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3 Answers

61.129 2hr 100nm xc for cpl

Asked by: 1819 views FAA Regulations

In Part (4) the reg specifies "one (point of landing) ... is a straight-line distance of atleast 250nm from original departure point" 

In Part (3) the language is different and unclear where it says "xc flight ... consists of total straight-line distance off more than 100nm"

It doesn't specify the point of landing be 100nm away like the first one does. And it added the word total, which implies that 2 50nm+ legs in the same flight would count, as if you flew 50 miles away and 50 miles back in the same 2hr flight. Is this the correct interpretation?

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3 Answers



  1. Bryan on Jul 04, 2023

    Don’t try to combine parts–it confuses everyone. Take them one by one and make sure you check the definitions of the words involved. Where your question focuses on the interpretation of 61.129(3), I’ll focus there.

    In 61.129(3)(iii) and (iv) you are required to get day (iii) and night (iv) cross country flights of a total straight-line distance over 100 nautical miles that are at least 2 hours long. There are two terms that need a little extra attention. First is “cross country” so we look to 61.1. Under Cross-country time we learn that cross country means … (ii) for the purpose of meeting the aeronautical experience requirements for … a commercial pilot certificate … 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 more than 50 nautical miles from the original point of departure, and (C) involves” navigation. Thus, any requirement for cross country time to meet the aeronautical experience requirements for a commercial pilot certificate requires a landing at least 50 NM from the original point of departure.

    The second term is “total” as you pointed out. The word total generally allows you to aggregate smaller units. How that would work here is if you suppose you have three airports that form a triangle and they are each 40 NM from each other. Flying from A to B to C would be a “total straight-line distance of more than 120 nautical miles from the original point of departure” even though you ended at your point of departure. However, that 120 NM triangle would fail to meet the definition we already looked at from cross country because you did not “include a point of landing that was at least a straight line distance more than 50 nautical miles from the original point of departure.” See how the requirements are slightly different?

    Because 61.129(3) is training (with an instructor), I find that the best way to get (iii) and (iv) done is to find a place that satisfies the mileage (50 and 100) and time requirements for your plane that has a good place to eat. Fly there during daytime conditions, eat until it’s night, then fly back during night conditions (or if it’s a great breakfast place, fly at night, eat, then fly back in daytime conditions).

    But that’s why the word “total” appears in 61.129(3)(iii) and (iv).

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  2. nickb86 on Jul 04, 2023

    Thanks for responding Bryan. I was only using part (4) to demonstrate the language used when the intent is to fly xxnm away vs when only the total flight distance is specified. And to be safe, yes, I would go ahead and do the 100nm from A to B in the future. The reason I’m asking is because I’ve already done several dual 2hr day and night xc, but they were not 100nm in any single leg. They were xc per the regs, and over 100nm total distance. So I believe we are both saying that yes, a normal there-and-back xc flight of 51nm counts given it meets the other criteria (ie dual and 2 hrs) Are you a cfi or dpe by chance?

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  3. Bryan on Jul 04, 2023

    CFI. Short a lot of hours to be a DPE.

    And you’re not looking for 100NM in any one leg. You could land every 5 miles and still get a total of 100NM total straight line distance from your point of origin…

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