Dilemma in Logging Cross-Country Hours

cadbury

cadbury

Well-Known Member
Dear Pilots/CFI/Examiner,

I will be pursuing my ATP AMEL in Spring 2026 and I have already fulfilled almost all of the aeronautical experience requirements.

However, I have found myself in a difficult situation when it comes to logging the 500 hours of cross-country experience required for the ATP (fixed-wing).

Last year, I worked as a flight instructor at a flight school in Indonesia. During that time, I accumulated many hours of cross-country under VFR with GPS navigation. All routes were fixed and had to be approved by the Indonesian aviation authority.

According to Indonesia DGCA regulations, a cross-country is defined differently from the FAA: it does not have to meet the “straight-line distance of more than 50 NM” requirement, but instead must be more than 50 NM with a landing or touch-and-go.

Here is where my confusion begins:

Many of my logged flights exceed 50 NM in overall routing distance, but if measured in a straight line, they are less than 50 NM.
Because of Indonesia DGCA restrictions, cross-country flights cannot cross the sea, must follow coastal routes, and must avoid restricted zones and hilly terrain, which often forced us into curved routes.

Case Study (1):
I know of Indonesian pilots who came to the US for the FAA ATP. Despite facing the same issue with their cross-country hours, they still passed their ATP checkrides and were issued FAA ATP certificates.

Case Study (2):
Similarly, I have met Republic of Singapore Air Force pilots who came to the US for FAA ATP. Their military flying often did not involve traditional “cross-country” flying with landings, yet they were still accepted by FAA DPEs.

This leaves me very uncertain. For my own situation:

Should I disclose my background and the nature of my logged cross-country hours to the FAA DPE before my ATP AMEL checkride?
Or should I remain silent, as others seem to have done, and simply proceed with my logbook as it is?

I sincerely ask for guidance from experienced professional pilots who may have seen similar situations. What would be the correct and prudent course of action here?

*Note:
§ 61.1 (b)(vi)(B) That is at least a straight-line distance of more than 50 nautical miles from the original point of departure;
 
Does your flight time meet the aeronautical experience requirements as defined in the regulation?

1) YES - Add the total to the correct column and use it towards the required experience.

2) NO - Do NOT add the total to any column unless you're comfortable lying on your application for a certificate.

Will anything happen if you label the time as cross country while not meeting the FAR definition? Probably not. I doubt the DPE/APD doing the check ride would be that obsessive to look at each leg and verify. That's probably how the other people you know got away with it.

It's on YOU to attest that the time entered and applied toward a rating meets the qualifications thereof. Would you get denied the certificate by the examiner, probably not. But should you ever be involved in any kind of incident that gets investigate by the FAA or NTSB then they might go back and look over your logbook with a fine toothed comb. And in doing so, if they find you falsified times for a rating you could be looking at anything from revocation of your certificates to possible civil penalties (aka $) or even jail time.

If you can draw a 50nm circle from your point of origin and denote a designated spot (waypoint, DME, lat/long) that's outside the circle then your time qualifies per the definition. Just going 50nm of ground track does not count as you are not necessarily 50nm away from your point of origin. It sounds like you are trying to use flights that have 50nm of ground track but do not go more than 50nm from the origin. If that's the case, then no, your time does not meet the requirements and cannot be used to satisfy the aeronautical experience requirements.
 
Karnage said:
If you can draw a 50nm circle from your point of origin and denote a designated spot (waypoint, DME, lat/long) that's outside the circle then your time qualifies per the definition. Just going 50nm of ground track does not count as you are not necessarily 50nm away from your point of origin. It sounds like you are trying to use flights that have 50nm of ground track but do not go more than 50nm from the origin. If that's the case, then no, your time does not meet the requirements and cannot be used to satisfy the aeronautical experience requirements.
Click to expand...

It seems there may have been a misunderstanding. I am not attempting to log flights that only have 50 NM of ground track without actually exceeding 50 NM from the point of origin. That is precisely why I am seeking clarification from experienced professionals here.

The issue is that in Indonesia, all cross-country routes are fixed, and each flight school must obtain approval from the aviation authority for their specific cross-country routes. As a result, I do not have the freedom to choose where I fly—I am required to follow the Indonesian aviation regulations.

My question is whether this situation might be acceptable to the FAA, since the flights are conducted under foreign aviation regulations. Even if I exclude a significant portion of hours that do not meet the FAA’s strict cross-country definition, I still have more than 500 hours of cross-country time, and my total flight time remains unchanged.

It is also worth noting that in several other countries—such as the Maldives and Hong Kong—pilots, trainees, and cadets often cannot perform cross-country flights exceeding 50 NM in a straight line. Yet their aviation authorities approve their training and issue ICAO-compliant licenses. These pilots are operating safely, and their aircraft are certainly not “falling out of the sky.”

I appreciate your time and guidance on this matter.

*Indonesia (click here for location in Google Map )
 
cadbury said:
Case Study (1):
I know of Indonesian pilots who came to the US for the FAA ATP. Despite facing the same issue with their cross-country hours, they still passed their ATP checkrides and were issued FAA ATP certificates.
Click to expand...
do you know what they logged and are you assuming that they did it in compliance with the FARs? not every examiner will sit there and pull your logbook and measure your cross countries, but if it was to be audited at some point you’d better be logged correctly and legally. Are you familiar with the different type of cross country that is able to be logged for the ATP?
 
bp said:
Are you familiar with the different type of cross country that is able to be logged for the ATP?
Click to expand...
I am only familiar with ...

"Cross-country time is defined in§ 61.1 (b )(3)(ii) as time acquired during a flight that is conducted in an appropriate aircraft; "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 that involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids,or other navigation systems to navigate to the landing point."


Can you please tell me how many different type of cross-country?
 
cadbury said:
The issue is that in Indonesia, all cross-country routes are fixed, and each flight school must obtain approval from the aviation authority for their specific cross-country routes. As a result, I do not have the freedom to choose where I fly—I am required to follow the Indonesian aviation regulations.

My question is whether this situation might be acceptable to the FAA, since the flights are conducted under foreign aviation regulations. Even if I exclude a significant portion of hours that do not meet the FAA’s strict cross-country definition, I still have more than 500 hours of cross-country time, and my total flight time remains unchanged.
Click to expand...

Does your time meet the requirement? It is that simple. Forget whatever other requirements Indonesia has, does it meet the FAA definition? Forced routings and geographical limitations are not addressed and irrelevant to the FAA definition. Did you go more than 50nm from your point of origin and use some means of navigation to get there? If you did, then the time applies towards the aeronautical experience requirements of § 61.159, if not, than you cannot use it to meet the requirements. Doesn't mean it cannot be logged, it just means you cannot use it to calculate the total time needed to show you have qualified for the certificate if asked to do so.

I used to keep three columns of cross country time in my logbook that corresponded to the three types of cross country flying I did. Definitionally parts (ii) and (vi) both apply when adding hours for the requirements for aeronautical experience on an ATP certificate, as landing is irrelevant to the times in (vi). Some flights would meet only (ii) or (vi) but any flight that meets the definition of (ii) also meets the definition for (ii) and (vi).

§ 61.1 Applicability and definitions.

Cross-country time means—

(i) Except as provided in paragraphs (ii) through (vii) of this definition, time acquired during flight—
(A) Conducted by a person who holds a pilot certificate;
(B) Conducted in an aircraft;
(C) That includes a landing at a point other than the point of departure; and
(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

(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.

(vi) For the purpose of meeting the aeronautical experience requirements for an airline transport pilot certificate (except with a rotorcraft category rating), time acquired during a flight—
(A) Conducted in an appropriate aircraft;
(B) That is 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.
Click to expand...
 
cadbury said:
It seems there may have been a misunderstanding. I am not attempting to log flights that only have 50 NM of ground track without actually exceeding 50 NM from the point of origin. That is precisely why I am seeking clarification from experienced professionals here.

The issue is that in Indonesia, all cross-country routes are fixed, and each flight school must obtain approval from the aviation authority for their specific cross-country routes. As a result, I do not have the freedom to choose where I fly—I am required to follow the Indonesian aviation regulations.

My question is whether this situation might be acceptable to the FAA, since the flights are conducted under foreign aviation regulations. Even if I exclude a significant portion of hours that do not meet the FAA’s strict cross-country definition, I still have more than 500 hours of cross-country time, and my total flight time remains unchanged.

It is also worth noting that in several other countries—such as the Maldives and Hong Kong—pilots, trainees, and cadets often cannot perform cross-country flights exceeding 50 NM in a straight line. Yet their aviation authorities approve their training and issue ICAO-compliant licenses. These pilots are operating safely, and their aircraft are certainly not “falling out of the sky.”

I appreciate your time and guidance on this matter.

*Indonesia (click here for location in Google Map )
Click to expand...

1. Unless there is some special regulation or treaty that says something different for a specific country, to meet an FAA requirement for an FAA certificate or rating, you have to meet the FAA's requirement, not one from some other country

2. Are we talking apples and apples. In your examples, have you reviewed their logbooks to see what they logged and where? Better yet, did you check if they used a foreign ATP to US ATP program?

3. Can you give us an example of a flight? I've seen people who don't understand the 50 NM requirement. Fore example, thinking that a leg has to be 50 nm.
 
Karnage said:
Does your time meet the requirement? It is that simple. Forget whatever other requirements Indonesia has, does it meet the FAA definition? Forced routings and geographical limitations are not addressed and irrelevant to the FAA definition. Did you go more than 50nm from your point of origin and use some means of navigation to get there? If you did, then the time applies towards the aeronautical experience requirements of § 61.159, if not, than you cannot use it to meet the requirements. Doesn't mean it cannot be logged, it just means you cannot use it to calculate the total time needed to show you have qualified for the certificate if asked to do so.
Click to expand...

MidlifeFlyer said:
1. Unless there is some special regulation or treaty that says something different for a specific country, to meet an FAA requirement for an FAA certificate or rating, you have to meet the FAA's requirement, not one from some other country
Click to expand...
Underlined sentences are very helpful! 👍
 
cadbury said:
Underlined sentences are very helpful! 👍
Click to expand...
I'm not even sure that's the issue. I went to SkyVector and can't see any problem with meeting the >50 NM requirement in Indonesia. I don't know where you are, but this is Sumba, one of the smaller islands in the chain. Two airports on the whole island. 64 NM apart. That's why I asked for an example. If the allowable destinations are fixed and only 16 NM away from each other, I can see a problem. I can't see how flying a circuitous route to get there changes it to 51.

1759252645605.png
 
MidlifeFlyer said:
I'm not even sure that's the issue. I went to SkyVector and can't see any problem with meeting the >50 NM requirement in Indonesia.
Click to expand...

Best I can tell is that the destinations are >50nm but that unlike the US where the pilot is responsible for the routing the routes themselves are proscribed by Indonesian regulation. Whether that means only between AAA and BBB airports or if it lists the exact routing with waypoints along the way, I cannot tell as the posts have not been clear.

It would be more helpful if @cadbury would provide the Indonesian regulatory definition of a cross country so that it can be compared to the FAR definition.
 
@Karnage @MidlifeFlyer

Thank you for spending time looking into it.

1. I have mentioned "Many of my logged flights exceed 50 NM in overall routing distance, but if measured in a straight line, they are less than 50 NM. Because of Indonesia DGCA restrictions, cross-country flights cannot cross the sea, must follow coastal routes, and must avoid restricted zones and hilly terrain, which often forced us into curved routes."

2. The flight routes (flying schools and clubs) for cross country are pretty much fixed. And all flight training syllabus (including cross-country routes) must be approved by authority. How I wish I can choose to fly anywhere.

Indonesia flight training is little "weird". Eg. for Commercial Pilot License requirement, no night cross country. Their Commercial Pilot License testing standard is so much simpler than US FAA or Australia CASA or Singapore CAAS or China CAAC standard.
 
A little late to this discussion, but out of curiosity: Are the aircraft you were flying N registered, or PK registration?
 
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