Instrument Time and Cross-Country

Key Conclusion

The FAA interprets that the aeronautical experience requirements of §61.65(d)(1) and §61.65(d)(2) may be accumulated concurrently, provided each flight independently satisfies the requirements of both provisions.

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Primary Legal Issue

Whether a pilot may:

• log instrument training time and PIC cross-country time during the same flight; and
• apply that flight toward both requirements for an instrument rating.

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Rule (CFR)

Cross-country experience

• §61.65(d)(1): Requires 50 hours of cross-country flight time as PIC.

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Instrument experience

• §61.65(d)(2): Requires 40 hours of actual or simulated instrument time.

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PIC logging

• §61.51(e): A rated pilot may log PIC while acting as the sole manipulator of the controls.

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FAA Interpretation

1. The requirements are not sequential

The FAA interprets that:

• §61.65(d)(1) and §61.65(d)(2)
• do not have to be completed in any particular order.

→ The regulations do not require 50 hours first and 40 hours afterward.

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2. One flight may satisfy both requirements

The FAA interprets that:

• A flight conducted under actual or simulated instrument conditions
• may also count toward the 50-hour PIC cross-country requirement,

provided the flight independently satisfies the requirements of both sections.

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3. PIC time still depends on the logging rule

The FAA notes that concurrent credit is available only if:

• the pilot may properly log PIC under §61.51(e),
• such as when acting as the sole manipulator of the controls in an aircraft for which the pilot is rated.

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4. Cross-country definition still applies

The FAA explains that instrument flight time counts toward the cross-country requirement only if the flight also meets the definition of cross-country time.

For §61.65(d)(1), this includes:

• a landing at an airport at least 50 NM from the original departure point.

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5. Practical limitation

The FAA also notes that, although concurrent credit is permitted,

• it is unlikely that all instrument training would qualify as cross-country time,

because basic instrument instruction is typically completed before cross-country training begins.

This observation describes a typical training progression rather than creating an additional regulatory requirement.

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Implication (Limited)

The interpretation permits concurrent credit, but it does not eliminate the need for each flight to satisfy the independent requirements of:

• PIC logging,
• cross-country definition, and
• instrument experience.

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Common Misunderstandings

• ❌ The 50-hour requirement must be completed before instrument training.
• ❌ Every instrument training flight counts as cross-country.
• ❌ Concurrent credit removes the individual requirements of §61.65.

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One-Sentence Summary

The FAA interprets that cross-country PIC time and instrument time may be credited concurrently when the same flight independently satisfies the requirements of both regulations.

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Reference

• Legal Interpretations - Gordon_2006_Legal_Interpretation