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Old 02-04-2013, 05:26 PM   #1  
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Default Logging XC according to Orlando FSDO

How do you guys log cross-country time? Letís assume that the total hobbs time is 3.0 and you made 2 full stop landings during your XC. Orlando FSDO make us deduct 0.2 from the XC time for each landing for what they call "Airport operation" which involves taxi, run-up, etc. So the "correct" way according to the FSDO to log this flight is 3.0 total time and only 2.6 XC time.
I tried to research this issue and couldn't find anything specific. Part 1.1 defines flight time as : "(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing".
While part 61.1 defines XC time as...
(i) Except as provided in paragraphs (b)(4)(ii) through (b)(4)(vi) of this section, time acquired during flight"
The FSDO interprets the time acquired during flight as the time that is acquired from takeoff to landing. My personal opinion is that the FSDO got it wrong as time acquired during flight is flight time... But I might be wrong. What are your thoughts? How do you log cross-country time? Do you consider time acquired during flight the same thing as flight time?
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Old 02-04-2013, 06:19 PM   #2  
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Quote:
Originally Posted by Squawk87 View Post
How do you guys log cross-country time? Let’s assume that the total hobbs time is 3.0 and you made 2 full stop landings during your XC. Orlando FSDO make us deduct 0.2 from the XC time for each landing for what they call "Airport operation" which involves taxi, run-up, etc. So the "correct" way according to the FSDO to log this flight is 3.0 total time and only 2.6 XC time.
I tried to research this issue and couldn't find anything specific. Part 1.1 defines flight time as : "(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing".
While part 61.1 defines XC time as...
(i) Except as provided in paragraphs (b)(4)(ii) through (b)(4)(vi) of this section, time acquired during flight"
The FSDO interprets the time acquired during flight as the time that is acquired from takeoff to landing. My personal opinion is that the FSDO got it wrong as time acquired during flight is flight time... But I might be wrong. What are your thoughts? How do you log cross-country time? Do you consider time acquired during flight the same thing as flight time?
Part 1.1 defines it as:
Quote:
Flight time means:

(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing; or
And part 61 says:

Quote:
(4) Cross-country time means—

(i) Except as provided in paragraphs (b)(4)(ii) through (b)(4)(vi) of this section, time acquired during flight—

(A) Conducted by a person who holds a pilot certificate;

(B) Conducted in an aircraft;

(C) That includes a landing at a point other than the point of departure; and

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

(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 ß 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.
61.51 says:
Quote:
(b) Logbook entries. For the purposes of meeting the requirements of paragraph (a) of this section, each person must enter the following information for each flight or lesson logged:

(1) General—

(i) Date.

(ii) Total flight time or lesson time.

(iii) Location where the aircraft departed and arrived, or for lessons in a flight simulator or flight training device, the location where the lesson occurred.

(iv) Type and identification of aircraft, flight simulator, flight training device, or aviation training device, as appropriate.

(v) The name of a safety pilot, if required by ß 91.109 of this chapter.

(2) Type of pilot experience or training— (XC)

(i) Solo.

(ii) Pilot in command.

(iii) Second in command.

(iv) Flight and ground training received from an authorized instructor.

(v) Training received in a flight simulator, flight training device, or aviation training device from an authorized instructor.

(3) Conditions of flight
Time acquired during a flight vs. flight time?

You should ask the FSDO if they think this would hold up in court? (it wouldn't). They'd have to argue that "time acquired during a flight" is not "flight time". It's a loophole that they left open, and while the FSDO is free to interpret it the way they have and make people present their logbooks in a "manner that is acceptable to the administrator", if this went up the pole to an NTSB judge, it would likely get knocked back down in favor of whomever wanted to record the "total" time, because the FAA wording isn't very clear and any decent lawyer would be able to argue that "time acquired during a flight" is synonymous with "flight time" when applying reasonable rules of the English language.

2 outta 3 are fairly clear that it's the total hobbs time essentially, and the case that doesn't fit doesn't fit just because they used the term backwards? Yeah...

Last edited by JamesNoBrakes; 02-04-2013 at 06:31 PM.
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Old 02-04-2013, 08:56 PM   #3  
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Quote:
...and while the FSDO is free to interpret it the way they have ...
The FSDO level does not have authority to interpret regulation. That is left to the Regional and Chief Legal Counsel, who interpret regulation (and issue letters of interpretation) on behalf of the Administrator.

Chief Legal Counsel letters of interpretation and legal opinions are defensible in the appeal process. The word of an inspector at the FSDO level, or even that word in writing, is not.

An FSDO inspector has authority to initiate the enforcement process, but not to interpret the regulation.
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Old 02-04-2013, 09:53 PM   #4  
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Central FL is very picky about student logging, and prone to random acts of management due to all the shenanigans at the puppy mills over the years.

If you don't feel like fighting city hall on this, just do touch and goes until you can get the hell out of the swamp.
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Old 02-05-2013, 03:24 AM   #5  
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Quote:
Originally Posted by JohnBurke View Post
The FSDO level does not have authority to interpret regulation. That is left to the Regional and Chief Legal Counsel, who interpret regulation (and issue letters of interpretation) on behalf of the Administrator.

Chief Legal Counsel letters of interpretation and legal opinions are defensible in the appeal process. The word of an inspector at the FSDO level, or even that word in writing, is not.

An FSDO inspector has authority to initiate the enforcement process, but not to interpret the regulation.
True, but I left out the part of the regs that does say "in a manner acceptable to the administrator", that gives the FSDO a wide berth, although it could be knocked down by a legal ruling. I'm talking about before it goes to legal.
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Old 02-05-2013, 05:16 AM   #6  
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That's true. The conundrum for the average citizen-pilot who is subject to the FSDO is that one will never get the opportunity to use the legal interpretations until the appeal process in enforcement action, so it's a two-way sword.

One must get past the FSDO in the first place.
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Old 02-05-2013, 03:50 PM   #7  
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I'm a retired Airline Guy with all the CFI tickets.
Recently trained a good friends son, in their family C-172, in the Ocala, FL area (under Orlando FSDO's jurisdiction).
Got the kid 90% complete, and the engine went out of limits on Annual!
Sent him to a good local Flight School for finish up, and they recalculated his X-C hours, using the .2 adjustment mentioned, because all the Designated Examiners in this area, are following this guideline we were told.
Family said fine, more training never hurts.
Kid didn't mind either.
I'd never seen this "adjustment" technique in 42 years as a CFI, but what it is, is what it is, I guess!!!
Just saying.
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Old 02-05-2013, 05:58 PM   #8  
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Originally Posted by jabr800 View Post
I'm a retired Airline Guy with all the CFI tickets.
Recently trained a good friends son, in their family C-172, in the Ocala, FL area (under Orlando FSDO's jurisdiction).
Got the kid 90% complete, and the engine went out of limits on Annual!
Sent him to a good local Flight School for finish up, and they recalculated his X-C hours, using the .2 adjustment mentioned, because all the Designated Examiners in this area, are following this guideline we were told.
Family said fine, more training never hurts.
Kid didn't mind either.
I'd never seen this "adjustment" technique in 42 years as a CFI, but what it is, is what it is, I guess!!!
Just saying.
Extra training is fine, but when you try to get your commercial especially on a multi-engine airplane it can get very pricey for no good reason... Just saying
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Old 02-05-2013, 07:56 PM   #9  
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I think most of us will agree this is fairly ridiculous. Personally I'd do some mathematical rounding to lessen the pain.
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Old 02-06-2013, 03:57 PM   #10  
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Originally Posted by Squawk87 View Post
Extra training is fine, but when you try to get your commercial especially on a multi-engine airplane it can get very pricey for no good reason... Just saying
Hey Squak87,

I agree with what you are saying.
In our scenario, it made no sense to "Fight City Hall".
Nothing in this business is cheap, as I'm sure you have already found out!
I'm sure like others have already said, there is little to nothing to support Orlando's thinking on this one.
Good luck on your training.
I left an opening at Big Brown for you, if your timing is right!

Jabr800

Last edited by jabr800; 02-06-2013 at 04:01 PM. Reason: Left out something
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