FAA Releases Cross Country and Repositioning Interpretations

[tlglenn]

http://www.faa.gov/about/office_org...rpretations/data/interps/2009/Louis Glenn.pdf

http://www.faa.gov/about/office_org...nterpretations/data/interps/2009/Hilliard.pdf

http://www.faa.gov/about/office_org...terpretations/data/interps/2009/Van Zanen.pdf

In short:
1) Unless the aircraft requires more than one pilot for the ENTIRE flight then only one pilot can log cross country time and only if he or she is the sole manipulator for the ENTIRE flight.
2) A repositioning flight is acceptable to allow the pilot to setup a subsequent flight as a cross country flight.

 

[JeffDG]

Nice and clear on the repositioning flight concept...

"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."

 

[poadeleted20]

Well, now we know. We also now know they don't know the difference between "discreet" and "discrete."

 

[EdFred]

I don't like this. Completely defeats the purpose of cross country training. Same thing with removing the complex requirement from commerical.

"Oh, look, I'll fly 26 miles east, hey I'm at 5,000 feet and can see my destination. Now I'll fly 26 miles west, hey look there's my airport, I'll fly over it, 'Hi airport', and hey look, I can see my destination 25 miles away. Yay, I did a cross country."

No, you didn't. I swear the FAA is making dumber and dumber decisions every day. Expect more new private pilots to get lost in the coming years.

 

[Bob Noel]

I don't like this. Completely defeats the purpose of cross country training. Same thing with removing the complex requirement from commerical.

"Oh, look, I'll fly 26 miles east, hey I'm at 5,000 feet and can see my destination. Now I'll fly 26 miles west, hey look there's my airport, I'll fly over it, 'Hi airport', and hey look, I can see my destination 25 miles away. Yay, I did a cross country."

No, you didn't. I swear the FAA is making dumber and dumber decisions every day. Expect more new private pilots to get lost in the coming years.

At one time CFI's approved/signed-off on student cross country flights. Don't they still do that? If so, how does this reasonable interpretation require the CFI to approve a silly cross country?

As more and more airports are lost to developers and more airports get
even more stupid "security" measures, I would expect that there will
be some areas of the country where getting the xc time could become
difficult. If in the future a student's home airport has only two usable
airports within 150 miles, one 10 miles to the east, and one 45 miles
to the west, this interpretation will be extremely helpful.

 

[TMetzinger]

If I read this right - don't share an X/C flight with another pilot if you want to log the X/C time. Only way to do that is you make the flight out and he makes the flight back.

Now, just for grins - what if I keep the hood on from takeoff to touchdown? Get steering cues from the safety pilot on takeoff, and have him call out 50...40...30...20..flare on the landing?

 

[tonycondon]

interesting that several forum names come up in the XC logging interpretation.

I wonder if All ATPs knows about this. They ain't gonna be happy...

 

[Matthew]

I don't like this. Completely defeats the purpose of cross country training. Same thing with removing the complex requirement from commerical.

"Oh, look, I'll fly 26 miles east, hey I'm at 5,000 feet and can see my destination. Now I'll fly 26 miles west, hey look there's my airport, I'll fly over it, 'Hi airport', and hey look, I can see my destination 25 miles away. Yay, I did a cross country."

No, you didn't. I swear the FAA is making dumber and dumber decisions every day. Expect more new private pilots to get lost in the coming years.

I always thought this trick was a little like cheating yourself out of a learning experience, too.

In my case, I visit my brother now and then - 46NM west. Now, I can fly to an airport about 10NM east for at t&g, then 56NM west for the trip I originally wanted to take, then 46NM east back home and count it as an XC flight. I still think it's cheating, but now it's legal.

I hope that CFIs with primary students avoid this method. I'll probably catch heat from someone for saying that, but I wouldn't have wanted to miss out on a real-live XC that required actually looking at and understanding a chart.

 

[poadeleted20]

At one time CFI's approved/signed-off on student cross country flights. Don't they still do that?

For Student Pilots, yes.

If so, how does this reasonable interpretation require the CFI to approve a silly cross country?

It doesn't. The instructor is free to set whatver minimums s/he chooses, but now has more legally-approved latitude on the low end. However, I think this is more an issue for PP's building time for the 50 hours XC PIC for their IR than anything else. Personally, I think it's a dumb idea for a pilot to be able to get an IR without ever having been more than 26nm from home, and a Commercial without having done that more than once on his/her own, but that's the FAA's ruling.

As more and more airports are lost to developers and more airports get even more stupid "security" measures, I would expect that there will be some areas of the country where getting the xc time could become difficult. If in the future a student's home airport has only two usable airports within 150 miles, one 10 miles to the east, and one 45 miles to the west, this interpretation will be extremely helpful.

I think we're a very, very long way from that being a problem.

 

[TMetzinger]

interesting that several forum names come up in the XC logging interpretation.

I wonder if All ATPs knows about this. They ain't gonna be happy...

Maybe they'll adopt my hypothetical as standard practice.

 

[SkyHog]

I don't like this. Completely defeats the purpose of cross country training. Same thing with removing the complex requirement from commerical.

"Oh, look, I'll fly 26 miles east, hey I'm at 5,000 feet and can see my destination. Now I'll fly 26 miles west, hey look there's my airport, I'll fly over it, 'Hi airport', and hey look, I can see my destination 25 miles away. Yay, I did a cross country."

No, you didn't. I swear the FAA is making dumber and dumber decisions every day. Expect more new private pilots to get lost in the coming years.

Can you quote where that is true, Ed, I'm not seeing anything about a landing no longer being required...

 

[TMetzinger]

Can you quote where that is true, Ed, I'm not seeing anything about a landing no longer being required...

See the regs for counting towards ATP. No landing at another airport required.

 

[SkyHog]

Also, why do they keep using:

and that involves the use of dead reckoning, pilotage, electronic
navigation aids, radio aids, or other navigation systems to navigate to the landing point.

Is it so that you can't get 100% lost, stumble across an airfield by accident, and log it as XC?

 

[SkyHog]

See the regs for counting towards ATP. No landing at another airport required.

I know that for ATP, but I was assuming Ed meant for lower ratings now.

 

[TMetzinger]

Nah, I think Ed's complaint is that for lower ratings, one can hop from airport to airport in short hops and log it all as X/C as long as ONE of the airports is more than 50 NM from another airport in the chain.

 

[poadeleted20]

Nah, I think Ed's complaint is that for lower ratings, one can hop from airport to airport in short hops and log it all as X/C as long as ONE of the airports is more than 50 NM from another airport in the chain.

Hence, my comment about getting your IR without ever going more than 26nm from home.

 

[Matthew]

Also, why do they keep using:



Is it so that you can't get 100% lost, stumble across an airfield by accident, and log it as XC?

I'm certainly no expert, but I think that's exactly the reason. I can't remember the wording in the PTS, something like "the outcome of the maneuver never in doubt"? If a student intends to navigate to airport A, and ends up at airport B instead, I think the intention is to force a do-over.

 

[poadeleted20]

I'm certainly no expert, but I think that's exactly the reason. I can't remember the wording in the PTS, something like "the outcome of the maneuver never in doubt"? If a student intends to navigate to airport A, and ends up at airport B instead, I think the intention is to force a do-over.

True on the PTS, but not for training. Of course, if one of my students ever got lost, that flight would be a do-over (after a bit more training) before I'd sign him/her off for the practical test even if the FAA says it's not necessary. But that's just me.

 

[SkyHog]

True on the PTS, but not for training. Of course, if one of my students ever got lost, that flight would be a do-over (after a bit more training) before I'd sign him/her off for the practical test even if the FAA says it's not necessary. But that's just me.

Would you say then, if a pilot departed VFR, got completely lost, and landed at the first strip he managed to see without using a map, a VOR, an NDB, a GPS, or vectors, that he cannot legally log it as XC? That's kind of how I read it.

And that seems bizarre.

 

[Matthew]

True on the PTS, but not for training.

Yeah - I was just trying to make a comparison. However, like the next question: "Would you say then, if a pilot departed VFR, got completely lost, and landed at the first strip he managed to see without using a map, a VOR, an NDB, a GPS, or vectors, that he cannot legally log it as XC? That's kind of how I read it."

I do think the intention is that if you just accidentally find an airport, the XC requirement of actually navigating to it on purpose has not been met.

 

[poadeleted20]

Would you say then, if a pilot departed VFR, got completely lost, and landed at the first strip he managed to see without using a map, a VOR, an NDB, a GPS, or vectors, that he cannot legally log it as XC? That's kind of how I read it.

I'd say that if it was a training flight, I'd make that trainee do it over without getting lost. But if that strip was over 50nm from home, it could be logged as XC PIC for PP/IR/CP experience purposes. Of course, if it were a Student Pilot, that log entry would raise some questions about compliance with 61.93, although I've never heard of the FAA busting anyone on that issue if they really got lost. See Administrator v. Corrigan, 1938.

 

[gismo]

Now, just for grins - what if I keep the hood on from takeoff to touchdown? Get steering cues from the safety pilot on takeoff, and have him call out 50...40...30...20..flare on the landing?

I assume you mean besides how this will look on the NTSB accident report?

 

[EdFred]

Can you quote where that is true, Ed, I'm not seeing anything about a landing no longer being required...

Sorry forgot to add that he landed at the airport 25 miles on the other side.

 

[wabower]

PIcky. A town or two one way or the other should be close enough.

True on the PTS, but not for training. Of course, if one of my students ever got lost, that flight would be a do-over (after a bit more training) before I'd sign him/her off for the practical test even if the FAA says it's not necessary. But that's just me.

 

[poadeleted20]

Sorry forgot to add that he landed at the airport 25 miles on the other side.

He will have to have landed at the one airport east of home, and then again at the other airport west of home, to have a flight with a landing over 50 miles from the "adjusted" OPD (the airport east of home) for PP/IR/CP XC experience purposes. BTW, if this involves a Student Pilot, the instructor will have to take care of 61.93 for the repositioning flight if it goes more than 25nm from home, and then another endorsement for the "real" XC flight.

 

[SkyHog]

I'd say that if it was a training flight, I'd make that trainee do it over without getting lost. But if that strip was over 50nm from home, it could be logged as XC PIC for PP/IR/CP experience purposes. Of course, if it were a Student Pilot, that log entry would raise some questions about compliance with 61.93, although I've never heard of the FAA busting anyone on that issue if they really got lost. See Administrator v. Corrigan, 1938.

What is the meaning behind requiring some sort of navigation means? That's what confusing me

 

[poadeleted20]

What is the meaning behind requiring some sort of navigation means? That's what confusing me

I have no idea. I suppose that if you saw the airport and flew to it, you used pilotage at least for that part of the flight.

 

[SkyHog]

I have no idea. I suppose that if you saw the airport and flew to it, you used pilotage at least for that part of the flight.

LOL.

I imagine flying along, and suddenly the wheels hit concrete and the pilot goes "holy crap, I just landed at an airport, wtf?" doesn't count then.

 

[Bob Noel]

Hence, my comment about getting your IR without ever going more than 26nm from home.

um, I'm not being a wise***, but how would the applicant meet the
requirement for: "A flight of 250 nautical miles along airways or by
directed routing from an air traffic control facility"?

 

[SkyHog]

um, I'm not being a wise***, but how would the applicant meet the
requirement for: "A flight of 250 nautical miles along airways or by
directed routing from an air traffic control facility"?

Since it is along airways, a flight could easily be within 26nm and along airways for more than 250nm.

Not pretty, but doable.

 

[gismo]

See the regs for counting towards ATP. No landing at another airport required.

That's been the case for as long as I can remember. IIRC the FAA specifically allows XC time without regard to any landings (for ATP applicant experience requirements) so that SAC bomber pilots could log XC time on missions.

 

[Matthew]

LOL.

I imagine flying along, and suddenly the wheels hit concrete and the pilot goes "holy crap, I just landed at an airport, wtf?" doesn't count then.

Hey, no fair! That's exactly what I said on my first solo!

 

[EdFred]

um, I'm not being a wise***, but how would the applicant meet the
requirement for: "A flight of 250 nautical miles along airways or by
directed routing from an air traffic control facility"?

While it might be just outside 26nm for me, I could fly to GRR, then fly V274, V26, V510, and keep flying that triangle until I tally 250nm.

 

[SkyHog]

While it might be just outside 26nm for me, I could fly to GRR, then fly V274, V26, V84, and keep flying that triangle until I tally 250nm.

From KSAF:

KSAF SAF V83 CAYAL V190 RENCO V62 SAF V83 CAYAL V190 RENCO V62 SAF lather rinse repeat until returning to land.

Furthest distance from KSAF?

24nm.

 

[EdFred]

There ya go. I'm inside a triangle of GRR, LAN, and KAZO, all of which I can "see" from 9D9 at altitude. I can see the airports, just can't see the VORs themselves, the Lansing VOR is furthest away at 28.8nm.

 

[poadeleted20]

From KSAF:

KSAF SAF V83 CAYAL V190 RENCO V62 SAF V83 CAYAL V190 RENCO V62 SAF lather rinse repeat until returning to land.

Furthest distance from KSAF?

24nm.

No good, because that would not be a "cross-country flight" per 61.1(b)(3)(ii), and thus would not count for 61.65(d)(2)(iii).

(iii) For an instrument-airplane rating, instrument training on cross- country flight procedures specific to airplanes that includes at least one cross-country flight in an airplane that is performed under IFR, and consists of-
(A) A distance of at least 250 nautical miles along airways or ATC-directed routing;

Since your flight a "cross-country flight" for IR experience purposes under 61.1(b)(3)(ii), it doesn't meet spec. You'd have to fly from KSAF to airport #2 over at the edge of the 25nm circle, land there, and then start a flight which included a landing at airport #3 on the other side of the circle more than 50nm from airport #2 before returning to airport #1 after covering at least 250nm of flying after leaving airport #2. In that case, you could do the flight without going more than 25.1 nm from home, but not without going more than 24nm from home, since that would limit the longest leg to 48nm and thus not be a "cross-country flight" for IR experience purposes.

 

[EdFred]

I don't recall the IR requring a landing.

 

[poadeleted20]

I don't recall the IR requring a landing.

If there's no landing, it's not a cross-country under 61.1(b)(3)(i), and doesn't count for 61.65(d)(2)(iii) since that flight is required for an IR and must be a "cross-country," making 61.1(b)(3)(i) applicable and a landing required. See the boldfaced words in the reg quoted in post #36.

As a CFI-IA, don't ever make the mistake of having an IR trainee of fly this one as a round robin with only low approaches at the corners. If the examiner sees only one landing on that flight, your trainee will be sent home to refly it, and will probably (and rightly, I think) expect you to pay for it, and you may get to explain yourself to the FSDO for signing off an applicant who didn't meet the requirements.

 

[EdFred]

If there's no landing, it's not a cross-country under 61.1(b)(3)(i), and doesn't count for 61.65(d)(2)(iii) since that flight is required for an IR and must be a "cross-country," making 61.1(b)(3)(i) applicable and a landing required. See the boldfaced words in the reg quoted in post #36.

As a CFI-IA, don't ever make the mistake of having an IR trainee of fly this one as a round robin with only low approaches at the corners. If the examiner sees only one landing on that flight, your trainee will be sent home to refly it, and will probably (and rightly, I think) expect you to pay for it, and you may get to explain yourself to the FSDO for signing off an applicant who didn't meet the requirements.

Is there a legal opinion on this? The only reason I ask is because all the other XC flights - that I can think of right now - specifically require a point of landing (more than 50nm, more than 250nm from point of departure) and this one does not. Additionally cross country for ATPs do not need to include a landing. I was always under the assumption that we aren't to read into regs things that aren't there, but to read them only as stated unless a legal opinion says otherwise.



Nevermind...I re-read 61.1 and see that since ATP isn't mentioned *that* is why it does not apply. Although it says cross country time, and not cross country flight in 61.1 The cross country in 61.65 does not indicate any time required, only distance.

 

[Exocetid]

This issue came up for me today. I flew from BPT to LFK, 86 NM one way. I got up there and the place was buzzing like a hornet's nest. Twice I went in on a long final and decided not to land because of someone on the runway, leaving the runway, or on the crosswise runway. Since it was calm the locals decided that the active was whatever rwy was handy. Anyway, not knocking them, I just decided I didn't need a landing and just headed back. i was just out for a Sunday fly around anyway.

So, I am dutifully filling out my logbook and wondered if my little afternoon flight qualifies as a CC. The roundtrip was a 172 NM, but I did not do a landing, although there was some navigating to get up there obviously.

Oh, and jeez are those Cessna's slow--I had forgotten.