Definition of X-Country PIC for ASEL Commercial Add-On

2 Answers

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   Russ Roslewski on Dec 27, 2022

   I’ve been around a long time on this and other forums, and I will admit this is the first time I’ve seen this question come up!

   I searched the FAA Chief Counsel Interpretations and did not come up with anything answering your question either. So what I am providing is my opinion only.

   First, it’s my OPINION that since 40 of the required 50 hours of XC can be completed in a non-airplane, then the XC rule that applies to them should logically be the one that applies to the aircraft category they were completed in. So, if you did them in a helicopter, follow helicopter rules. If you did them in an airship or a weight-shift trike, follow those rules. Etc.

   HOWEVER, I don’t think that’s what the rules say. I’m trying to read very literally here, so here goes, one step at a time:

   61.63b says that for an additional category rating (which is what you will be doing once you get your Commercial Helicopter rating), you must have the applicable aeronautical experience.

   61.129a says that for a Commercial ASEL rating, you must have “50 hours in XC flight of which at least 10 must be in airplanes”.

   61.1, Definitions, Cross Country (ii) says “for the purpose of meeting the aeronautical experience requirements (EXCEPT for a rotorcraft category rating) [meaning this paragraph applies to airplanes, which is your intent]…for a commercial pilot certificate…time acquired during a flight…conducted in an appropriate aircraft…50 nautical miles… .

   Note the definition does not differentiate between the different categories of aircraft. It strictly says that if the time is being used for an airplane category rating, the XC definition to be used is 50 nm.

   So I think that’s your answer right there. Try to maximize the opportunities to get >50nm XC flights in the helicopter.

   The best person to contact is really going to be the DPE who does your Commercial-Airplane checkride. Right or wrong, they are really the last stop in most cases. If they think the helicopter 25-nm XC’s are countable (as I stated above I think they should be), then that’s pretty much all you need. I don’t think IACRA will flag anything because it doesn’t ask for distance, just “XC” time”. I do suspect that if the DPE hasn’t faced this before, he or she will ask the FSDO, and then it becomes the FSDO’s call.

   Good luck, and I’d be interested in hearing how it goes.

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   Bryan on Dec 27, 2022

   Hi Chris:

   Your answer lies in the definition for cross country in 61.1. The part that allows you to count 25 NM trips as XC is the fifth section under the definition of XC and it reads:

   (v) For the purpose of meeting the aeronautical experience requirements for any pilot certificate WITH A ROTORCRAFT CATEGORY RATING or an instrument-helicopter rating, or for the purpose of exercising recreational pilot privileges, in a rotorcraft, under § 61.101(c), time acquired during a flight –

   (A) Conducted in an appropriate aircraft;

   (B) That includes a point of landing that was at least a straight-line distance of more than 25 nautical miles from the original point of departure; and

   (C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

   This means that you can only count cross-country time under this definition “for the purpose of meeting aeronautical experience requirements for any pilot certificate with a rotorcraft category rating..”

   To find out what can count for an ASEL commercial certificate, scroll up a bit and you will find it in the second section of that definition:

   (ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under § 61.101 (c), time acquired during a flight –

   (A) Conducted in an appropriate aircraft;

   (B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and

   (C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

   Thus, when 61.129 says cross-country, it means the definition from (ii) under cross-country in 61.1, not (v). If you had flights that you counted toward your XC experience to get your rotorcraft commercial under 61.129(c)(2)(ii) that also happened to be more than a straight line distance of 50 NM you can count them under 61.129(a)(2)(ii) as part of the 40 hours not in an airplane. Additionally, because the requirements for your rotorcraft commercial include two cross-country flights with the 50 NM requirement under 61.129(c)(3)(ii) and (iii), that cross-country time can also be counted under the non-airplane hours required by 61.129(a)(2)(ii).

   But the bottom line is that (ii) under the definition of cross-country in 61.1 is what says that ALL cross-country time under 61.129(a) must be 50 NM straight line distance.

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