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4 Answers

Commercial Pilot Cross-Country Double-Dip

Asked by: 3657 views ,
Commercial Pilot, FAA Regulations

I'm a CFII with a Commercial Student who wants to "double-dip" on the commercial cross-country requirements by doing 1 long cross-country that covers both 61.129(a)(4)(i) and the two dual-cross countries in 61.129(a)(3)(ii) & (iii).

 

Historically, the long cross-country in 61.129(a)(4)(i) was a solo cross-country, but that changed to allow an instructor to be onboard (I believe due to multi-engine flight schools being unable to obtain insurance to let students solo multi-engine aircraft). I've read elsewhere on the internet that you can't double-dip because 61.129(a)(3) says those requirements have to do with "instruction" whereas 61.129(a)(4)(i) potentially has an instructor onboard who isn't "instructing".

 

Which leads to a second question regarding 61.129(a)(4)(i), which is how is the student supposed to log that flight if an instructor is onboard? Do we say it's solo time? Or Dual-received?

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4 Answers



  1. Russ Roslewski on Aug 07, 2021

    You cannot double-dip these requirements.

    The 2 100nm 2-hr dual XC flights are clearly a training requirement, they are under the heading of “20 hours of training”. The 250-nm XC flight, however, is under the “10 hours solo or performing duties as PIC” heading. The “PDPIC” requirement is what I refer to as a “ballast CFI”. The CFI is there for insurance purposes and is not conducting any training, and the pilot is not receiving any training (and none is logged – see the legal interpretation below).

    But there is a way to combine some of them. You fly somewhere 250 nm away as a dual instructional flight. That knocks out the 100 nm 2-hour dual XC. Then you fly back as a PDPIC flight, doing a few additional landings, and since it’s more than 250 nm counts as the long solo XC. That’s more efficient than doing one 250-nm XC flight that turns into 500 nm because most people come back to the starting point for obvious reasons. Then you do the night dual XC some other time (you really could even work that into this same trip if you made a leg at night.

    As far as logging during the PDPIC time, the pilot does not log solo, because it isn’t. They can log PIC if they are rated for the aircraft. They do not log dual received. You log PIC as an authorized instructor, but not dual given. See below.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2014/Kuhn%20-%20(2014)%20Legal%20Interpretation.pdf

    However, there are a couple of caveats. One is that if the pilot does ANY of the 10 “solo” hours as PDPIC, they have to do them ALL as PDPIC. There is no mix and match. See below:

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2016/Grannis%20-%20(2016)%20Legal%20Interpretation.pdf

    The other caveat is a personal opinion. It appears from your wording here that the pilot has the choice to either do solo or PDPIC, that there isn’t an insurance requirement at play. If that’s the case, then I question why? It’s good for a pilot to get out on their own, away from the safety net of a CFI, and if they’re aren’t comfortable doing that, then they aren’t ready to be a Commercial Pilot. Again, my opinion.

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  2. AviatorTrevor88 on Aug 08, 2021

    Thanks for the response. It seems these letters of interpretation do not precisely address the question of “double-dipping” though.

    The student I’m working with has something like 1500 hours. He knows how to fly cross-country just fine, but he just cannot find an entry in his logbook that meets all of the criteria, primarily because it needs 3 points of landing. So, he’s dragging his feet to meet this requirement because he isn’t really learning anything from it, he’s just burning avgas to meet the requirement. But rules are rules.

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  3. Russ Roslewski on Aug 08, 2021

    Sure they do. 61.129a(3) requires 20 hours of “training” in the following areas, which includes the dual XC flights. However, the Kuhn letter, third paragraph, specifically says that when they’re doing the PDPIC time (so, the long solo XC) it is NOT instruction.

    Therefore, they cannot be double-dipped. One is required to be instruction, one specifically is not instruction.

    Unless you’re arguing that “training” and “instruction” are not synonymous in this context…

    The applicant has to meet the experience requirements. He could have met them at any time during the last 1500 hours but did not. So he has to meet them now. I recommend to all of the Private Pilots that I work with, that if they think they might ever want a Commercial certificate, that they pay attention to the requirements so they can knock them out when convenient. Sometimes it just takes an additional touch and go to make a long solo trip count for the XC. Or they’re up getting night current, why not hop over to the nearby towered field instead and meet that requirement?

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  4. Mark Kolber on Aug 13, 2021

    >>Thanks for the response. It seems these letters of interpretation do not precisely address the question of “double-dipping” though.

    Please explain your theory of how the same flight can be both dual and not dual at the same time. Maybe you’ve come up with something no one else has.

    Now, there is a way to do it sort of efficiently, You choose a location 300 NM away. You do the 61.129(a)(4)(i) substitute solo flight outbound. On the way back you do the daytime dual, stop for dinner and come the rest of the way back at night. Basically, all you’ve done is add 50 NM to the substitute solo log cross country.

    That’s not “double-dipping.” That’s three separate flights, each of which meets a specific requirement. To make things clear, log them separately with references to the appropriate FAR subsection.

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