CPL Long X-Country Question

[Murdoughnut]

Looking at my logbook, I did one long cross country flight from KPIE to KAGS (330nm straight line distance) with a fuel stop at KAYS. Two days later I departed KAGS for the return trip, stopping at KGNV for gas on the way.

I had been planning a separate long cross country flight thinking that the above trip wouldn't count since it was "two flights" despite being a single trip, and because it was spread over three days. But then I saw some folks posting that as long as you're returning to your point of origin, it's still one flight.

Thoughts?

 

[Sky Dog]

I can’t find it now, but I remember reading an FAA interpretation that said that the cross country could be logged over multiple days as long as the final leg ends at the original departure point. I researched it for a commercial student I was working with who had a similar situation where the departure and return were a couple of days apart. He had fuel stops on the way out and back so all the other requirements were met.

I would contact your DPE to make sure he/she interprets it that way or not. If not, you could Google the official FAA opinion on it to see if that changes his mind, but the DPE has the final say.

 

[MidlifeFlyer]

the cross country could be logged over multiple days

Yes, it can be done over multiple days. The earliest statement I know is from the old, disowned Part 61 FAQ, ""The 'original point of departure' for the purpose of a cross country does not change with a new day or delay." In 2009, answering a number of question about cross country logging (mostly regarding safety pilot scenarios), the FAA Chief Counsel made the following observation in response to a question about repositioning fights:

“There is nothing in § 61.1(b)(3)(ii) or previous FAA interpretations dictating how separate flights must be logged. 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. Section 61.1(b)(3)(ii) requires that the flight include a landing at a point other than the point of departure.” 2009 Glenn Letter

So long as you are not being ridiculous - you fly to a destination, hang around for two weeks, fly some more, and call it a single flight, it's pretty much in the eye of the beholder. FWIW, Mine was over the course of 4 days..

as long as the final leg ends at the original departure point.

There is no interpretation which requires an cross country of any type to be a round robin. Most tend to be round robins for obvious reasons. But can you imagine flying commercially from Virginia to California to pick up your new airplane, flying it home being told the three day, 2,000+ mile one-way trip with 4 fuel stops and an overnight didn't count?

 

[Old Pete]

but the DPE has the final say.

Not necessarily, there are other DPEs and other FSDOs, who may not interpret things the same way, twice I switched DPEs because they did not have the same understanding of the regs, as I did.

 

[Murdoughnut]

Not necessarily, there are other DPEs and other FSDOs, who may not interpret things the same way, twice I switched DPEs because they did not have the same understanding of the regs, as I did.

So to that point, I contacted the DPE I would probably use for this and he threw me a curveball stance that I haven't seen anyone take. His feedback was "no, it wouldn't count" ... not because of the time elapsed between departure/return ... but because he says he interprets the regulation to suggest that you have to fly a 250nm leg without stopping. Because I stopped for fuel once on each side of the trip - none of the non-stop legs was greater to or equal to 250nm.

Not how I read it when I look at it, but he's the law - will be doing another one.

 

[killbilly]

I had to go back over my logbook to double check this, because I had a fuel stop (and another one) in my long CSEL XC, but the leg between the two stops was 334NM.

The DPE had zero problem with this.

 

[Beefy McGee]

So to that point, I contacted the DPE I would probably use for this and he threw me a curveball stance that I haven't seen anyone take. His feedback was "no, it wouldn't count" ... not because of the time elapsed between departure/return ... but because he says he interprets the regulation to suggest that you have to fly a 250nm leg without stopping. Because I stopped for fuel once on each side of the trip - none of the non-stop legs was greater to or equal to 250nm.

Not how I read it when I look at it, but he's the law - will be doing another one.

Yeah, I remember in my program there had to be a single leg at least 250nm long as one of the key tasks, which would require you to successfully navigate that long distance. In the old days, that was a harder VOR/NDB navigation task than it is now with GPS so common.

 

[Sky Dog]

There is no interpretation which requires an cross country of any type to be a round robin. Most tend to be round robins for obvious reasons. But can you imagine flying commercially from Virginia to California to pick up your new airplane, flying it home being told the three day, 2,000+ mile one-way trip with 4 fuel stops and an overnight didn't count?

That is true. I’m not sure exactly what I was thinking when I wrote that. As long as you have 300 NM, 3 different points of landing, and one of those points is at least 250 NM from your departure point, you’re good.

 

[Sky Dog]

Not necessarily, there are other DPEs and other FSDOs, who may not interpret things the same way, twice I switched DPEs because they did not have the same understanding of the regs, as I did.

Yes, ultimately it’s up to the FSDO, though they don’t usually get involved unless you call them or there’s been a problem with the DPE. And choosing another DPE is always an option. Just remember that many of them are friends and talk to each other, so if you have a disagreement with one about the regs, stay respectful or you may have to go farther than you had intended to find a DPE for your checkride!

 

[drunkenbeagle]

So to that point, I contacted the DPE I would probably use for this and he threw me a curveball stance that I haven't seen anyone take. His feedback was "no, it wouldn't count" ... not because of the time elapsed between departure/return ... but because he says he interprets the regulation to suggest that you have to fly a 250nm leg without stopping. Because I stopped for fuel once on each side of the trip - none of the non-stop legs was greater to or equal to 250nm.

Not how I read it when I look at it, but he's the law - will be doing another one.

Yeah, well, because the 61.129 doesn't say that. It says:

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.

A 301 nm mile, one way flight with two stops along the way meets that definition. Since "flight" is singular, and "landings" is plural, the requirement is clearly that at least one of the landings be 250 nm from where you started. Says nothing about where those other landings are, other than they can't be the same place. Besides, if a longer leg were the point of the regulation, why require multiple landings? And there are plenty of airplanes that can't do a 250nm leg without a fuel stop anyway.

 

[Sky Dog]

So to that point, I contacted the DPE I would probably use for this and he threw me a curveball stance that I haven't seen anyone take. His feedback was "no, it wouldn't count" ... not because of the time elapsed between departure/return ... but because he says he interprets the regulation to suggest that you have to fly a 250nm leg without stopping. Because I stopped for fuel once on each side of the trip - none of the non-stop legs was greater to or equal to 250nm.

Not how I read it when I look at it, but he's the law - will be doing another one.

He is incorrect. Here is the exact wording:

“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.”

Nowhere does it say one leg has to be 250 NM. Compare to how they state the requirements for PPL:

“One solo cross country flight of 150 nautical miles total distance, with full-stop landings at three points, and one segment of the flight consisting of a straight-line distance of more than 50 nautical miles between the takeoff and landing locations; “

Note the phraseology “one segment of the flight…” If they had wanted one segment of the CPL cross country to be over 250 NM, they would have worded it similarly.

I have seen a lot of flight schools and DPEs misinterpret that bit.

Maybe a call to your local FSDO would help.

Or just go fly a long cross country that checks all the boxes as your DPE interprets it. After all, that’s why we do this: to fly.

 

[Beefy McGee]

He is incorrect. Here is the exact wording:

“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.”

Nowhere does it say one leg has to be 250 NM. Compare to how they state the requirements for PPL:

“One solo cross country flight of 150 nautical miles total distance, with full-stop landings at three points, and one segment of the flight consisting of a straight-line distance of more than 50 nautical miles between the takeoff and landing locations; “

Note the phraseology “one segment of the flight…” If they had wanted one segment of the CPL cross country to be over 250 NM, they would have worded it similarly.

I have seen a lot of flight schools and DPEs misinterpret that bit.

Maybe a call to your local FSDO would help.

Or just go fly a long cross country that checks all the boxes as your DPE interprets it. After all, that’s why we do this: to fly.

It also depends on the program he's in. If it's a 141 school and their FSDO interpreted the FAR as a 250 mile segment or the program as approved by the FSDO says 250 mile segment, then it will need to be a 250 mile segment. My long cross country had a 250 mile segment from central IL to Joplin, MO with the total distance with all stops well over 300 miles. It was a Cessna 172 so that range / 3.5ish hour flight time was no problem.

 

[Sky Dog]

It also depends on the program he's in. If it's a 141 school and their FSDO interpreted the FAR as a 250 mile segment or the program as approved by the FSDO says 250 mile segment, then it will need to be a 250 mile segment. My long cross country had a 250 mile segment from central IL to Joplin, MO with the total distance with all stops well over 300 miles. It was a Cessna 172 so that range / 3.5ish hour flight time was no problem.

True, but in that case the OP would have done the long cross country as part of the course and it would have met all the requirements for the program.

 

[MidlifeFlyer]

So to that point, I contacted the DPE I would probably use for this and he threw me a curveball stance that I haven't seen anyone take. His feedback was "no, it wouldn't count" ... not because of the time elapsed between departure/return ... but because he says he interprets the regulation to suggest that you have to fly a 250nm leg without stopping. Because I stopped for fuel once on each side of the trip - none of the non-stop legs was greater to or equal to 250nm.

Not how I read it when I look at it, but he's the law - will be doing another one.

Assuming it's not a Part 141 with some weird special requirement, he's wrong. Period. There is no 250 leg requirement In 61.129.

Ask him again to be sure. If he sticks to it, might be better to find a DPE who knows the rules they are supposed to be testing, You have no idea how many other nonexistent rules this one will make up.

funny. This is reminiscent of an interpretation publishEd by the Buffalo FSDO many years ago. They insisted every leg of a student solo cross country needed to be more than 50 NM. It was amazing how quickly it disappeared after the Chief Counsel got involved.

 

[AA34]

A bit unrelated but I’ve got a lot of XC flights that would qualify for the Commercial requirements that I have to go back and redo because I always had a passenger with me so they weren’t “solo” as I wasn’t the sole occupant.
Can anyone explain how having my wife with me (furthest thing from a pilot) is somehow detrimental to the requirement?

 

[killbilly]

A bit unrelated but I’ve got a lot of XC flights that would qualify for the Commercial requirements that I have to go back and redo because I always had a passenger with me so they weren’t “solo” as I wasn’t the sole occupant.
Can anyone explain how having my wife with me (furthest thing from a pilot) is somehow detrimental to the requirement?

Because it says "solo."

It doesn't say "pax detrimental."

EDIT: I am not trying to be a jerk, but they define solo in the beginning of the FARs. It's unambiguous. It doesn't matter if a pax is detrimental or not, the reg says "solo."

 

[Old Pete]

Because it says "solo."

It doesn't say "pax detrimental."

EDIT: I am not trying to be a jerk, but they define solo in the beginning of the FARs. It's unambiguous. It doesn't matter if a pax is detrimental or not, the reg says "solo."

I'm good friends with a DPE who would casually ask about that xc and when an applicant mentioned that the wife or a friend accompanied him, he would say sorry, can't do the ride, and quite frankly I don't blame him, it's explicit-solo is solo.

 

[MidlifeFlyer]

A bit unrelated but I’ve got a lot of XC flights that would qualify for the Commercial requirements that I have to go back and redo because I always had a passenger with me so they weren’t “solo” as I wasn’t the sole occupant.
Can anyone explain how having my wife with me (furthest thing from a pilot) is somehow detrimental to the requirement?

There's no way to police whether a passenger was helpful or not. So they write a bright line where only being dishonest gets you around it.

 

[MidlifeFlyer]

I'm good friends with a DPE who would casually ask about that xc and when an applicant mentioned that the wife or a friend accompanied him, he would say sorry, can't do the ride, and quite frankly I don't blame him, it's explicit-solo is solo.

I knew a guy who was rejected. He said he had flights which were solo but he didn't log them as solo.

 

[Old Pete]

I knew a guy who was rejected. He said he had flights which were solo but he didn't log them as solo.

well, you can make corrections to your logbook if they were entered in error,(and I have done that) but this guy would be a bit sly "I see you stopped in SSI, there is a great BBQ place there" applicant "Yes, I had the pulled pork and the wife had the ribs" DPE "Did she enjoy the flight there?"