Legal Interpretations
Wambolt 1993
Summary
The Question
Since 14 CFR 61.155(b)(2)(i) sets no landing or mileage requirement, what flight experience counts as cross-country for the airline transport pilot certificate?
Background
A requester asked the FAA's Northwest Mountain Regional Office to clarify the cross-country flight requirement for an airline transport pilot certificate, noting that other certificates and the instrument rating set out cross-country requirements with particularity.
The FAA’s Interpretation
It depends. There is no legal definition; Flight Standards decides. For commercial pilots as required crewmembers, it includes time under 14 CFR part 121, 14 CFR part 123, or 14 CFR part 135 landing at another point; time under 14 CFR part 91, 14 CFR part 127, or 14 CFR part 137 landing elsewhere using dead reckoning, two navigation facilities, or a sole-source navigation device; and qualifying military flights over 50 nautical miles.
- Requester
- Wambolt
- Issued
- March 15, 1993
- Subjects
- Pilot Certification & Privileges · General Operating & Flight Rules · Air Carrier & Commercial Operations
Page 1
March 15, 1993
Mr. Troy Wambolt
Dear Mr. Wambolt:
This letter is written in response to your letter to the Northwest Mountain Regional Office, dated February 24, 1993. In your letter you requested clarification with regard to the cross-country flight requirements for an airline transport pilot certificate in Part 61 of the Federal Aviation Regulations. As you note in your letter, the cross-country flight requirements for an instrument rating, and student, private, and commercial certificates are set forth with particularity in the relevant FARs. However, FAR 61.155(b)(2)(i) does not impose a landing or mileage requirement.
There is no legal definition of the term "cross-country flight." Whether specific flight experience is cross-country in character is a technical determination to be made the FAA Flight Standards Service. It is the position of Flight Standards Service that, for pilots holding a commercial pilot certificate, the following flight experience as a required pilot flight crewmember is cross-country in character:
1. Any flight time acquired in an operation under Part 121, 123, or 135 of the Federal Aviation Regulations, when a landing is made at a point other than the point of departure, regardless of the distance between the two points.
2. Any flight time acquired in an operation under Part 91, 127, or 137, when a landing is made at a point other than the point of departure, regardless of the distance between the points, and when the flight requires the use of one of the following:
(a) Dead reckoning navigation.
(b) At least two navigation facilities.
(c) A sole source airborne navigation device.
Page 2
3. Any military flight time by a military pilot who qualifies for a commercial pilot certificate under section 61.73 based on military competency, when the flight involves a travel distance of more than 50 nautical miles from the point of departure, regardless of whether a landing is made at a point other than the point of departure. I hope that this response addresses the question that you raised in your letter of February 24, 1993. With best regards,
PHILIP G. POMPILIO
Staff Attorney
Regulations Referenced
Snapshot retrieved August 6, 2026.