AFS - 13 - 520 - P

March 14, 2014

Mr. Mar k Veney 2907 Needlewood Lane Bowie, Maryland 2076 Dear Mr. Veney : Inyour letter dated August 18 , 201 3 yo u petition ed the Federal Aviation Administration to amend the definition of ‘cross country time’, for the purposes of me eting the aeronautical experience requirements for an airline transport pilot certificate, as defined in § 61. 1(b) of Title 14, Code of Federal Regulations (CFR) . When the FAA responds to petitions for rulemaking, it must follow the requirements of 14 CF R p art 11, particularly

those guidelines for processing petitions for rulemaking found in § 11.73. As stated in that section, the FAA uses the following criteria when making a decision as to whether or not to amend current regulations based on a petition for rulemaking: 1) the immediacy

of the safety

or security

concerns the petition raises; 2) the priority

of other FAA issues; and 3) the resources we have available to address these issues. While your petition does not meet the criteria for consideration at this time, we offer the following as background on this issue. The current regulation, in pertinent part for the purposes of meeting the aeronautical experience requirements for an airline transport pilot (ATP) certi fi cate (except with a rotorcraft category r ating), defines “ cross - country” as a straight - line distance of more than 50 nautical miles from the original point of departure . This petition for rulemaking would add language to the definition of “cross - county” to allow certificated flight instructors , who are instructing in an aircraft that he/she is appropriately rated, to be able to log cross - county time towards their airline transport pilot certificate any time the aircraft is flown to an airport and lands, to a full stop, at an airport different than the airport of departure. The petitioner’s justification is that a rule change would allow for “an increase in public interest by expanding the pool of potential ATP applicants and would promote an environment of continuing education and professionalism for flight instructors.”2

The FAA has consistently viewed the 50 nautical mile straight - line distance for cross - country as necessary

to ensure experience in pilotage, dead reckoning, and navigation involving the use of electronic navigational aids, radio aids, or other navigational equipment. The FAA believes that these skills are imperative to an airline transport pilot and any deviation would negatively

affect safety . The proposed change would remove the minimum distance and would not ensure that a pilo t would have earned the experience appropriate for an ATP certificated. A s a result of the Airline Safety and Federal Aviation Administration Extension Act of 2010 (PL11 - 216), the FAA promulgated § 61.160, Aeronautical Experience

– Airplane Category Restricted Privileges rulemaking , which enables a pilot, in certain situations, to obtain an ATP c ertificate with reduced total time as a pilot based on academic experience. The FAA updated the cross - country flight time requirements for a restricted privilege s ATP certificate with 200 hours of cross - country flight time instead of the 500 - hour requirement of § 61.159(a) . The FAA notes that the requirement for 200 hours of cross - country flight time is consistent with the International Civil Aviation Organizatio n (I CAO) standard for an unrestricted ATP certificate. For the reasons stated earlier and in accordance with 14 CFR § 11.73 , we will take no further action on yo ur petition for rulemaking . Accordingly , Docket No. FAA - 2013 - 0759 is being closed . Sincerely , /s/ John Barbagallo Acting Deputy

Director, Flight Standards Service