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8 Answers

Commercial Pilot Requirements cross country

Asked by: 4889 views , , , ,
Commercial Pilot, FAA Regulations, General Aviation, Instrument Rating, Private Pilot, Student Pilot

I noticed some confusion in regards to the requirements to apply for a commercial pilot license and the X-country times you need to have before you can apply. Article 61.129 of the FAR/AIM summarizes these requirements and is not referring to any previous obtained flight time for other ratings. For example; to get your instrument rating you need a X-country flight of 250 nautical miles along airways or by directed routing from an air traffic control facility. I did a X-country of 270 Nm away (straight line) from my POO and made three different (instrument) approaches at three different airports. I believe I can use that same flight for my commercial time since this is in compliance with the commercial (daytime) X-country requirements. My instructor claims that you cannot 'double-dip' and count this time for the commercial rating and that I have to do this X-country again before the DPE will accept this. Neveryjeless, the FAR does not mentioning anything about the use of previous flights and I therefor believe this X-country can be used as they talk about flight time in general regardless when and how be flown. 

The same discussion I have about the night X-country; I have done numerous night X-countries (solo PIC) of more than 2 hours that consist of a total flight straight-line distance of more than 100 Nm from the POO. But none without an instructor. My instructor claims that also this particular night X-country has to be flown again before it counts for the commercial rating, he even states that it has to be with a certified flight instructor before the DPE will accept this on the checkride. The FAR does not state anything about the need of an instructor being present during that flight so I believe my solo night X-country flights of >100 Nm also count for the commercial rating. 

Are there any commercial pilots or DPE's out there who can clarify the above? 

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8 Answers



  1. Mark Kolber on Jul 02, 2019

    If I understand your question, your instructor is correct.

    In part, you need to do a better job reading the requirements. The 100 NM day and night cross countries are under the commercial “training” requirements of 61.129(a)(3). “Training” is a keyword which means “while receiving training from a CFI.” Solo doesn’t cut it.

    There’s another key phrase which deals with the “double dip.” Those flights are not only “training,” but they are, to quote 61.129(a)(3), part of the requirement for “20 hours of training on the areas of operation listed in §61.127(b)(1) of this part.” That is where the “no double-dip” rule comes from. The “areas of operation” language is used by the FAA to indicate that the flight must include the tasks specified for the rating being sought, both as to kind and quality. It is a position long held by the FAA and supported by a number of Chief Counsel interpretation letters.

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  2. Mark Kolber on Jul 02, 2019

    Sorry, only part of that was supposed to be bold.

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  3. Dodulation on Jul 02, 2019

    Hi Mark, I do appreciate your respond and explanation a lot but I\’m not convinced if your statement is correct. I admit that English is my second language but if I read 61.129(a)(3) correctly than I notice the word \’training\’ only specifically being mentioned in the parts (i) and (ii).

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

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

    No referral to (dual) training is mentioned there. And what does the FAA to be considered a \’training\’? The mandatory 50 Nm SOLO X-country for the PPL is being considered training as well but it is still being flown solo as part of the training. I noticed that the parts required an instructor is specifically mentioned and includes the words \’with an authorized instructor\’ (see part (v))

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  4. Mark Kolber on Jul 03, 2019

    I will try to parse it correctly for you. You have to understand how outlines work. I’m using hyphens to show indentation, but the point is that (i) thru (v) are a list of things covered by (a)

    61.129(a)(3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—

    —–(i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

    —–(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;

    —–(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; and

    —–(v) Three hours in a single-engine airplane with an authorized instructor in preparation for the practical test within the preceding 2 calendar months from the month of the test..

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  5. Warren Webb Jr on Jul 04, 2019

    Another way to look at it is 3 is dual, 4 is solo. Mark, did you mean (i) thru (v) is under (a) or (3)?

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  6. Mark Kolber on Jul 06, 2019

    Warren, both

    Section 61,129 – requirements for the commercial certificate
    >Paragraph (a) – single engine rating requirements
    >>Subparagraph (3) – 20 hours of dual
    >>>Sub-subparagraphs (i)-(iv) – the list of dual tasks

    So, (I)-(iv) is a list of tasks to be accomplished during the 20 hours of dual required for a single-engine rating for the commercial certificate.

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  7. Warren Webb Jr on Jul 06, 2019

    Mark – thanks of course that’s correct. I think I saw your Jul 03 reference to (a), skipped over and missed the reference to the full paragraph 61.129(a)(3) in the next line.

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  8. sr22captain on Jan 27, 2021

    I know this is a rather old thread but it seems that Mark’s interpretation means that additional 10 hours of instrument training is required as well even if the applicant is an instrument rated and current pilot. That surprises me. Has the FAA issued any clarification on this?

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