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Helicopter commercial add on cross country requirements

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Commercial Pilot, FAA Regulations, Flight Instructor, Helicopter

I have my fixed wing multi engine ATP and private helicopter and am training for instrument and commercial helicopter add on ratings. My school wants to integrate the commercial cross country requirements into the instrument training so that by the time I finish the instrument training I will be ready to take the commercial check ride. So far I see there are three different cross countries required for the commercial add on. Day 2 hour cross country over 50nm, night 2 hour cross country over 50nm, and 3 point /50nm cross country.

My questions are:
1. I already fulfilled the 2 hour day/ 3 point cross country requirement when I did the 100nm 3 point solo cross country for the private add on, do I have to do it again specifically for commercial training?

2. Can I combine the 2 hour day cross country with the 3 point cross country?

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2 Answers



  1. HelicopterTrainingVideos.com on Mar 06, 2021

    Hi Lnaa,

    Answer to question 1:

    Yes you do need to do it again.

    My understanding is that you can not use the long solo XC as you were performing at a student helicopter pilot level in your planning and execution of the flight. My reference for that is the FAA’s Letter of Interpretation (LOI) [Murphy – (2011)] and the other LOI it references [Theriault – (2010)]

    The Murphy LOI essentially says that the FAA do not permit a pilot to use experience acquired while training for a private pilot certificate to satisfy commercial pilot requirements “because a student pilot who is training for a private pilot certificate is not expected to perform at commercial-pilot-level standards…”

    Here are the direct links to those two FAA Letters of Interpretation

    Murphy – (2011) https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Murphy%20-%20(2011)%20Legal%20Interpretation.pdf

    Theriault – (2010) https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Theriault%20-%20(2010)%20Legal%20Interpretation.pdf

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  2. HelicopterTrainingVideos.com on Mar 06, 2021

    Answer for question 2:

    My gut feeling in no, because for an instrument rating XC you would be under the hood, flying solely by instruments, using navigation aids, on an IFR flight plan (if able), with terrain and traffic separation and altitudes assigned by ATC, flying instrument approaches to the airports. But for a commercial XC, you would be VFR, using pilotage as well as navigation aids, not under positive ATC control (although you may be getting flight following), eyes outside for traffic, picking your own VFR altitudes, making your won way to the airport, avoid the flow of FW traffic, probably landing direct to the ramp, etc. It just seems a very different flight using different skills, IMO.

    I couldn’t find a Letter of Interpretation to say either way, but maybe someone else knows of one.

    On the plus side, an extra 2 hr XC experience can’t be bad for you…

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