This is a repost from our WhatsApp group but it is worth archiving here

It has come to my attention that there was a rather spirited conversation in the office the other day on an old topic: the interpretation of the long commercial cross country flight and whether it can be done VFR or IFR.

It is true that FAR 61.129 does not specify VFR or IFR for the long cross country. It doesn’t even specify day or night. However, and this is a big HOWEVER, the ACS is what the DPE will use to measure the applicants skill, knowledge, and risk management. The ACS specifies often that the skills being evaluated for a commercial pilot are for VFR flight. Our local DPEs have specifically mentioned that doing any of the commercial cross country flights as instrument flights would defeat the purpose of the commercial pilot requirements and that they would not consider a flight logged under IFR valid as prerequisite for any cross country in 61.129. I agree. 

With respect to the cross country training, the logic is that commercial applicants are further developing their skills at the commercial pilot level - not instrument pilot level. Among many other areas, this includes greater accuracy and precision with pilotage (requires VFR) and dead reckoning (VFR when using visual landmarks) as they apply to cross country piloting. The syllabus also incorporates this into the cross country training for commercial pilots. Thus, we will continue to have our applicants complete this requirement daytime VFR. The interpretation of the regulations only begins with the FAR. We are not the legal experts but, believe me, there is a lot of time invested here seeking interpretation and guidance on the regulations. Always feel free to ask for help with interpretation.

After our instructor meeting and conversations with some of you recently, I wanted to follow up on the topic of risk management. I know that some of you would love it if we just had a matrix to follow that gave you a go / no-go for any given flight. Unfortunately, that won’t happen. It isn’t that easy. Risk management is much too important of a topic to make it that simple. Those two words appear together nearly 150 times in the Private Pilot ACS, as an example. The target is moving on every single flight and there is no black and white. Each scenario is different.

My main thing that I have been focusing on, and want all of us to focus on, is the lesson for the student and where they are in their instruction. We must model and teach sound risk management techniques that will benefit the student - always. Their tolerance of risk should be gradually stretched without the mentality of ‘showing them what it’s like to fly in XYZ conditions.’ We also must be careful not to push them too far beyond their abilities knowing that you’ll save them. Ideally, by the time the student is soloed, they should be making the go / no-go decision on their own. If you have talked with me more than five minutes on this topic you know I am a big fan of Flight Risk Assessment Tools.

I’m also a huge fan of having the student make the go / no-go call then respecting that once they have a good grasp on the process. Yes, most of the time, you can probably handle the given flight scenario with a higher safety margin than the student but, again, if the student doesn’t get to flex that intellectual muscle and make the decision, they may not get to practice the sound decision making called for so often in the ACS. If the student is soloed and has solo limits, then you blast through those limits for a dual flight, what does that teach? If the student isn’t even soloed yet and the modeling is that you do really funky conditions with the CFI but the student gets stuck with more benign weather, what does that model?

There are numerous opportunities to bring no-fly days into the classroom or simulator. Keep the target moving and don’t fixate on hard numbers. Instead, fixate on the goals of your lesson with the student and think about everything you model throughout your instruction. Point the students to the FAA’s Risk Management Handbook. I’d also recommend reviewing Chapter 10 in the Aviation Instructor’s Handbook. That’s got some good info in there!