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Cross Country 61.65(g)(1)

Asked by: 1139 views
Instrument Rating, Private Pilot, Student Pilot

My son's Part 61 flight school told him that he could work on his instrument cross-country requirements while he waits to get a check ride date for his PPL. (Getting a check ride date is a whole other issue that I don't want to discuss here.) I searched the FARS and found 61.65(g)(1), which allows students to credit 45 hours of cross-country time flying with an instructor to be credited toward the Instrument requirement. Combined with the 5 hours of solo (PIC) cross country required for the Private, it totals 50 hours. So I have a few questions about this: 1.) I'm assuming it won't count toward Commercial cross-country requirements since it's not PIC. Is this correct? 2.) I heard that combining the two types of training will require the student to do both check rides at the same time. Yikes! Is that true? Where is the regulation? 3.) Can a student pilot do more than 5 hours of solo (PIC) cross country and have it count toward that 50 for the instrument rating? What if he did 50 hours of solo PIC cross country as a student pilot? I'm assuming only 5 of it will count. Is that correct? Thanks for your help.

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1 Answers



  1. Jeff Baum on Sep 21, 2023

    Well, sort of, but you are asking about a few different situations. There is the “usual” path of completing a Private Pilot Certificate and then continuing to train for the Instrument Rating, followed by the Commercial. Some go Private, then Commercial, then Instrument. Then there is the combined Private Pilot & Instrument followed by the Commercial.

    The Combined Private Pilot & Instrument is a single checkride and rarely used (I’ve never been asked to administer a combined PVT/Inst test). ANY failed Task in either part of the combined Test will result in a failure for the entire checkride. The applicant would not be allowed to pass the Private section and fail an Instrument Task and receive the Private Certificate. It’s an All-or-Nothing checkride.

    Can your son continue his training towards an Instrument Rating while waiting for his Private checkride? Sure. He could continue training towards the Commercial as well.

    You have to look to the section of the regulation which applies to what you want to do. As an example 61.65(g) requires “up to 45 hours of cross-country flight time performing the duties of Pilot in Command with an authorized instructor” With an Instructor onboard, this time is not PIC, but “performing the duties”. Combining this with the minimum 5 hours Solo cross-country is to achieve the minimum of 50 hours cross-country (XC) time. More Solo XC would require less “performing the duties” time. So, Yes, more than 5 hours XC would still count. Note; this regulation applies only to the Combined Private & Instrument, not the stand-alone Instrument.

    Is the student “Required” to complete the combined Private & Instrument checkride if they have trained for both? No, if they meet the requirements listed in 61.65(d) and 61.109 (Private).
    If they do not meet 61.65(d) and are using 61.65(g) requirements and they train for the combined checkride, applied for the combined checkride, then Yes, they must complete the combined checkride.
    (I trained for both Commercial and Instrument at the same time. I took my Instrument checkride one one day, and my Commercial the next as separate checkrides)

    You asked for the “regulation”. The Instrument Airman Certification Standards (ACS) states;
    “A combined certificate and rating evaluation should be treated as one practical test, requiring only one application and resulting in only one temporary certificate, disapproval notice, or letter of discontinuance, as applicable. Failure of any Task will result in a failure of the entire test and application. Therefore, even if the deficient maneuver was instrument related and the performance of all visual flight rules (VFR) Tasks was determined to be satisfactory, the applicant will receive a notice of disapproval.”

    Now, for the Commercial you need to look at 61.129 for those requirements…
    Commercial has both “PIC” and “SOLO” requirements, they are different. Solo will be PIC, but PIC may or may not be Solo.

    Here the reg states that the applicant must have 50 hours cross-country as PIC. If the student pilot is solo, that time is considered PIC. Would his student Solo XC time count towards the PIC requirements? Yes. Also, ONCE he has his Private SEL, any cross-country time when he is the “sole manipulator of the controls” in a SEL will be PIC even with a CFI onboard.

    May a student pilot fly more than 5 hours Solo XC and have it count towards his total PIC XC time? Absolutely. If he’s Solo, he has to be PIC and that time does count.

    As to the logging of this time there’s the FAA General Counsel’s Legal Interpretation (Kuhn 2014) which goes into this question. Basically, a pilot (student or not qualified to be PIC) who is “performing the duties of Pilot in Command” with a CFI may log the time as such, referencing either 61.65(g) or 61.129(a)(4). But they MAY NOT log that as PIC, since they are not qualified to act as PIC except while Solo, and not as Dual Received as the CFI is not allowed to instruct.

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