Pilot training experience requirements—just do what the regulation says!
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The title of this blog post sounds like a complaint. In a way, it is meant to sound that way to draw attention and to make the point that we have something to fix.
In too many training processes, we have CFIs and their students trying to get creative with their training. They are trying to shortcut training, combine requirements, and double-dip things to make it so there is less time needed to get things done. Many times this is causing students to end up with missing or mis-qualifying activities toward their required aeronautical experience.
Please stop trying to get overly creative!
That’s it. Don’t get creative and try and mix and match. The best advice I can give here is simple: do what the regulation says.
Let’s give you some examples of where this goes awry.
How about this as a long private pilot solo qualifying cross-country flight?
At first look, it might look good. It has more than 150 NM; it has a leg that is longer than 50 NM; and it has a landing point that was more than 50 NM from the original point of origin (14 CFR 61.1 definition). But there is a hiccup here.
The crafty, creative CFI thought it would be a great opportunity for the student to get in some practice at another airport. In this case, he had the student grab another airport (a 4th) along the way. They thought that the student doing another landing at Marion (KMWA) would be some good additional experience for them at a towered airport. They aren’t wrong about that, but in a strict sense, it now means that cross-country solo flight doesn’t count toward the experience requirements for a private pilot certificate.
Huh? You are probably reading this and thinking, “Why?” Well, words matter. Let’s break it down.
14 CFR 61.109(a)(5)(ii) indicates that a private pilot candidate needs to complete:
It doesn’t say “at least three landings” or “three or more landings”, it says AT THREE POINTS. By stopping at four airports in this case (inclusive of the one the student came home to, they didn’t do what the regulation says. Ok, this is picky. Yup, but it is technical and correct.
That savvy CFI might just then say, ok, well, then how about I have him “fix his logbook” and that the last leg home was a “different flight” then? Hmm…maybe. But how did they endorse the student for that then? Does that match what the student did or logged?
Plus, this will cause another problem. If we indulge this possibility, we get the following:
Ha, see, now its only three airports! But now its less than 150 NM total distance. So, by making that “creative logging” change, you kill the cross-country as a qualifying item another way. Build this carefully, and just do what the regulation says and you won’t end up in this challenge.
What about instrument cross-country requirements?
We have that long IFR cross-country we have to do. Here is an example of one:
Well, it gets to the 250 NM requirement if we assume they shot approaches at each airport they could and had the right mix of approaches along they way so it looks good on the surface.
The regulation (14 CFR 61.65) says the instrument pilot in training must complete the following:
Here are a few ways this could go wrong, and did.
First, the student and CFI did not land at KTVC or KSLH, but did land at KRQB where they got fuel before coming back to their home airport at 7D3 (which didn’t have fuel). So, while the total distance traveled is over 250 NM, they did not land at a location that is more than 50 NM away from the point of origin. KRQB back to 7D3 was only 17.3 NM. This means that the ENTIRE flight does not count as a cross-country flight for use toward a certificate/rating according to the definition in 14 CFR 61.1.
Ok, so that’s a problem. But let’s assume they had landed at KTVC of KSLH, even a full stop taxi-back and then were on their way. Well, the regulation states that the pilot must have “an instrument approach at EACH airport.” In this case, the CFI and the pilot flew three approaches, one at KTVC, one at KSLH, and one at KRQB. Then they jumped back to 7D3 under VFR, not shooting an approach. I noticed this when I saw four airports and three approaches. It got me asking more questions and that’s what I found. That also would nullify meeting the requirement.
Ok, let’s say that they logged that flight separately—the quick VFR leg back home. I think you might see where this is going from the example above, but without that extra 17.3 NM, they end up with a total flight distance of 247 miles which is short of the required 250 NM. Sigh. A little better planning ahead of this particular event could have avoided these pitfalls.
I have seen this instrument long cross-country flight go wrong lots of ways. Flying out of an airport that doesn’t have an approach and returning to it is another example. Not flying enough total miles, but getting the number of approaches is another. Failing to land at an airport more than 50 NM away is yet another. All of these can nullify a very expensive flight from counting toward the required experience.
There are LOTS of hiccups in the commercial pilot training experience requirements outlined in 14 CFR 61.129 that people get creative with. My favorites are when people try to “double-dip” a cross-country requirement from their private or instrument training toward their commercial. These are separate regulations. Just because your CFI was with you on a cross-country flight in your instrument training doesn’t mean that you can use it also toward your dual day or night cross-country experience requirements for your commercial. However, there are some creative ways to plan ahead.
You could potentially fly a leg out to a destination to meet a specific requirement and fly a leg back to meet another requirement, but that takes good planning and some forethought and savvy. Most people mess this up if they to do it ad hoc. If you are planning a full training sequence from student pilot to commercial pilot, you may be able to do this if you lay it out correctly. If not, again, my best advice is to do what the regulation says in one separate activity to ensure it meets the requirements.
The biggest problem in the commercial we end up finding relates to the solo time requirements. 14 CFR 61.129(a)(4)[single-engine] and (b)(4) [multi-engine]. Note that the pilot shall complete:
So let’s imagine we wanted to go away from the cold weather in the winter with our plane and do some flight training in Puerto Rico. Sounds good, right? How about this for a long-commercial-qualifying cross-country flight?
Scenic, beautiful, and a total of 315 miles. Ha, you may be thinking, the regulation says they have to land at three places! They landed at more airports than that so it kills it, right?
Well, not in this case. The commercial specifically says “with landings at A MINIMUM OF three points…” This means you can land as many times as you want during this effort. But it does say you have to have a landing point that is more than 250 NM from the point of origin. Again, language counts.
In this case, KTJBQ (Aguadilla) is the furthest point away which is only 141 NM from TISX (St. Croix). So, you haven’t traveled somewhere physically far enough away from where you started.
We commonly see this mistake for this reason: when people think there has to be a “leg” that is over 250 NM of “in-air” time (that isn’t the case for this one) or even that people think you have to return from the flight! I this case, you could go somewhere 251 NM away, fly 50 NM back, park the plane, and never bring it back. I have seen people meet this requirement when they were selling a plane, delivering it, etc. But they did so carefully in their logbooks. The commercial requirements have to be carefully applied.
Again, you are probably tired of hearing it by now, but just do what the regulation says.
There are some more on the commercial and the private that you might want to check out in an older blog post of mine, Common CFI Checkride “Administrata” Errors posted in February 2019. These errors haven’t gone away since I posted this. They keep happening, but we can improve.
How about a couple of others?
In the private pilot, there must be landings at night:
I have seen CFIs do these at touch-and-go landings. That doesn’t count. The same holds for the requirements for a student in private pilot training at controlled airports practice where they have to complete:
I have watched tower controllers clear students for the touch-and-go and the student either wasn’t instructed to make them full-stop landings or was afraid to ask the controller to do so when the controller cleared them otherwise. These little things count.
I could keep offering more of these, but I think you get the point. Get detailed, simplify it, and do what the regulation says. Don’t try to get too crafty. It can burn your student if you don’t get it exactly correct when you try to wedge too many experience requirement satisfying things in one activity.
So, how can you make sure you don’t make these mistakes?
Have a good checklist for each certificate/rating you are training someone for (or if you are receiving training, you can take some control of your training efforts to make sure your CFI is doing it right). There are lots of them out there, there are even some under the Resources tab at JasonBlair.net you can use. I don’t care if you use mine or someone else’s but use something. Don’t just “wing it” (pun intended) and hope that toward the end you can go back into the FARs and review if you have managed to cover everything.
Have a good syllabus, not just things you will cover, but an order in which you will do it. I get it, you might get bored going to the same airports with students over and over, but if you build a sequence that works, covers everything you are supposed to cover, and meets the requirements, it will make sure your students get it done right. Plus it isn’t about you as a CFI. You are supposed to be a professional providing a good training experience. And for them, it will be the first time they have done these things. Think about proper customer service and professional instruction efforts.
Track the student’s progress through the experience requirements, syllabus, and training program. Document it well in case another CFI has to step in and do any of it, or if you as a CFI have to move on to other jobs. Don’t leave your student in a case where people don’t know what experience requirements are done and what ones are left to cover.
When it comes down to it, it is about being a professional. Be a competent CFI who puts the time into planning your student’s training effort to be effective, and efficient, and that it will meet requirements properly.
- Pilot training experience requirements—just do what the regulation says! - April 14, 2025
- How Many Hours is Average to Earn a Pilot Certificate? - December 16, 2024
- Excuses to Proceed with a Checkride (You Probably Shouldn’t be Using) - July 15, 2024
This is the kind of ticky-tacky stuff that gives DPEs a bad reputation. In asking whether a flight meets the criteria of 14 CFR 61.109(a)(5)(ii), then you simply ask if there were “full-stop landings at three points”? If I landed at more than three points, then the answer is a resounding: “Yes, I did land at three points!” It doesn’t say “at exactly three points” or “no less or more than three points.” As you say: language counts! Honestly, if a DPE had refused my logbook for that reason alone, I would report it to the FSDO and find a new DPE.
The real advice to CFIs and students is that you should make your logbook unimpeachable. Trying to do the bare minimum is usually what gets people in trouble, but it’s training, so try to do everything better and more. You might save a few bucks and time by doing the bare minimum, but one DPE can ruin your plan and cost you more time and money than you saved, especially if you are making a career out of this.
61.65 that you posted said “ a flight off 250 nautical miles” by your rational that flight better not be 251nm or it won’t count! A flight of four legs has 3 legs. Trying to disqualify a four leg flight because it has more than the required 3 legs should result in a complaint to the overseeing FSDO.
Sorry Jason, but I think you are off base on the private cross country. If the 14CFR said a “maximum” of three points, you would have an argument. As long as you land at three points you are ok.
I agree with the instrument and commercial cross-country. It must be cross-country, so you need the 50 NM distance for the instrument and 250 for the commercial.
Best, Vince
Thankfully, those cross country landing requirements do not apply to military pilots. I received ATP with maybe 100 hours of civilian-legal cross country time. But, I had thousands of hours of flights >200NM from takeoff base without landing.
I don’t disagree with the concerns expressed here of the “very narrow application” of these regulations in these examples. What I will say is that I have seen this (the 3 points in the private example) be used as a “discussion point” during a 44709 for a CFI with an FAA inspector as they worked through the CFI becoming more proficient at properly applying applicant experience requirements. The main point here is to try to work within the regulations, and just do what they say, to make sure requirements are met, not try to work around them and get overly creative and end up doing things that may make an applicant non-eligible for a practical test, required to complete more (and costly) training, or delay their training completon.
14 CFR 61.109(a)(5) states:
10 hours of solo flight time in a single-engine airplane, consisting of at least—
This is where the “at least” applies to all the requirements. So doing the 4th airport would qualify as long as it remained with all the other parameters. Without that, one could argue that student pilots who are based at a controlled airport would be ineligible since they would have more than the “3 full stop landings”.
Um, no. You are completely wrong. By your logic the cross country would need to also be EXACTLY 150 miles, not 151 or 150.6. Your credentials say you are a DPE. You need some education before continuing in that role. If one of my students failed a check ride with a DPE for a reason like this not only would I be very vocally complaining at the governing FSDO, flight schools and aviation community but you would be spending some time trying to defend yourself in court for the fees and wasting our time.
What hog swallop.
Frank, I don’t make the regulations as a DPE, I just apply them. When an applicant is not “qualifiable” for a practical test, it is not a disapproval. It is a non-start. I do not charge for a test that is not able to proceed due to applicant missing experience requirements or documentation of their required training. I also don’t charge for retests. Complaining to a FSDO that a DPE is not proceeding with a practical test to a FSDO when an applicant doesn’t meet the requirements is certainly within your right, but this is exactly what generated the focus on highlighting the need to meet the requirements. I have seen this result in the CFIs outing themselves for not providing training that meets the requirements numerous times. Take that for what you will. If you do less, that is up to you as a CFI and if you get away with it, and you are OK with that, I’m not here to stop you. I am here as a DPE to make sure I don’t provide tests to applicants that don’t meet requirements or can’t demonstrate that they do so I don’t give a test that can be overturned as valid for the applicant’s sake later. A quality CFI should have that same desire.
“Frank, I don’t make the regulations as a DPE, I just apply them.” If you have not started a check ride because a candidate had four airports they landed at, then as others have said, you are *selectively* applying the regulations. If you will be pedantic about 3 airports, you must be pedantic about the cross country being exactly 150 miles. You cannot have it both ways.
I can’t imagine 4 airports not exceeding the requirement of 3 airports. Everything was met, the distance was equal or greater and the airports were equal or greater. Seems legit.
This is ridiculous, especially about the 4 landings on the cross country. Let me spin it further Jason; the requirements also say that ONE segment should be above 50nm. Not two, not three. One. So you would now also disqualify those students who flew a triangle with two legs above 50nm.
Makes it quite a task. You need to fly 150nm in 3 legs but only one can be above 50nm.
Tell me if I’m wrong about interpreting this as “strictly” as you do with 3 landings. If you insist on the “exactly” 3 landings you’d also need to insist on ONE leg being above 50nm.
Hope that thought helps to illustrate how unreal your argument is.
Chris, the point in the distance is that the regulation states that “one segment of the flight consisting of a straight-line distance of more than 50 nautical miles”, it doesn’t say anything about the other two segments length. Your question on that point becomes a point of language use, left apart, not descriptor for those legs is given in the regulation. Thus, they could be as desired, less, more, no description is given of what the composition of the other legs need be. I used this example of the 3 points because I have seen it applied this way and held up when questioned by FAA ASI disqualified applicant’s long-xc that they did and they were required to re-fly them with less landing points (to mee the 3 point requirement). I can’t tell you I think that is what should happen, I can just tell you that I have seen it applied and held up that way. So, to avoid that potential, do what the regulation says. When it says do 3, do 3. If it says a leg has to be greater than 50 NM in length, don’t try to make a stop in the middle and have 25 NM and 25 NM or do a leg that is only 49 NM. When a CFI isn’t precise in what they have their students do, it leaves the DPE with an inability to clearly qualify an applicant and the test may not be able to proceed. If the DPE doesn’t catch it, it can lead to interpretation at a later date that the individual was not properly qualified for the certificate they hold.
So to be clear, how you and the ASI are interpreting the regulation, is the following:
The student needs 5.0 hours of solo x-country time. If they have 5.1 hours or more, then they can’t do the checkride.
They need 150 nm x-country with 3 full stop landings. If they have 4 full-stop landings and/or flew 151 nm or more, they can’t do the checkride.
They need 3 full-stop landings at a controlled field. If they have done 4 or more, they can’t do the checkride.
A good question. It is about using the english language sentence parsing here like in old school English class.
The 61.109(a)(5) then has sub parts (the (i), (ii), and (iii) that are basically like finishing a sentence, so the modifier “at least from the (5) portion that reads 10 hours os folo flight int ein a single-engine airplane, consisting of AT LEAST -” and then we add to the rest of the sentence, each sub part. So it would read “…AT LEAST 5 hours of solo cross-country time.” Which means more can be done also, so doing 5.1 as you propose would still meet the requirement of this sub-section. The same holds true of part (iii) which would read “…at least three takeoffs and landings….” which means more than is acceptable.
The challenge with (ii) is that it would read “…at least one solo cross country…” and that is where the “event” in the sentence applies for the modifier “at least”. The rest of the sentence is a clause, a modifier of the event, where it discriminates that the event, the long solo XC in this case, must have certain criteria met, including the “…full-stop landings at three points…” The “at least” clause in the (5) section of this leaves open that a candidate could fly more than one if they so chose, but 1 becomes the minimum of number of XC flights that must be met that then meet the descriptor criterion in the remainder of the sentence.
While it is possible to argue that more than three might meet this, I have seen it disqualify the event for an applicant in more than one instance. So, as a CFI, I just don’t put my students into the position where as an applicant for a practical test they even had to argue the point that it did. If they do 3, it clearly meets the requirement as written.
The regulations are written very carefully in the language, and there are times where there are errors also (some times we get them changed with regulatory updates when possible). But the regulations are written using very precise englinsh language and it some times takes us back to old school English class to parse out the sentences and the modifiers.
So if we read it how you propose, the student also needs to fly exactly 150 nm. 151 nm or more would not meet the requirements.
I guess what I’m having trouble with is the the intent of part 61 seems to be the minimums required to become a pilot. Everything is the minimum amount of knowledge or experience, until we come to the solo x-country requirement for a PPL, now we have an exact amount of experience required.
Keller 2009 legal interpretation addresses this
The 2009 Keller letter you referenced states “with full-stop landings at a minimum of three points”. So how is the 4th landing not meeting the requirements?
Yes it does. Ran into that also when the situations that generated this discussion came up. The response we got was that the legal interpretation quoted the regulation as saying “with full stop landings at a minimum of three points…” but that the current regulation does not have that language the same. The current regulation does not have the words “a minimum of” in there, and it was thus deemed not applicable since the current regulation does not match what was in the legal interpretation on that segment.
I honestly don’t know if the quotation was wrong in the interpretation, or if the regulation changed at some point after 2009 when it was given. At that point, the affected individuals chose to fly the flights over with three landing locations. It would be interesting to know if that regulation language had a change to it at some point after that.
Listen, if this is how it is going to be, we might as well just pack the whole thing in and I’m going to take up knitting.
Let us have a moment of silence for all the Student pilots in southwest Michigan.