Commercial dual XC requirements

jrh

jrh

Well-Known Member
Ok, I know I should know this, but be patient with me...I haven't trained a commercial applicant in three or four years.

May a pilot count a dual cross country they did during their instrument rating training towards the "Two hours day VFR" or "Two hours night VFR" dual cross countries for their commercial certificate training?

I have a customer who did a 2+ hour cross country, with an instructor, in day VFR counditions, while wearing a hood, for the purpose of training for his instrument rating several years ago.

Now we're wondering if he needs to complete another dual cross country for the purpose of his commercial training.

My gut instinct is to have him do another dual cross country specifically over the areas of operations listed for commercial pilot training (61.127(b)(1)), but I don't want to be overly conservative and waste his time/money either.

Sorry if this has been discussed before. I searched the archives and kept coming up with threads that didn't address this specific situation.
 
I've seen the day of the checkride come more than once when the examiner said that the applicant didn't meet the requirements since on one of their XC flights they logged hood or actual.

Day or night VFR with ZERO IFR of any type enroute is the safest bet.
 
esa17 said:
I've seen the day of the checkride come more than once when the examiner said that the applicant didn't meet the requirements since on one of their XC flights they logged hood or actual.

Day or night VFR with ZERO IFR of any type enroute is the safest bet.
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That's my thought as well. But is there any official FAA letter of interpretation or anything to back this idea up?
 
jrh said:
May a pilot count a dual cross country they did during their instrument rating training towards the "Two hours day VFR" or "Two hours night VFR" dual cross countries for their commercial certificate training?
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The old FAQs said "no" and I think this is the only reasonable answer. I see no way that a trip in simulated instrument conditions could be interpreted to meet the requirements of a day or night VFR trip. In fact, the whole purpose of the hood is to ensure that it doesn't. ;)
 
Maybe do the xc in your 140 to ramp up the challenge factor for him? Pilotage & ded rec only, no VOR allowed, find a grass field somewhere in the middle of nowhere.
 
Uhh, hate to bust your bubble here, but you might want to check the version of the FAR/AIM your running off of. The most recent publication of 61.129 changed the wording of the two dual X/C's.

61.129(a)3:
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure.

So, should be ok, regardless of the VFR/IFR argument, since they dropped the VFR part of the regulation
 
KSCessnaDriver said:
Uhh, hate to bust your bubble here, but you might want to check the version of the FAR/AIM your running off of. The most recent publication of 61.129 changed the wording of the two dual X/C's.

61.129(a)3:
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure.

So, should be ok, regardless of the VFR/IFR argument, since they dropped the VFR part of the regulation
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:yeahthat:
 
KSCessnaDriver said:
Uhh, hate to bust your bubble here, but you might want to check the version of the FAR/AIM your running off of. The most recent publication of 61.129 changed the wording of the two dual X/C's.

61.129(a)3:
(iii) One 2-hour cross country flight in a single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure
(iv) One 2-hour cross country flight in a single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure.

So, should be ok, regardless of the VFR/IFR argument, since they dropped the VFR part of the regulation
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Yeah, I knew about the change, I just referred to those XCs as VFR trips because those were the rules I trained and taught under, so I'm used to using that terminology. Ugghh...I'm finally starting to sound like an old timer :(. I believe they dropped the VFR language to discourage scud running, improve dispatch safety, and because being proficient at IFR operations is a legitimate part of being a commercial pilot.

I'm not so concerned about the fact that he was under the hood as much as that it's obvious he was training for the instrument rating, not the commercial certificate. And the reg specifically says the 20 hours of training time, including the day/night dual cross countries, should be over the areas of operation listed in 61.127(b)(1), commercial training requirements.

I'm not sure that an instrument training flight could be considered over the areas of operation in 61.127(b)(1).
 
jrh said:
I'm not sure that an instrument training flight could be considered over the areas of operation in 61.127(b)(1).
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That's a good thing to be not sure of. Flight Standards has been fairly consistent in opposing the cross-application of training from one certificate or rating to another. The reg is too new for there to have been any interpretive activity. Even though the commercial cross country can now be under IFR, given the history I'd take the conservative approach and treat the commercial duals as independent flights.
 
jrh said:
I'm not so concerned about the fact that he was under the hood as much as that it's obvious he was training for the instrument rating, not the commercial certificate. And the reg specifically says the 20 hours of training time, including the day/night dual cross countries, should be over the areas of operation listed in 61.127(b)(1), commercial training requirements.
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Fair enough. I'm not sure it would ever really be an issue. Would a DPE dig that deep into the issue, to make sure they actually had the training required in 61.127(b)(1)? I know on my commercial checkride, the only thing the DPE looked at was the total time on the last page of the logbook, and compared to the 8710 I had filled out.
 
KSCessnaDriver said:
Fair enough. I'm not sure it would ever really be an issue. Would a DPE dig that deep into the issue, to make sure they actually had the training required in 61.127(b)(1)? I know on my commercial checkride, the only thing the DPE looked at was the total time on the last page of the logbook, and compared to the 8710 I had filled out.
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Well, the DPE we use the most has a tendency to thumb through the applicants' logbooks and verify things fairly closely.

Plus, this particular customer has an interesting background to say the least. He has 1000+ total time, only 120 XC, and only *8* hours at night.

How did he get his hundreds of hours of local flying? By working as a jump pilot flying skydivers. :banghead: Not at the dropzone I fly or jump at. The "other" dropzone that has a reputation for being shady by pretty much any metric. After they crashed a plane last summer the feds finally cracked down on them and the DZ is making their pilots get commercial certificates now.

Since this guy has clearly written "flew jumpers" in line after line for the comments section of his logbook, I have a feeling the DPE will take a close look at everything and have an interesting conversation over privileges and limitations during the oral. I want to make sure this customer is completely squared away when it comes time for his checkride.
 
jrh said:
Well, the DPE we use the most has a tendency to thumb through the applicants' logbooks and verify things fairly closely.

Plus, this particular customer has an interesting background to say the least. He has 1000+ total time, only 120 XC, and only *8* hours at night.
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Got it now. Yeah, I'd probably do the 2 cross countries just to cover myself, if I were in your shoes. Good luck with the whole thing.
 
bksslc said:
I think it is a new revision for 2010. My FAR/AIM for 2009 shows the day VFR language.
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My 2010 FAR/AIM still has the day & night VFR language as in previous years. However the regulations are current only as of July 27, 2009
 
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