VFR 150 – only 3 points of landing or atleast 3 points of landing?

7 Answers

1. 
   

   
   

   LTCTerry on Sep 05, 2021

   A guide I’ve tried to follow in life is “if you have to explain, even if you are right your are wrong.” This has kept me out of trouble frequently.

   61.109 says “at three airports.” It doesn’t offer “at least three, if…” (I know that if you landed at four, you also landed at three.) If one of the landings is just a touch and go then there are only three full-stop landings…

   I would suggest not putting any private pilot candidate in the position of having to convince the DPE the requirement was with no doubt(s) met. 150 miles. 50 miles. Three full stop landings. Clean. Simple.

   This is just my opinion, not anyone’s legal interpretation.

   Training a rated glider private pilot and an LSA and in an airplane are two different things.

   EVERY Private Pilot regardless of ratings is already a Light Sport Pilot. So only light sport add on rules apply (two CFIs, train, evaluate, paperwork).

   Adding ASEL to Private Pilot Glider is an additional category/class under 61.63. Your student must do all the things in 61.109 that say “in a single engine airplane.”

   61.109 (a) (1) says “and the training must include at least – 3 hours of cross-country flight training in a single-engine airplane;”

   Your student may solo an ASEL on the glider private certificate. No student certificate is required/allowed. Unlike the standard 90-day endorsement for student solo flight, the standard endorsement for an add on category/class does not include an expiration. You may put an expiration date and any limitations you like.

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2. 
   

   
   

   LTCTerry on Sep 05, 2021

   A couple typos above. Sorry.

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3. 
   

   
   

   John D Collins on Sep 05, 2021

   Although not precisely on point, see this FAA General Counsel Opinion:

   https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/?year=all&q=61.109+%28a%29%285%29%28ii%29&bSubmit=Search

   Notice the wording of the third paragraph by the attorney:

   “The aeronautical experience requirement in 14 CFR 61.109(a)(5)(ii) provides, in pertinent
   part, that training must include at least one “solo cross country flight of at least 150 nautical
   miles total distance, with full-stop landings at a minimum of three points, and one segment
   of the flight consisting of a straight-line distance of at least 50 nautical miles between the
   take off and landing locations.\” [61. l09(a)(5)(ii)]”

   Although she was not asked the question if the three full stop landings was an exact number required, she paraphrased it as \”with full-stop landings at a minimum of three points\”, so at least in her wording, she considered it a minimum requirement.

   LTC Terry\’s advice is regarding having to explain oneself is still good advice, but a quick check with the local DPE with a reference to the FAA General Counsel opinion wording should solve that issue. IMHO, only a pedant would read this as a specific limit. A specific limit would mean that a cross country flight of a total of 500 miles and 4 stops would not qualify, nor would a precautionary landing due to weather qualify, where the student exorcises good judgement, lands and waits out bad weather before continuing the flight.

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4. 
   

   
   

   Mark Kolber on Sep 05, 2021

   John, was there an amendment since that opinion letter deleting “a minimum of” from the regulation?

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5. 
   

   
   

   John D Collins on Sep 06, 2021

   Mark, great question. This is the wording I found through the 1-1-2009 edition:

   (ii) One solo cross-country flight of at least 150 nautical miles total distance, with full-stop landings at a minimum of three points, and one segment of the flight consisting of a straight line distance of at least 50 nautical miles between the takeoff and landing locations; and

   The opinion is dated 9-8-2009.

   The wording I found used in 1-1-2010 changed to read as:

   (ii) One solo cross country flight of 150 nautical miles total distance, with full-stop landings at three points, and one segment of the flight consisting of a straight-line distance of more than 50 nautical miles between the takeoff and landing locations; and

   It appears to be the result of the final rule: FR Doc No: E9-19353 effective October 20, 2009 https://www.govinfo.gov/content/pkg/FR-2009-08-21/html/E9-19353.htm

   The reason cited for the wording change was:

   52… Sec. 61.109(a)(5)(ii)… Changes the distance on a cross country flight for private pilot certification–single engine airplane rating from “at least 50 nautical miles” to “more than 50 nautical miles.”

   The detail explanation of the change follows:

   52. This revision of Sec. 61.109(a)(5)(ii), (b)(5)(ii), and (e)(5)(ii)
   amends the solo cross country mileage requirements for consistency with
   the mileage requirements under the definition of “cross country”

   This final rule revises Sec. 61.109(a)(5)(ii), (b)(5)(ii), and
   (e)(5)(ii), standardizing use of the term “cross country” throughout
   part 61. Under Sec. 61.1(b)(3)(ii), the FAA defines the distance of a
   cross country flight, in pertinent part, as “more than 50 nautical
   miles.” Under Sec. 61.109(a)(5)(ii), (b)(5)(ii), and (e)(5)(ii), the
   regulations erroneously state, “of at least 50 nautical miles.” The
   revision amends all definitions of “cross country” to read “more
   than 50 nautical miles.” Four commenters supported changing the
   definition of cross country. One commenter asserted the change will
   eliminate questions regarding rounding without a significant negative
   impact. Nine commenters objected to the change with one arguing that
   the change could force performance of longer cross country flights in
   instances where existing airport pairings are exactly the specified
   number of miles apart. One commenter believed there was no compelling
   safety or other concerns sufficient to mandate the change, and another
   commenter asserted the proposed change would only provide minimal
   benefits.
   Two commenters recommended that, rather than changing Sec.
   61.109(a)(5)(ii), (b)(5)(ii), and (e)(5)(ii), the FAA change Sec.
   61.1(b)(3)(ii) to read “at least” for continuity purposes. One
   commenter recommended that, if the definition of cross country flight
   is to be changed to a format of “more than” a number of miles, that
   mileages be reduced by one mile (i.e., from at least 50 miles to more
   than 49 miles). One commenter asserted the change will eliminate
   rounding without a significant negative impact. One commenter asserted
   the costs of the change outweigh the minimal benefit resulting from
   changing the definition. One commenter, while opposing the change, will
   accept it if it would prevent issuance of a certificate stating
   “Holder does not meet ICAO requirements.”
   The purpose of the rule change is to correct a mistake in the
   former rule and no substantive changes have been made.

   The last sentence of the reason for the change says “The purpose of the rule change is to correct a mistake in the former rule and no substantive changes have been made.” So my opinion is that the change that dropped the words “a minimum of” was merely editorial in nature and not intentional.

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6. 
   

   
   

   Russ Roslewski on Sep 07, 2021

   See also the answers to a very similar question recently:

   http://www.askacfi.com/35201/can-the-150nm-cross-country-have-4-destinations-airports-instead-of-3.htm

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7. 
   

   
   

   Mark Kolber on Sep 08, 2021

   I agree with you, John. “No substantive changes have been made” tells us it was not intentionally written to limit the number of stops.

   Of course, as Russ mentioned in the other thread on the subject, I guess one has to watch out for pedantic DPEs.

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