AFS-13-520-P

March 14, 2014

Mr. Mark Veney

2907 Needlewood Lane

Bowie, Maryland 2076

Dear Mr. Veney:

In your letter dated August 18, 2013 you petitioned the Federal Aviation Administration to

amend the definition of ‘cross country time’, for the purposes of meeting 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 

CFR part 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) certificate (except with a rotorcraft category rating), 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 pilot would have earned the experience appropriate for an ATP 

certificated.

As a result of the Airline Safety and Federal Aviation Administration Extension Act of 2010 

(PL 11-216), the FAA promulgated § 61.160, Aeronautical Experience – Airplane Category

Restricted Privileges rulemaking, which enables a pilot, in certain situations, to obtain an 

ATP certificate with reduced total time as a pilot based on academic experience. The FAA 

updated the cross-country flight time requirements for a restricted privileges 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 Organization (ICAO) 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 your petition for rulemaking. Accordingly, Docket No. FAA-2013-0759 is being 

closed.

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service