Joe
Well-Known Member
A discussion has recently come up at my flight school between myself my coworkers (and some of our students) regarding the 500 hours of cross-country time required to act as PIC under IFR for a Part 135 operation as per § 135.243(c):
Now, here's where my coworker and I disagree: He says that if you fly to an airport 10 NM away and spend an hour doing pattern work and end up logging 1.5 hours of flight time, that you can only log the time spent in transit between those airports as "point-to-point" (P2P) cross-country time. When adding up his P2P time, he devised average times to and from our nearby airports that we often visit (e.g., .2 for PVD-OQU-PVD, .4 for PVD-SFZ-PVD, etc.). Those coworkers who say he makes a valid point argue that once you land there, Point B becomes Point A and you're no longer landing at another airport. I argue that you don't stop operating the airplane during the landing rollout or even taxiing; and that the flight doesn't end until the end of the lesson upon engine shutdown... in other words, Point B remains Point B, and you return to Point A and the flight ends where you started, therefore making the entire flight P2P cross-country time... and I've spoken with an equal number of people agree with me there. If he adds it up his way (which he did), he's 70 hours short of the P2P cross-country required for 135 IFR PIC... if he does it my way, he's got more than enough... I know FlightLogg.in logs it that way for me, and I believe the other electronic logbooks do as well... in fact I don't even know that you can reduce the P2P cross-country time since they do it automatically.
Anyway, I'm curious as to what everyone's thoughts on this are, particularly those who fly or have flown Part 135 and have had to add up this time to get the job in the first place and the technical/legal/reg experts on here: Is the whole flight, maneuvers and pattern work loggable as P2P, or only the time spent travelling between the two airports? I'm convinced he's wrong and isn't comfortable logging it as cross-country because it goes against the 50 NM definition most people have always known, and that he's short-changing himself significantly.
Now, § 61.1(b)(4)(i) defines cross-country as any flight involving a landing at another airport:(c) Except as provided in paragraph (a) of this section, no certificate holder may use a person, nor may any person serve, as pilot in command of an aircraft under IFR unless that person—
(1) Holds at least a commercial pilot certificate with appropriate category and class ratings and, if required, an appropriate type rating for that aircraft; and
(2) Has had at least 1,200 hours of flight time as a pilot, including 500 hours of cross country flight time, 100 hours of night flight time, and 75 hours of actual or simulated instrument time at least 50 hours of which were in actual flight; and
(3) For an airplane, holds an instrument rating or an airline transport pilot certificate with an airplane category rating; or
(4) For a helicopter, holds a helicopter instrument rating, or an airline transport pilot certificate with a category and class rating for that aircraft, not limited to VFR.
Paragraphs (b)(4)(ii) through (b)(4)(vi) give the "more than 50 nautical mile" requirements for private, instrument and commercial training, and later regulations in Part 61 give even more specific cross-country requirements for those certificates or ratings. Meeting Part 135 minimums doesn't fall under those paragraphs, so therefore any flight involving a landing at another airport, regardless of distance (i.e., less than 50 nautical miles from the point of departure), can be logged as cross-country time to meet these minimums. Many people are surprised to learn this (including myself way back when I did), as well as to meet the cross-country requirement for the ATP certificate you have to fly at least 50 NM from the point of departure but don't have to land (but that's a different topic for a different thread).(4) Cross-country time means—
(i) Except as provided in paragraphs (b)(4)(ii) through (b)(4)(vi) of this section, 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.
Now, here's where my coworker and I disagree: He says that if you fly to an airport 10 NM away and spend an hour doing pattern work and end up logging 1.5 hours of flight time, that you can only log the time spent in transit between those airports as "point-to-point" (P2P) cross-country time. When adding up his P2P time, he devised average times to and from our nearby airports that we often visit (e.g., .2 for PVD-OQU-PVD, .4 for PVD-SFZ-PVD, etc.). Those coworkers who say he makes a valid point argue that once you land there, Point B becomes Point A and you're no longer landing at another airport. I argue that you don't stop operating the airplane during the landing rollout or even taxiing; and that the flight doesn't end until the end of the lesson upon engine shutdown... in other words, Point B remains Point B, and you return to Point A and the flight ends where you started, therefore making the entire flight P2P cross-country time... and I've spoken with an equal number of people agree with me there. If he adds it up his way (which he did), he's 70 hours short of the P2P cross-country required for 135 IFR PIC... if he does it my way, he's got more than enough... I know FlightLogg.in logs it that way for me, and I believe the other electronic logbooks do as well... in fact I don't even know that you can reduce the P2P cross-country time since they do it automatically.
Anyway, I'm curious as to what everyone's thoughts on this are, particularly those who fly or have flown Part 135 and have had to add up this time to get the job in the first place and the technical/legal/reg experts on here: Is the whole flight, maneuvers and pattern work loggable as P2P, or only the time spent travelling between the two airports? I'm convinced he's wrong and isn't comfortable logging it as cross-country because it goes against the 50 NM definition most people have always known, and that he's short-changing himself significantly.