250 nm IFR XC requirement

jrh

jrh

Well-Known Member
I've got a question about the IFR cross country requirement listed in 61.65(d)(iii).

Here's the deal: I flew with a student this morning on a trip between four airports. We took off from Airport 1, went to Airport 2, then Airport 3, then Airport 4, then returned to Airport 1.

The total distance of the trip was over 250 miles. The distance without the last leg, between Airport 4 and Airport 1, was less than 250 miles.

We shot a GPS approach into Airport 2, an ILS into Airport 3, a VOR into Airport 4, and a visual approach into our home base at Airport 1. We were under IFR at all times.

I reviewed 61.65(d)(iii) after the trip and I forgot that it says "an instrument approach at each airport."

So I'm wondering, does the visual approach count as an approach, as defined in Part 97? Can this trip count to fulfill this requirement for the instrument rating? Or am I misunderstanding the reg? Would the trip still count even if the visual approach does not count as an "instrument approach" for this requirement?

Stupid me...I need to look these things up before I jump in the plane...
 
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The total distance of the trip was over 250 miles. The distance without the last leg, between Airport 4 and Airport 1, was less than 250 miles.

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Was one of hte legs at least a 100NM straight line distance? I believe that is a req as well.

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I reviewed 61.65(d)(iii) after the trip and I forgot that it says "an instrument approach at each airport."

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Again I don't have the FARS in fron of me, but I believe if you have the 3 approaches, you should be o.k.

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Can this trip count to fulfill this requirement for the instrument rating? Or am I misunderstanding the reg? Would the trip still count even if the visual approach does not count as an "instrument approach" for this requirement?

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For the student's sake, I sure hop is still counts. That is a pretty expensive mistake if it doesn't.
 
I haven't read the FARs in a while but when i did mine- i shot ILS at the first airport, then a VOR approach to the next airport, followed by a LOC approach. We headed back to our home base VFR and that was it! It sounds to me you did the same thing except ours was just over 300 nm at the end of the trip where we did the last approach. The requirement is that two non-precs and one precesion approach and a total of 250 nm. Therefore, i don't think your flight will be counted for the 250nm. Anyways- this is just my opinion-anyone else?
 
Disregard the commnet about the 100nm leg. It appears that was only for helicopter reading (I think)
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I don't really feel like looking it up, but our TCO certified by the FAA allows for a Visual Approach to be done in lieu of a navaid approach.
 
I think the way it reads is "3 airports with an instrument approach at each airport." So, as long as you did 3 instrument approaches, I'd say you're good.
 
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I think the way it reads is "3 airports with an instrument approach at each airport." So, as long as you did 3 instrument approaches, I'd say you're good.

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...(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;
(B) An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems;


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After doing some research, I've found that all is well. The last leg of the trip with the visual approach doesn't even need to count.

The trip between Airports 1, 2, 3, and 4 (three legs) is about 235 miles via airways. However, the regs allow for counting the distance along "ATC directed routing." I believe this means that vectors setting us up for the approaches counts.

I went and plugged the route into AOPA's flight planning software, then rubberbanded in waypoints for my best, fairly conservative estimates for the exact route, including vectors to set up for the approaches and the approaches themselves (I think the approaches themselves count for the distance requirements...ATC saying "cleared ILS 32R approach" should constitute ATC directed routing).

According to the software, our exact route, including vectors and the approaches, came to 269 miles. Even if I'm a bit off in my estimates, that should still be over 250.

I'll definately be more careful in the future.
 
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After doing some research, I've found that all is well. The last leg of the trip with the visual approach doesn't even need to count.

The trip between Airports 1, 2, 3, and 4 (three legs) is about 235 miles via airways. However, the regs allow for counting the distance along "ATC directed routing." I believe this means that vectors setting us up for the approaches counts.

I went and plugged the route into AOPA's flight planning software, then rubberbanded in waypoints for my best, fairly conservative estimates for the exact route, including vectors to set up for the approaches and the approaches themselves (I think the approaches themselves count for the distance requirements...ATC saying "cleared ILS 32R approach" should constitute ATC directed routing).

According to the software, our exact route, including vectors and the approaches, came to 269 miles. Even if I'm a bit off in my estimates, that should still be over 250.

I'll definately be more careful in the future.

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You should probably discuss this with the examiner who will be giving the checkride. If you can convince him/her that it works, then go for it, but if they're not going to accept it, then you'll be SOL and it's much better to find out now than then.

It would be easy to argue either side. Yes, the vectors count, but you can't count on them for planning purposes. Therefore originally the flight wouldn't have counted.
 
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It would be easy to argue either side. Yes, the vectors count, but you can't count on them for planning purposes. Therefore originally the flight wouldn't have counted.

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I can see what you're saying, but I don't see how planning has anything to do with it. The requirement is based on what was actually flown, not what was planned.

A commercial student could plan a cross country flight to go alone across the state to visit friends, then in the air they decide to have fun and do a few touch and goes along the way, and end up flying at least 300 miles away from their home base. That trip counts for their long solo cross country. That requirement is considered complete. It doesn't matter what the intent or plan of the original trip was. The student might not have even been thinking about meeting any particular requirements, but they did, unintentionally, and it counts.

In my mind, that is sort of like what happened to us. We might have originally misplanned the trip, but we unintentionally met the requirement in a different way. The vectors and routing added enough length to the first three legs to make that portion of the trip count.

As far as the legitimacy of the route with vectors--I think it is clear we met both the intent and specific requirements of the reg. It's not like we took a trip to another airport fifty miles away and told the controller, "Hey, can you vector us in a huge zig-zag pattern so that we can get 250 miles out of this?" We flew a cross country trip, shot three different approaches, over a long distance, under IFR. That is the intent of the reg. I also think it is believable that over a trip of that length we would get vectored at least 15 miles.

If the examiner doesn't believe me? I don't know what to say...I logged the trip in the student's logbook as "Meets the requirements of 61.65(d)(iii)." If he can't believe my word, what can he believe? I mean, it's possible that I could have just forged the whole entry to begin with. Not to say that I would ever consider such a thing, but the fact is that he has to take it for what it says. The requirement was met.
 
I said it's easy to argue either side, not that I want to argue either side. Examiners can be a fikle bunch. You don't want to take my advice, fine, but don't whine if you find out at the last minute that it won't be accepted.

I've seen more than one student stumped by an examiner for something that he/she and his/her instructor thought qualified and the examiner disagreed. They basically had two options when that happened. Do it again, or get the FAA involved for an interpretation. Because of that I was always very anal about making sure every requirement was clearly met with no room for questions about it, and I audited the student's logbook before the checkride with enough time left to do any catchup flights that were missed.

Let's see, a 5 minute phone call now, or the chance of days of heartache down the road, I know which one I'd take.
 
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Here's the deal: I flew with a student this morning on a trip between four airports. We took off from Airport 1, went to Airport 2, then Airport 3, then Airport 4, then returned to Airport 1.

The total distance of the trip was over 250 miles. The distance without the last leg, between Airport 4 and Airport 1, was less than 250 miles.

We shot a GPS approach into Airport 2, an ILS into Airport 3, a VOR into Airport 4, and a visual approach into our home base at Airport 1. We were under IFR at all times.

[/ QUOTE ]I have a question. You don't mention it, but which airport(s) did you land at? Was one of them more than 50 NM from the airport where you started?

Ralgha's point about problems with the requirement is well-taken. Here's what the Part 61 FAQ has to say about it:

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NOTE: This request for interpretation regarding cross-country flight requirements for an instrument rating under 14 CFR § 61.65 of the Federal Aviation Regulations is answered by: Komal K. Jain, Office of Chief Counsel, AGC-240, Washington, DC 20591

QUESTION: Do the approaches required under § 61.65(d)(2)(iii)(C) need to be completed at three different airports?

ANSWER: No. Under § 61.65(d)(2)(iii), a pilot seeking an instrument-airplane rating must perform three different kinds of approaches with the use of navigation systems, but the approaches may be performed at one or more airports. In addition, in order to meet the aeronautical experience requirements under § 61.65(d)(2)(iii), the pilot also must (1) land at one or more airport(s), other than the airport of original departure, using an instrument approach; (2) return to the airport of original departure using an instrument approach; (3) travel a total distance of 250 nautical miles or greater along airways or ATC-directed routing; and (4) choose an airport for landing that is separated by a minimum straight line distance of more than 50 nautical miles from the airport of original departure (see § 61.1(b)(3)(ii)(B)). Given the requirement that the pilot land at a minimum of one airport other than the airport he or she originated from, it is most efficient if a different approach is used for each landing so the requirements under § 61.65(d)(2)(iii)(C) partially are met.
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The weird part of the opinion is requirement (2), that the pilot must "return to the airport of original departure using an instrument approach." I can't figure out where the heck that one came from. There is not one cross country rule that says anything about any cross country having to return to the original point of departure in order to count toward anything. It's probably a mistake (maybe the attorney was in a rush to get home that day) but definitely opens the door to saying that your cross country just doesn't qualify.
 
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The weird part of the opinion is requirement (2), that the pilot must "return to the airport of original departure using an instrument approach." I can't figure out where the heck that one came from. There is not one cross country rule that says anything about any cross country having to return to the original point of departure in order to count toward anything. It's probably a mistake (maybe the attorney was in a rush to get home that day) but definitely opens the door to saying that your cross country just doesn't qualify.

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I guess the assumption is one of a round-robin flight when they made the rule, though I'm with you on the opinion. Are they saying an XC that doesn't terminate at the point of departure wasn't an XC?
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I said it's easy to argue either side, not that I want to argue either side. Examiners can be a fikle bunch. You don't want to take my advice, fine, but don't whine if you find out at the last minute that it won't be accepted.
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Let's see, a 5 minute phone call now, or the chance of days of heartache down the road, I know which one I'd take.

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Ok, my apologies. I re-read my post, and it did sound a bit argumentative. I didn't intend it like that. My point was just that I thought it was quite clear that the requirement was met. I couldn't see how even the most anal examiner would be able to justify not accepting it.

But you're right, a five minute phone call now is better than a snag during the checkride later.

I just got off the phone with our local examiner and everything is fine. I described our first three legs that totaled 235 miles via airways, and how I was quite certain we got more than 250 miles because of being vectored and cleared direct to some IAFs. At first, he said the trip has to be 250 miles point to point, between airports. Then, I asked him what the meaning of "ATC-directed routing" was if it was not referring to vectors. He thought for a second and said, "That probably does count then. I don't know. Did you endorse it in the student's logbook as meeting the requirements? Because if you did, what you said is what you did. There's no way to know. Just be a little more careful in the future."

Then I told him that we had continued on to our home base under IFR, but taken a visual approach, and the reg says we needed to fly instrument approaches at each airport. He said, "Oh, goodness, count it then. Count it! All you have to do is shoot three approaches, and you did that. It counts for sure." He almost sounded disgusted that I'd bothered him.

So it's all good. But as I said above, I'll certainly be more careful about these things in the future.
 
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He almost sounded disgusted that I'd bothered him.


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I'd have done the same thing in your shoes. He probably would have been more disgusted if you guys had the conversation the day of the checkride. Glad that he said it's all good.
 
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