Attention Instrument Rated Pilots or CFIIs…!

[rgrazian]

Hello All,

As I’m getting close to my check ride and in reviewing my log book, I had a little disagreement with my instructor regarding the 50 hours cross country time required for an instrument rating under Part §61.65(d)(1)

It states:

§61.65 (d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:
(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country flight time as pilot in command, of which 10 hours must have been in an airplane; and
(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:…….

Here’s the rub…

I contend that “Solo” cross country time as a student counts towards that 50 hours. I used §61.51(e)(4) allowing a student to log PIC (when solo) to justify that those solo cross country trips were indeed PIC. I believe prior 1997 there was a requirement that those 50 hours had to be post private, but I cannot validate that. If I cannot count that student time, I’m still over 50 PIC XC. However, I think it should be counted according to the FARs. I cannot find an opinion letter on this specific example, so I may contact the FSDO just to be sure before I put in IACRA. Has anyone else counted this time towards the 50?

Rob

[jtek]

I believe you are correct (and I definitely counted my student solo XC time on my 8710), but if you've got enough time either way, I would do the diplomatic thing and stick with what your CFII says.

[Keith Smith]

I would find out the right answer and make sure both you and the CFII know it If the CFII isn't interested in finding out the real answer (not saying this is the case), that would not be a good sign.

[rgrazian]

Josh and Keith... Thanks for the responses. I think I'm going to ask the FSDO. I just really want to know the correct answer. And I want my paperwork correct regardless of whether I can count it.

[dehavilland]

Hey Rob!

Your PIC XC time as a student pilot absolutely counts towards your 50 hours PIC XC time required for your Instrument Rating.

Be safe, have fun & keep learning!

Matt D'Angelo
Chief Instructor
Aero Safety Training

[rgrazian]

Hello Everyone,

As Matt and Josh stated, the time does indeed count. Here is the response from the FSDO (my email to them is at the bottom):

Date: Fri, May 17, 2013 at 8:13 AM
Subject: Fort Worth FSDO Information
To: Rob Grazian

Mr, Grazian
Any cross country flight time that may be considered as PIC cross country
may be used toward the instrument rating requirement.

Operations Unit Supervisor
AFW FSDO Fort Worth, Texas



Message:
----------------------
Instrument Rating - Aeronautical Experience

Hello,

I have a question regarding the Aeronautical experience required under Part
§61.65 for an Instrument Rating, Airplane. Can student pilot solo cross
country time apply toward “50 hours of cross-country flight time as pilot
in command” as required by the regulation since a student can log PIC as
provided in Part §61.51(e)(4) when solo? This is assuming all other
requirements defining “a cross country” flight were met.

Kind Regards,

Robert A. Grazian - Private Pilot