Part 135 Cross Country Time

[FlyersCFI]

I know this has been asked before...but could I please have a definition of cross-country time for the purpose of meeting Part 135 PIC requirements? Thank you.

 

[Jetpup]

As far as cross-country time goes, it’s really very simple:

1 - Anytime you land at another airport, it is a cross-country flight. Period. Whether you log it as cross-country time is another matter.

2 - Only cross-country flights >50 nm can be applied towards the rating requirements. That doesn't make the flights less than 50nm not cross-country - they just don't count towards the minimums for those certificates and ratings. You can still log them in the total cross-country column. They count for all other purposes, including 135 minimums.

AS far as logging goes, in the end I went with one column in my logbook, and only log flights over 50nm. I know other people who logged all their cross-country time regardless of distance, simply marking those particular flights to be applied for their advanced ratings (i.e. >50nm) with an asterisk so they could show the DFE which ones counted. As long as you have some effective way of showing which flights count towards the ratings requirements, that’s all you need – and it’s not even a requirement of any sort – it’s just a matter of presentation.



From the FAA FAQs:

QUESTION: Can cross country legs of less than 50nm count toward the Part 135 requirements?

ANSWER: Yes, flights including a landing at a point less than 50 nautical miles from and other than the original point of departure can count as a cross country and can be logged as a cross country for Part 135 operations in accordance with § 61.1(b)(3)(i). There are no qualifying distance requirements for a cross country in Part 135. As long as we are NOT talking about an APPLICANT seeking a private pilot, commercial pilot, or airline transport pilot certificate, or an instrument rating, § 61.1(b)(3)(i) applies.

{q&a-190}

 

[FlyersCFI]

Thank you Jetpup

Great reply....thank you

 

[avbug]

Note that for the ATP, a landing at a point other than the point of departure is NOT required. However, the length must still be at least 50 minles from the origional point of departure. This means that cross country time used toward the ATP may include extended flights that depart and arrive at the same runway, and may still be counted as cross country time so long as the flight at some point reaches a distance of at least 50 nm from the origional point of departure.

This is the only time cross country time is defined not requiring a landing at a point other than the point of departure.

Therefore, any flights used for the purpose of meeting the x-c experience requirements under FAR 135.(b)(2) & (c)(2), must have a landing at a point other than the point of departure, except those flights used to meet the experience requirements of the ATP certificate, under FAR 61.159(a)(1).

You will find the definition of cross country time in it's different applicabilities under FAR 61.1(b)(3).

 

[CAK@4000]

Response from Jetpup is right on the money. I had the same discussion with Detroit FSDO, and everything he states is correct. See ya.

 

[avbug]

Everything, with the exception of the above comments regarding the ATP.

Use caution getting clarifications or interpretations regarding the FAR from a FSDO. The FSDO is responsible for initiating enforcement action, but has no authority to interperet the FAR. Ask a dozen FSDO's or inspectors, and you may get a dozen different answers. Don't base your understanding or actions on a reply received from the FSDO; it's not necessarily correct, and doesn't have to be. Your actions, however, do.

Also remember that in the event of a violation, you cannot ever stand on the ground that you did what the FSDO told you was acceptable to do, because the FSDO has no such authority. You'll be violated, regardless of what the FSDO said, if the case warrants.

FAR 61.1 clearly spells out the definitions of cross country time.

 

[Wiggums]

Note that for the ATP, a landing at a point other than the point of departure is NOT required. However, the length must still be at least 50 minles from the origional point of departure. This means that cross country time used toward the ATP may include extended flights that depart and arrive at the same runway, and may still be counted as cross country time so long as the flight at some point reaches a distance of at least 50 nm from the origional point of departure.

Here's a question. Lets say on a regular basis I takeoff, fly to a VORTAC, and shoot an approach to an airport. The VOR is 50 miles from my departure point, the destination airport 46. From what you said above I can log the flight towards ATP cross-country time. If this is true, how should I indicate this in my logbook? The way it's logged now just shows the 46 mile flight. Should I add the VORTAC to the route of flight section?

 

[avbug]

Wiggums,

In the case you describe, there is no need to make a landing at any point other than the point of departure, in order to count this flight as cross country flying. You do not need to justify the destination airport being a greater distance than 50 nm, and you do not need to define the distance flown, with respect to logging of the flight.

You are correct that in order to be counted as cross country time for the purposes of FAR 61.159(a)(1) (ATP cross country requirements) the flight must be at least 50 nm from the point of departure. However, there is no requirement to land at any point other than the point of departure, in order to qualify as cross country for the ATP, (or for military pilots crediting flight experience toward the commercial pilot certificate).

I believe what you're asking is how to show the flight as having met the requirements of FAR 61.1(b)(3)(iv) (x-c requirements for the ATP). You could certainly include in the remarks column that you flew to a point such as the VOR which was 50 nm from the point of departure, but this is unnecessary. Simply include in the cross country column of your logbook the duration of the flight as cross country time.

This also means that you can show the entire flight as cross country, not just the time spent enroute. For example, flying an airplane with a 100 knot groundspeed to a point 50 nm away will take approximately one hour. However, you went to that point, performed airwork and sightseeing, and concluded three hours of flight time. For the purposes of meeting the definition of cross country requirements for the ATP, all of this time may be logged as cross country, even if you return to the origional point of departure, with landings at no other location.

Scenic tours of the Grand Canyon are another example. The west end tour may go to several locations, and often returns to the same point of departure. This is still cross country time, and one does not need to define how far into the tour one flew. One never lands at another location during the trip, but the entire flight is cross country, be it one or several hours (depending on the departure point). It's all still cross country.

For clarity, you can note that you flew to a point 50 nm away, but this is inferred by logging cross country time. I have seen examiners who did open charts and measure distances, and on several occasions have seen examiners refuse to proceed with a practical exam with an applicant who barely met the minimum times, and who had been a few miles short on a cross country flight (1 nm short, in one case; the applicant had to go fly another cross country to qualify before being allowed to return and take the practical test).

The FAA no longer scrutinizes logbooks. Formerly, one might be quizzed on various flights to determine that you were justified in logging the flight as you did, and the FAA would often do spot checks throughout the logbook to determine that a specific airplane was registered and current, or where it was supposed to be in the log, at a given time. They'd check it for authenticity, calling former employers, FBO's, etc, to determine that the times were correct. That was a time when getting the authorization to take the ATP written test (when there were written tests) still meant something; it was a tacit stamp of approval for your logbook by the FAA. Most employers required the authorization to take the ATP, because it was verification of what was in your logbook.

Any more, the FAA doesn't do this, and much of the validity behind getting the authorization (and the certificate itself) is gone. It no longer means anything. What this does mean for you, however, is that in all likelyhood, nobody in the world (or their right mind) is going to go through your logbook with a fine tooth comb to determine that you have included verification on every flight that your trip was indeed cross country time.

The FAR does allow you to log cross country time for flights less than 50 nm. However, this is contrary to the general definition of cross country time, as commonly used. This means that while you can log any flight as cross country which lands at another airport other than the point of departure, it gives the appearance of padding one's time to a certain extent, and should be avoided. The only real value this might have is getting you to the FAR 135 cross country minimums more quickly (which only specify cross country, but don't require a specific difference; FAR 61.1(b)(3)(i) is all the guidance you need for logging x-c to meet the requirments of FAR 135).

However, keep all your cross country logging within the 50 nm rule, and you won't have to worry about picking and choosing through your logbook. Your only determination then will be if the flight included a landing at a point other than the point of departure, which was at least 50 nm away, and then only for all ratings and certificates other than the ATP. Hopefull this hasn't been too confusing. Good luck!!

 

[Wiggums]

Avbug,

Thanks for the very detailed answer. Just one thought here. I always understood the general definition of cross-country flight to be, “time acquired during a flight that in includes a landing at a point other than the point of departure.” Under the basic definition the FARs don't list any particular distance. (61.1[3]) I've always logged any flight that included a landing at another airport as cross-country, even those trips under 50nm. I always thought this was acceptable as long as when you apply for a rating, you use to correct definition for that rating.

Using that methodology, if I was the pilot doing Grand Canyon tours, I would be hesitant to log that time as cross-country, since it didn't include a landing at another airport. However, I would use it as cross-country for my ATP. So, in order to determine the amount of cross-country time that meets the ATP aeronautical experience requirement, in my logbook I would have to subtract the cross-country time for trips less then 50nm, and add the time for the trips greater then 50nm that didn't include a landing. How would the examiner feel about that?

 

[avbug]

Perhaps the best policy is to never log as cross country any flight less than 50 nm. This doesn't mean that you must land at a point 50 nm distance away, but the flight must be to a point at least 50 miles from the point of departure. For the purposes of logging cross country time toward your ATP, you may land at the departure point, or any point inbetween. You need only fly to a point at least 50 nm from the place from which you depart.

You needn't add or subtract; it's cross country time. If you're using cross country time for any other certificate or rating, it must include a landing at least 50 nm from the point of departure. In such a case, you may wish to specify which flights are used to meet the experience requirements for that particular certificate or rating, but I would do so only at the request of the examiner. Otherwise, it's probably easiest and most convenient to log all your cross country flights simply as "cross country."

Once you have achieved all your cross country experience to meet the requirements for the ATP, then you will have also met the requirements for FAR 135, and you needn't worry much about how you log it, as you don't need any additional cross country for any further certificates, ratings, or privileges.

The definition for cross country you need will be found in FAR 61.1(b)(3). Consult (i) for general cross country definition, and (iv) for that applying to the ATP. If anyone ever questions you, it's written very clearly and unmistakably in FAR 61, which defines the requirements for each certificate and rating, as well as the logging of flight time (61.51).

While your past logging practice has been technically correct, the generally accepted definition of cross country means that the flight must be at least 50 nm. (While a flight two miles away is techically a cross country under 61.1(b)(3)(i), most folks won't see it that way, and it doesn't look very good). On the other hand, the Grand Canyon example may cover several hundred miles of ground track during the course of the flight, and is without question a cross country flight.

You are also correct that for the purposes of FAR 61.159(a)(1), your cross country flights used for the ATP must be at least 50 miles in length. How you add or subtract, or highlight, or otherwise divide that time is up to you. However, you must be able to demonstrate compliance with the FAR by meeting that minimum experience requirement. Chances are that when you arrive to take the practical test, your logs will be given a very cursory exam and you'll go right into the practical test without question. However...

If your logbooks include a wide compilation of different time logging techniques, I recommend one of two courses of action:

The first is to provide a reference sheet detailing the dates of each flight used to meet the experience requirements for the ATP. If you have a mix of flights meeting various logging requirements and all of them can't be used, make it as simple as possible for the examiner. When you arrive, have a list of each flight by date that is used to meet the requirements of the FAR. In this way, if the examiner so desires (he or she won't), the various entries may be quickly referenced for verification.

The second recommendation would be my personal recommendation. Modify your logbooks. While any flight less than 50 nm can be logged as cross country time, the only possible advantage for you in so doing is to build up enough time to qualify for the PIC requirements under FAR 135.243. As you are preparing for the ATP with it's requirements for 500 hours of cross country time, you will already meet the IFR 135 requirements specified under 135.243(c)(2), and there is no need to have any more logged.

(It's a mute point for 121 ops, because to act as PIC, you must have an ATP anyway).

What it boils down to is that by having the experience for the ATP certificate, you negate any value in logging any flights of less than 50 nm in length, as cross country.

My recommendation then, is to include in your cross country totals, only the cross country time that is 50 nm or more in length. Log all cross country flights as cross country, if they meet the various definitions, but only include in the totals column those flights of at least 50 nm. In this manner, all your flights are logged, but only those exceeding 50 nm are expressed in the total. You can easily make a change by simply changing the total on your next page in your logbook, and making a note at the bottom of the page as to the purpose of this change. If you do, be sure to include the relevant FAR reference, and the purpose for the change.

This isn't as drastic as it might appear. You may have 800 hours of cross country time in your log, for example. You find that only 500 of them meet the experience requirements for the ATP. You simply change the total carried over onto the next page, from 800 to 500, and make a note in the margin at the bottom of the page. It need say something only as simple as "Cross country total altered to reflect only the requirements of FAR 61.1(b)(3)(iv)."

How you log the time, or display it, of course, is entirely up to you. There will certainly be others here who will disagree, and their input will be invalueable in giving you a better idea of what you may wish to do. The bottom line is that it really doesn't matter; you're logged the time legally and within the definition of the FAR, and no one can fault you are argue with you for it. How you present this information to an examiner is up to you. I suggest that you find a way to present your information in the most streamlined and simple terms available, for the sake of efficiency and peace of mind at the time of the application for the practical test.

I hope that helps.