Uh oh, FSDO and XC definitions...

[etsisk]

Well, after a discussion with my instructor about what constitutes a cross country flight for instrument rating purposes (he said ya have to have a 50nm+ leg) he suggested that I contact Greensboro FSDO and ask them.

So I did.

I talked with one of the guys there for about 25 minutes, bless his heart. And, in honor of my argument to the contrary, he went and consulted with the OTHER four guys there. And they ALL said that ...

A CROSS-COUNTRY FLIGHT FOR THE PURPOSES OF THE INSTRUMENT RATING 61.1.b.3.ii, THE FLIGHT MUST INCLUDE ONE LEG OF MORE THAN 51nm LENGTH FROM THE ORIGINATING AIRPORT.

Y'all might note that this is in direct disagreement with the definition as we read it - meaning that you could fly as many short legs as you wanted, as long as you made ONE landing at an airport that was a straight line distance of more than 50 nm from the original point of departure. So what they're saying is, you have to have that one long leg, then you can stop as many times after that as you want.

I pointed out that in the definition for the student pilot long cross-country, the regs specifically mentioned that there had to be ONE SEGMENT OF THE FLIGHT that was 51 or more nm long, and that the ABSENCE of that specific clause meant the absence of that specific requirement. They weren't buying it. It was, however, a good conversation. Except for the outcome.

So, if anyone knows a ruling that supports our position and can post a citation to that ruling, I would surely love to see it!

 

[gprellwitz]

Did they provide you a cite to the regs or anything to support their contention?

 

[KennyFlys]

In their minds, they don't have to provide one.

 

[gprellwitz]

In their minds, they don't have to provide one.

Yeah, but there's still a hierarchy at the FAA, and at some point someone may have to argue that one FSDO's interpretation is more correct than another's. Isn't that part of what AFS-800 is about?

Heck, it might not hurt to file a comment at http://www.faa.gov/about/office_org/headquarters_offices/avs/customer_feedback/afs/afs800/

 

[poadeleted20]

"(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under §61.101 (c), time acquired during a flight—
"(A) Conducted in an appropriate aircraft;
"(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; and
"(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point."

Send the FSDO a letter (with a cc: to the Regional Counsel's office) detailing the conversation and requesting a written answer signed by the Regional Counsel (or the Chief Counsel's Office) which says that 14 CFR 61.1(b)(3)(ii) (quoted above) means "THE FLIGHT MUST INCLUDE ONE LEG OF MORE THAN 51nm LENGTH FROM THE ORIGINATING AIRPORT." That should fix the problem.

 

[Ghery]

Clearly there are some folks at that FSDO who have a hard time reading and understanding the English language. I have no idea where they came up with that interpretation. Not from the words in the regulations, that's for sure.

 

[gismo]

" That should fix the problem.

Sorry, IMO that won't fix the problem, i.e. FAA personnel insisting that their faulty interpretation of the rules is all that matters.

 

[judypilot]

OK, then, admitting the FAA can't read, let's look at the spirit of the regulation. You're trying to learn how to fly cross-country on instruments. The longer the distance between airports, the more opportunities to screw up. You want to learn not to screw up. Ergo, it is an essential part of your training (IMHO) that you have to gain the skills and confidence not to screw up on a long XC (and 50 nm isn't long--in my airplane, it's <1/2 hour). I'm not convinced that airport-hopping your way to some point 50 nm away from your home airport and then airport-hopping your way back is going to teach you those skills; if nothing else, you have to learn how to handle the boredom of flying so long without being able to see anything but the panel.

Judy

 

[bbchien]

Just write the counsel general. Get it over with.

 

[etsisk]

well, a good question was raised: do we really want a concrete definition? Once we've got one, that's it - even if it's one we don't like!

Thank heavens this is such small potatoes!

 

[poadeleted20]

well, a good question was raised: do we really want a concrete definition? Once we've got one, that's it - even if it's one we don't like!

Yes, we do want that definition, and it's already written in concrete by the Chief Counsel's office. Having a FSDO rewrite their own contrary definition is bad for everyone. Send them the letter I suggested! And if you don't want to, send me an email detailing who/what/when and I'll take care of it myself.

 

[etsisk]

oh, what the heck! I'll send the letter!