14 CFR 61.1(b)(3) must include one leg that includes a landing that is at least a straight-line distance of more than 50 nm from the original point of departure.

This response was prepared by Adrianne Wojcik, an Attorney in the Regulations Division of the Office of the Chief Counsel, and has been coordinated with the General Aviation Division of Flight Standards Service.

So, yes, you can create a legal cross country flight by stringing together as many 3 nm legs as you have the patience to string together, as long as ONE landing amongst the lot of 'em occurs at a place that is more than 50 nm straight-line distance from the original point of departure for the flight, not the leg.

Isn't that nice?

 

[EdFred]

Yeah,

The smart ones have been saying that for quite some time now.

BTW, how did you get an answer? I wrote them a year ago with no response.

 

[etsisk]

just lucky, I guess - what I did was print out the letter and fax it to them, with a phone call that it was coming. Perhaps the fact that I had gotten conflicting information from a FSDO helped move it along. Even so, the reply was darn near 4 months to the day in coming!

 

[KennyFlys]

Yeah,

The smart ones have been saying that for quite some time now.

So, you've not been saying this?

I had known about it before. The weird thing about this is rule is you can fly out fifty miles, land, throw in another or however many you wish, then return to your home drome... do all the touch-n-goes you want as part of the same flight... then, log the entire thing as cross-country. I don't think anyone would do this but it's just funny how it can be interpreted. Such an action could enable you to accumulate the required XC time toward a commercial ticket.

But, the landings do have to be on a normal runway. No conveyors.

 

[flyingcheesehead]

I had known about it before. The weird thing about this is rule is you can fly out fifty miles, land, throw in another or however many you wish, then return to your home drome... do all the touch-n-goes you want as part of the same flight... then, log the entire thing as cross-country. I don't think anyone would do this but it's just funny how it can be interpreted.

Likewise, let's just say that you always use the same practice area (for me at MSN, I was pretty much always in the NW practice area). Let's say I flew 49nm southwest, then flew to an airport 49nm east of the departure airport, and then returned. The middle leg would be 2(49 cos 67.5) = 90.5 nm, the total trip would be 188.5nm, and the closest you ever got to the departure airport on the middle leg would be 49 cos 67.5 = 18.75nm away, and on the side of the airport you haven't been to. But, it doesn't count - Unless you make one quick hop across that 50nm ring around the departure airport.

I suppose, all things considered, the rule is about as good as it can be. No matter what the rule was, you'd be able to find an extreme case that didn't make sense (as both of us just did) but I think for the most part it works as intended.

 

[KennyFlys]

I suppose, all things considered, the rule is about as good as it can be. No matter what the rule was, you'd be able to find an extreme case that didn't make sense (as both of us just did) but I think for the most part it works as intended.

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

If I discovered my student doing that, I'd push for their visa termination and send them home. From what I know about the school's owner, he'd do it, too. If the student is taking that short-cut, who knows what other short-cuts they are taking when not supervised.

For the life of me, I won't understand why someone would be so dang lazy. I'd take advantage of that time and go truly enjoy a nice XC to somewhere. Heck, if I'm paying for it I'm gonna get something out of it. Hopefully, I can encourage my students to make their XC fun by going a few places that are more than just meeting the requirement.

 

[gprellwitz]

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

If I discovered my student doing that, I'd push for their visa termination and send them home. From what I know about the school's owner, he'd do it, too. If the student is taking that short-cut, who knows what other short-cuts they are taking when not supervised.

For the life of me, I won't understand why someone would be so dang lazy. I'd take advantage of that time and go truly enjoy a nice XC to somewhere. Heck, if I'm paying for it I'm gonna get something out of it. Hopefully, I can encourage my students to make their XC fun by going a few places that are more than just meeting the requirement.

It's just terrifying that someone would think that's alright to do! I pray to all the Hindu Gods that I never have one of them as my pilot!

 

[midlifeflyer]

Also a cross-post - here's the official opinion:

http://www.faa.gov/about/office_org...00/interpretations/data/interps/2008/Sisk.pdf

 

[Teller1900]

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

One of the CAs I fly with has a story like that...Student took a plane out, flew two towns over, tied the tail down, left the engine running, and went off to lunch. About two hours into it, someone happened by the plane and called the authorities. Kid got in a pretty good amount of trouble on that one.

 

[midlifeflyer]

BTW, how did you get an answer? I wrote them a year ago with no response.

Was your question this easy, or would it have required some research?

 

[n20junkie]

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

If I discovered my student doing that, I'd push for their visa termination and send them home. From what I know about the school's owner, he'd do it, too. If the student is taking that short-cut, who knows what other short-cuts they are taking when not supervised.

For the life of me, I won't understand why someone would be so dang lazy. I'd take advantage of that time and go truly enjoy a nice XC to somewhere. Heck, if I'm paying for it I'm gonna get something out of it. Hopefully, I can encourage my students to make their XC fun by going a few places that are more than just meeting the requirement.

That happens when flight schools try to milk students for the time spent on the battery, as most aircraft are set up with a oil pressure switch for just such a reason. Why would you want to log every time a mechanic turns a battery on to check a radio or what not. Its just a wat to get a .2 out of every student the way I see it.

 

[KennyFlys]

That happens when flight schools try to milk students for the time spent on the battery, as most aircraft are set up with a oil pressure switch for just such a reason. Why would you want to log every time a mechanic turns a battery on to check a radio or what not. Its just a way to get a .2 out of every student the way I see it.

I can't tell you how often I've seen preflights performed with the master left on the entire time. That's a heck of a drain on the battery. In the case of the Diamond 20, the battery is no larger than that on a motorcycle. The flaps are not lowered during preflight for this very reason. I've seen a Skyhawk need ground power twice in the last three years. In the last two weeks around the DA-20, I've seen it twice on two different aircraft.

So, while it may seem a means to collect more on the rental, I think it's more so an incentive to properly handle the aircraft on the ground during preflight. It's not so far off why aircraft are rented wet instead of dry. Dry rates seem to be an incentive to lean out and run the engine hot. Fouled plugs are a lot cheaper to deal with than an engine falling far short of TBO.

/7500

 

[flyingcheesehead]

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

If I discovered my student doing that, I'd push for their visa termination and send them home.

Holy crap!!! These people are going to call themselves pilots???

Heck, if they're paying for it, why not FLY it? That makes absolutely no sense to me. And who the heck puts single-engine (I'm assuming) hobbs on the master switch?

And frankly, you'd be a lot nicer to them than I would. I'd be tempted to feed them to a prop headfirst.

 

[KennyFlys]

Heck, if they're paying for it, why not FLY it? That makes absolutely no sense to me. And who the heck puts single-engine (I'm assuming) hobbs on the master switch?

Beats me. Idiot move, obviously.

I addressed the Hobbs idea in the the thread prior to your post.

 

[EdFred]

But, the landings do have to be on a normal runway.

Where does it say runway in the regs?

 

[ScottM]

But, the landings do have to be on a normal runway. No conveyors.

But conveyors can be used for take off!!

BTW what is a normal runway?

 

[Skip Miller]

BTW what is a normal runway?

I suppose the runways at KBMI could be considered "normal runways"....

-Skip

 

[ScottM]

I suppose the runways at KBMI could be considered "normal runways"....

-Skip

yep

I am sure you are right about that.

BTW that was were I went for my dual and solo XCs

 

[infotango]

BTW, how did you get an answer? I wrote them a year ago with no response.

The wheels of bureaucracy grind veeerrry very slowly.....

 

[etsisk]

The wheels of bureaucracy grind veeerrry very slowly.....

Plus ya have to be a really, really great person!

 

[KennyFlys]

Where does it say runway in the regs?

Well, we could shave your head with some runway-like markings and offer it to a scuffed up nose tire.

 

[jesse]

The flaps are not lowered during preflight for this very reason.

When I flew the DA-20 I always set the flaps to 'Take-Off' during preflight. Since I needed the flaps for takeoff I always checked them in the position I was taking to the air with. I would leave them on Take-Off until I was in the air.

If you are going to check your flight controls you might as well check all of them. I don't know the mechanics well enough to know if split flaps are possible on a DA-20 but I don't ever want to find out the hard way.

I generally always take off with flaps and I'm probably overly paranoid about making sure they are both operating correctly and are both even. Flight control failure has always been a fear of mine. I try to avoid it.

 

[flyingcheesehead]

When I flew the DA-20 I always set the flaps to 'Take-Off' during preflight. Since I needed the flaps for takeoff I always checked them in the position I was taking to the air with. I would leave them on Take-Off until I was in the air.

If you are going to check your flight controls you might as well check all of them. I don't know the mechanics well enough to know if split flaps are possible on a DA-20 but I don't ever want to find out the hard way.

I generally always take off with flaps and I'm probably overly paranoid about making sure they are both operating correctly and are both even. Flight control failure has always been a fear of mine. I try to avoid it.

And you'd be right to check the flaps... It's item #18 in the preflight checklist in the POH.

 

[jesse]

And you'd be right to check the flaps... It's item #18 in the preflight checklist in the POH.

I've also found that the DA-20-C1 battery has plenty of power. It'll spin that prop around for quite awhile before it goes dead. If the temperature is below 25 degrees it's not going to start without being plugged in. Plug it in and it'll fire right up.

 

[t0r0nad0]

Likewise, let's just say that you always use the same practice area (for me at MSN, I was pretty much always in the NW practice area). Let's say I flew 49nm southwest, then flew to an airport 49nm east of the departure airport, and then returned. The middle leg would be 2(49 cos 67.5) = 90.5 nm, the total trip would be 188.5nm, and the closest you ever got to the departure airport on the middle leg would be 49 cos 67.5 = 18.75nm away, and on the side of the airport you haven't been to. But, it doesn't count - Unless you make one quick hop across that 50nm ring around the departure airport.

Too... much... trigonometry!!!! Head... going... to... explode!!!

One of the things discovered at my old school was Indian students would fly off to a nearby airport, go into the deli and eat. Meanwhile, they leave the master on and the Hobbs ticks away. Obviously, they are paying for the time. But, all they want is the total time and the supposed XC time to qualify for a commercial ticket.

If I discovered my student doing that, I'd push for their visa termination and send them home. From what I know about the school's owner, he'd do it, too. If the student is taking that short-cut, who knows what other short-cuts they are taking when not supervised.

For the life of me, I won't understand why someone would be so dang lazy. I'd take advantage of that time and go truly enjoy a nice XC to somewhere. Heck, if I'm paying for it I'm gonna get something out of it. Hopefully, I can encourage my students to make their XC fun by going a few places that are more than just meeting the requirement.

Yeah, I definitely would push for that... furthermore, I would try to write a letter to the FAA to try to ensure that they will never get a US Pilot's Certificate. As was said above, if they habitually take that kind of shortcut in their training, who's to say that they won't in their "professional" flying career? To build x-c time for a commercial rating, I would be more tempted to knock off a few airports on this site.

How's they get discovered? Did someone finally question how they flew around for 3 hrs and still had a full tank of gas?

 

[KennyFlys]

And you'd be right to check the flaps... It's item #18 in the preflight checklist in the POH.

Flaps are cycled after engine start per our revised checklist which are approved by the POI. Add to that, a few aircraft on leaseback to us are owned by inspectors.

I don't know what types of operations you've seen DA-20s undergo. But, it would be an eye-opener to watch the abuse by international students who will not always listen and you can't control what may happen while away from the base on solo. We have twenty-three DA-20s between the five locations. Add another six DA-40s and five DA-42s. I'd have to look up the number and variety of Cessnas and Pipers used in training. Someone along the way figured out what works best to keep these birds flying more regularly without maintenance issues.

 

[ScottM]

a cross country flight MUST include ONE LEG that was greater than 50 nm from the original point of departure and included a landing greater than 50 nm from departure.

Yeah, I know, necrothread!

I was digging in the regs last night about rotorcraft requirements and ran into the >50NM XC rule does not apply.

XC for rotorcraft is >25NM

§61.1 Applicability and definitions.

(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating).......
( 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; ....

Looking further into the text you find this subheading:

§61.1 Applicability and definitions.

(v) For the purpose of meeting the aeronautical experience requirements for any pilot certificate with a rotorcraft category rating or an instrument-helicopter rating

( B ) That includes a point of landing that was at least a straight-line distance of more than 25 nautical miles from the original point of departure;

Interesting.