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7 Answers

Hypothetical student XC loophole?

Asked by: 1768 views FAA Regulations, Flight Instructor, Student Pilot

Hypothetical.

If a student pilot has the following endorsements (plus other applicable ones):

I certify that Joe Student has received the required training in both directions between KGRI and KJYR, including takeoffs and landings at the airports to be used, and I have determined that he/she is proficient of § 61.93(b)(2) to conduct repeated solo cross-country flights over that route, subject to the following conditions: Less than 5kt X-wind for takeoff and landings.

and

I certify that Joe Student has received the required training in both directions between KGRI and KEAR, including takeoffs and landings at the airports to be used, and I have determined that he/she is proficient of § 61.93(b)(2) to conduct repeated solo cross-country flights over that route, subject to the following conditions: Less than 5kt X-wind for takeoff and landings.

 

KGRI to KJYR is 31nm.

KGRI to KEAR is 35nm.

KJYR to KEAR is 64nm.

 

KGRI is the home airport.

 

Assuming the wind is calm all around that day, can the solo student takeoff at KGRI, fly to KJYR, land, takeoff, fly back along the route to KGRI but not land at KGRI, then continue flying to KEAR, land, then takeoff to land back at KGRI? If so, can the student log that as XC time since TOL were 64nm straight-line distance apart? They stayed on the endorsed routes.

Just curious... seemed like an interesting loophole for a student to log solo XC time if so...

Edit: More clarification of how this day would go:

  • Student solo takes off at KGRI.
  • They fly directly to KJYR and do a full stop landing, taxi back, and takeoff to head back towards KGRI.
  • When they are flying over KGRI, they turn towards KEAR.
  • At KEAR they do a full stop landing, taxi back, and takeoff to head back towards KGRI.
  • They make a full-stop landing and park back at KGRI.

 

The questions are... 

  • Is this legal with the endorsements given (the two repeat XC endorsements above, no explicit one-time endorsement for a KGRI KJRY KEAR KGRI XC)?
  • Can the student log this as solo XC time (for the purpose of meeting experience requirements, 50nm between TOL)?

 

(Edited a few points for clarity)
(Edit2 - Used real airports for example, as suggested, and added more points/detail for clarity.)

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7 Answers



  1. Mark Kolber on Feb 17, 2020

    I am not sure what you are asking. It would be easier if you used real airports so we can see it in a map. But offhand it sounds like you there is a cross country for YYY ZZZ XXX after the repositioning flight from XXX to YYY, which doesn’t count as part of the xc.

    Your comment about “not landing” at XXX on the YYY ZZZ leg and the comment about 59 TOL leads me to think you are misreading the reg since the answer would be the same whether or not there was a landing at XXX on that portion of the flight.

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  2. stuwk on Feb 17, 2020

    I updated the question with example airports and additional details.

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  3. Kris Kortokrax on Feb 17, 2020

    Take a look at the Van Zanen interpretation.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Van%20Zanen%20-%20(2009)%20Legal%20Interpretation.pdf

    While it discusses the situation you propose and seems to allow it, it would not be allowed for a student. A student, with the two endorsements you cite, would not be able to redefine his original point of departure. He is allowed to make the flight between GRI & JYR and the flight between GRI and EAR. Neither JYR nor EAR is more than 50 NM from the original point of departure (GRI), so no portion of the flight you outline could be considered XC.

    If you were a private pilot (and not in need of an endorsement), you could declare the trip to JYR as a repositioning leg and then log the time from JYR to EAR to GRI as XC.

    91.93(b)(2) uses the language “that is within 50 NM of the airport from which the flight oriigntated”. If you, as a student, were to use JYR as the original point of departure, the flight would now be over 50 NM and would require a different endorsement.

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  4. Mark Kolber on Feb 18, 2020

    Kris, you are right about those endorsements. Just adds to my thought about misunderstanding the rules (a necessary requirement for finding loopholes 😉 ). OTOH, he did say “other applicable ones” about endorsements 😀

    Looks like my guess was accurate, so my answer is the same (and the same as yours). Assuming properly endorsed, the initial KGRI KJYR leg is a repositioning flight. The “original point of departure” is KJYR. The “countable” student cross country is KJYR KEAR KGRI. It doesn’t matter if there is a KGRI landing or not in the KJYR KEAR portion,

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  5. Best Answer


    Kris Kortokrax on Feb 18, 2020

    Just to clarify for Stuwk. As endorsed, he could not perform the flight outlined and could not count any of it toward the cross country requirements for a Private pilot certificate.

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  6. Mark Kolber on Feb 18, 2020

    Agreed, neither of those listed is an endorsement for a qualifying solo cross country student solo flight.

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  7. Mark Kolber on Feb 20, 2020

    I’m still trying to figure out what the supposed loophole is.

    Was it about doing a cross country without the proper endorsements? Was it about whether the route qualifies assuming the proper endorsements were given? Both? Something else?

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