300NM CPL requirment

[JohnPork]

Hello! I have my PPL but my flight school does not offer CPL training. however i do want to get my 300nm out of the way asap. can i do my 300nm cpl requirement without being under 'supervision' from a flight school or instructor. eventually i will find a flight school who offers this but i cant currently do to my location. i assume if i can i just will have to write it in my PTR when i do find my school. In the CARS it doesnt mention the solo part of cpl time building does not require you to be under supervision with someone who has a instructor rating. i assume its like this bc you are now licensed and can make your own decisions. Thanks everyone!

[Big Pistons Forever]

See CAR 421.30. Your question is unambiguously answered there

[waterruddersup]

Your 300NM flight doesn't have to be "under supervision" or the part of a CPL training syllabus. It's just a requirement for the license. But, do take the time to do it right, challenge yourself a bit - file flight plans, perhaps request flight following, land at some new airports, etc. It's an expensive requirement, so best to learn some new things and familiarize yourself with how flying usually is. (It's not just ripping circuits.) Have fun.

[mmm...bacon]

You have a PPL. You’re good to go.

FFS, DO NOT just go 300.0001NM from your point of departure! If you are going to be a commercial pilot, this is pretty much the only time in your career that you’ll have an aeroplane at your disposal without someone else telling you where, when, how high, and how fast. Save up a bunch of money, rent a plane and head N/S/E/W, wherever your fancy takes you…fly 20, 30, 40 hours off. You’ll learn *WAY* more about real-life decision making in that much time doing unfamiliar XC than you will in 3 or four times that time farting around in the practice area, or doing the ‘prescribed’ 301NM XC that seems to be in vogue at most FTUs nowadays.

Good luck.

[Fly0nTheWall]

You have a PPL. You’re good to go.

Your 300NM flight doesn't have to be "under supervision" or the part of a CPL training syllabus. It's just a requirement for the license.

Nope and nope. OP, please read the CARs as mentioned above. It is pretty clear, and would need to be recorded in a PTR.

Edit for clarification - everything in CARs 421.30 4(a)(i) can be done whenever/wherever you like and is just recorded in your personal logbook. Everything in CARs 421.30 4(a)(ii) must be done under the training/supervision of a flight instructor. Everything in 4(a)(ii) counts towards the experience requirements in 4(a)(i) though, which is why I think there's some confusion some times.

[rookiepilot]

I made mine a multi day, over 1500 NM trip (one way radius) , 40 hours, entirely in the US, small and large airports, (to the far SW). Learned a ton, planned it carefully, got a little chunk of mountain, and high altitude takeoff experience too.

[digits_]

You have a PPL. You’re good to go.

Your 300NM flight doesn't have to be "under supervision" or the part of a CPL training syllabus. It's just a requirement for the license.

Nope and nope. OP, please read the CARs as mentioned above. It is pretty clear, and would need to be recorded in a PTR.

Edit for clarification - everything in CARs 421.30 4(a)(i) can be done whenever/wherever you like and is just recorded in your personal logbook. Everything in CARs 421.30 4(a)(ii) must be done under the training/supervision of a flight instructor. Everything in 4(a)(ii) counts towards the experience requirements in 4(a)(i) though, which is why I think there's some confusion some times.

In reality though most instructors would be ok with putting a previously flown 300 nm trip in the PTR and signing off on it.

Note that the cars say flight training solo time. It's only the dual requirements that require instructor supervision.

You could make a case flight training is always under supervision, but it's not explicitly defined.

[Big Pistons Forever]

CAR 400.01 (1)

solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,

CAR 421.30
30 hours solo flight time including:
(amended 2006/12/14)
(I) 25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure; and

The 300 mile Cross Country is flight training and thus has to be under the supervision of a flight instructor and signed for in the PTR. If any 300 nm flight would count the CAR would not specify that the 300 nm Cross Country had to be a "solo" flight.

I would not personally sign a PTR for a guy/gal who showed up and said they had already done the flight.

[Big Pistons Forever]

I made mine a multi day, over 1500 NM trip (one way radius) , 40 hours, entirely in the US, small and large airports, (to the far SW). Learned a ton, planned it carefully, got a little chunk of mountain, and high altitude takeoff experience too.

Good for you. I always highly encourage prospective CPL's do do a real cross country. 2 of my CPL students flew all the way across Canada. They got all of their build up time done quickly and more important learned a ton of real world flying skills.

[digits_]

CAR 400.01 (1)

solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,

Let's quote the full definition, shall we?

solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,

(a) in the case of a pilot, the flight time during which the pilot is the sole flight crew member, and

(b) in the case of a student pilot permit holder, the flight time during which the holder is the sole occupant of an aircraft while under the direction and supervision of the holder of an instructor rating for the appropriate category of aircraft; (temps de vol en solo)

Note that the requirement of supervision is specifically only listed as a requirement in (b). A PPL holder would fly under (a).

The 300 mile Cross Country is flight training and thus has to be under the supervision of a flight instructor

Says who? I couldn't find a single CAR that requires flight training an sich to be under supervision. Or any definition of 'flight training'.
As quoted above, the car definition of 'solo time' goes out of its way to specify which solo time needs to be under supervision.

The whole concept of 'solo time under supervision' for a CPL student which is a PPL holder doesn't make much sense.
Let's say our PPL holder CPL student shows up for his 300 NM flight. Crappy weather, no prep. Instructor says 'No, I won't sign off on this'. Student can go 'ok cool beans, but I'm going anyway'. He's a PPL holder, he doesn't need instructor approval to fly.
All of the solo time for a CPL (except perhaps the night stuff), can be done with a PPL. Solo time under supervision only makes sense if you're practicing something for which you have no license (eg, as a PPL student, or night training).

[rookiepilot]

I made mine a multi day, over 1500 NM trip (one way radius) , 40 hours, entirely in the US, small and large airports, (to the far SW). Learned a ton, planned it carefully, got a little chunk of mountain, and high altitude takeoff experience too.

Good for you. I always highly encourage prospective CPL's do do a real cross country. 2 of my CPL students flew all the way across Canada. They got all of their build up time done quickly and more important learned a ton of real world flying skills.

At least, I suggest do more or different than driving the 401, as so many around here do, going to Kingston and then Montreal. BORING.

Go north, change regions, see some different weather. Turn off the GPS, one way, Navigate the old way with map, watch, and landmarks at 1500, 2000 AGL. Even 1000 AGL, down south. (Chart towers carefully)

Its cool, and might save your butt one day.

On the return, navigate through every single page on the 430, if you have one. Learn it thoroughly while droning alone in cruise.

[DHC-1 Jockey]

Nope and nope. OP, please read the CARs as mentioned above. It is pretty clear, and would need to be recorded in a PTR.

Edit for clarification - everything in CARs 421.30 4(a)(i) can be done whenever/wherever you like and is just recorded in your personal logbook. Everything in CARs 421.30 4(a)(ii) must be done under the training/supervision of a flight instructor. Everything in 4(a)(ii) counts towards the experience requirements in 4(a)(i) though, which is why I think there's some confusion some times.

You might be confused as well.

I did my 300 NM X-country after my PPL but before starting my CPL. I flew to Oshkosh one summer as PIC. The following year, I started my CPL and when we began the discussions about the X-country with my instructor, I mentioned that I did a flight to Oshkosh the year prior and wondered about the distance. I knew the instructor personally, and he was already aware that I made the flight, which was backed up by the flight school journey log.

We then got out the maps, measured the distance and found it was about 350 NM. That was good enough for him, so we added the flight to my PTR, the instructor signed it and that was good enough for Transport.

So, it might be possible to do your 300 NM X-country "unsupervised" and prior to officially starting your CPL.

[Aviatard]

CAR 400.01 (1)

solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,

CAR 421.30
30 hours solo flight time including:
(amended 2006/12/14)
(I) 25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure; and

The 300 mile Cross Country is flight training and thus has to be under the supervision of a flight instructor and signed for in the PTR. If any 300 nm flight would count the CAR would not specify that the 300 nm Cross Country had to be a "solo" flight.

I would not personally sign a PTR for a guy/gal who showed up and said they had already done the flight.

I would not argue that a 300 nm cross country flight is not flight training, but I don't think your interpretation is correct. The definition of flight training in the CARS is here but does not say that it has to be done under the supervision of an instructor:

flight training means a training program of ground instruction and airborne training that is conducted in accordance with the flight instructor guide and flight training manual applicable to the aircraft used; 

Here is the CPL dual requirement statement under 421.30:

(A) 35 hours dual instruction flight time, under the direction and supervision of the holder of a Flight Instructor Rating — Aeroplane, including ...

And here is the solo requirement statement under 421.30:

(B) 30 hours solo flight time including :
(I) 25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure;

Note that the solo requirement does not mention being under the supervision of a flight instructor, while the dual requirement does. Based on this, I would conclude that it isn't necessary to be signed out by an instructor for the 300 nm flight.

[Conflicting Traffic]

Note that the solo requirement does not mention being under the supervision of a flight instructor, while the dual requirement does. Based on this, I would conclude that it isn't necessary to be signed out by an instructor for the 300 nm flight.

It's tempting to accept this interpretation (and realistically, TC turns a blind eye when 300 NM trips are not supervised). But it ignores the requirements of CAR 405.31 and .32:

405.31 No person shall commence a training flight unless the trainee has received from the flight instructor
(a) a pre-flight briefing; and
(b) where new flight exercises are to be conducted during the flight, preparatory ground instruction.

405.32 Before the commencement of a training flight, the flight instructor who will conduct or supervise the training shall
(a) authorize the training flight; and
(b) receive an acknowledgement of that authorization from the trainee.

The 300 NM X/C is a training flight per CAR 421.30. So the omitted supervisory requirement in CAR 421.30 notwithstanding, there is a requirement for supervision stipulated in other regulations.

There may be an argument to be made that the 300 NM X/C *should* be an experience building exercise, and not formal training. But as the regs are currently written, it's training and therefore requires instructor supervision.

[DHC-1 Jockey]

There may be an argument to be made that the 300 NM X/C *should* be an experience building exercise, and not formal training. But as the regs are currently written, it's training and therefore requires instructor supervision.

How does this explain that Transport accepted my PTR, even though I did my 300 NM X-country before I started my CPL training? I even believe the PTR dates weren't in exact order.. ie a bunch of "actual" training flights towards my CPL in 2005, then my 300 NM X-country (which happened in 2004) and then resumption of my CPL training flights in 2005.

Did I just get lucky, or is it possible that the 300 NM flight can be done any time prior to applying for the CPL license, whether it was done as part of an "approved training syllabus" or simply for pleasure?

[CpnCrunch]

The 300 NM X/C is a training flight per CAR 421.30. So the omitted supervisory requirement in CAR 421.30 notwithstanding, there is a requirement for supervision stipulated in other regulations.

It doesn't say anywhere that the solo time is "flight training". (Edit: actually it does, I just missed it).

[Conflicting Traffic]

It doesn't say anywhere that the solo time is "flight training".

Sure it does:

following the issuance of a private pilot licence — aeroplane by Canada or another contracting state, have completed 65 hours of commercial pilot flight training in aeroplanes consisting of a minimum of:

[Conflicting Traffic]

How does this explain that Transport accepted my PTR, even though I did my 300 NM X-country before I started my CPL training?

Did I just get lucky, or is it possible that the 300 NM flight can be done any time prior to applying for the CPL license, whether it was done as part of an "approved training syllabus" or simply for pleasure?

As noted

... realistically, TC turns a blind eye when 300 NM trips are not supervised

Also, if the flight is in the PTR, TC accepts that as evidence that the training was done (that's what the 'T' in 'PTR' stands for -- it's not a logbook, it's a Training Record). The fact that the training wasn't done in accordance with the CARs just means that the PTR is inaccurate (and possibly fraudulent) and you / your instructor didn't get caught. This happens a lot because getting caught would require an audit of the PTR v. the DFLs (and maybe other records). I think the odds of that happening are pretty low. But not getting audited/caught doesn't mean that you were in compliance with the regulations as written.

I even believe the PTR dates weren't in exact order.. ie a bunch of "actual" training flights towards my CPL in 2005, then my 300 NM X-country (which happened in 2004) and then resumption of my CPL training flights in 2005.

Being out of order makes the PTR a PITA to review, but otherwise it's no big deal. It should be a red flag that record keeping wasn't done properly and some training might not have been conducted properly (case in point: this discussion), but assuming that's not the case and it's a documentation error (and the misordering is just an artifact of correcting the error), it's not likely to cause a problem.

[DHC-1 Jockey]

It seems this exact discussion was held back in 2012, and there was no clear consensus as to the answer either, but others did their X-country before officially starting their CPL or being "supervised" and it as allowed by Transport. Someone made the interesting point that if this was not allowed, that there must be dozens if not hundreds of CPL's that should never have been processed due to this error, leading to the answer that it must be allowed because surely Transport would have caught on to it and put a stop to it:

I don't see any requirement for the solo time to be under supervision of a flight instructor. Sure it has to go in the PTR as it is part of your commercial pilot training, but why would it have to be supervised by an instructor?

A good point which sent me searching thorugh the CARS...I think the answer is buried in 405.32.

Authorization of Training Flight
405.32 Before the commencement of a training flight, the flight instructor who will conduct or supervise the training shall
(a) authorize the training flight; and
(b) receive an acknowledgement of that authorization from the trainee.

Pilot Training Record
405.33 (1) A person who conducts flight training for the issuance of a private pilot licence, a commercial pilot licence or a flight instructor rating - aeroplane or helicopter shall, for each trainee, maintain a pilot training record that meets the personnel licensing standards.
(2) On request from a trainee receiving training for the purposes referred to in subsection (1), the person responsible for maintaining the trainee's pilot training record shall
(a) certify the accuracy of the entries; and
(b) provide the trainee with the record.
(3) When a trainee has completed flight training, including all of the tests and written examinations required pursuant to Subpart 1, the person who conducted the flight training shall forward the trainee's pilot training record to the Minister.


I think, strictly speaking, that the PTR and flight sheets at the school must document entries for the solo time acquired in pursuit of the license and that it isn't "training" unless it is documented in that way.

I don't read it that way at all. I've added some emphasis above. 405.32 applies to an instructor who conducts or supervises flight training. We have already seen in the CARs that the Private Pilot Licence requires all hours to be conducted or supervised by a flight instructor:

421.26 Requirements - Private Pilot Licence - Aeroplane
(4) Experience

(a) An applicant shall have completed a minimum of 45 hours private pilot flight training in aeroplanes under the direction and supervision of the holder of a Flight Instructor Rating - Aeroplane. A maximum 5 of the 45 hours may be conducted on an approved aeroplane simulator or flight training device.

(b) The flight training shall include a minimum of:

(i) 17 hours dual instruction flight time, including a minimum of 3 hours cross-country flight time and 5 hours of instrument time of which a maximum of 3 hours may be instrument ground time; and

(ii) 12 hours solo flight time, including 5 hours cross-country flight time with a flight of a minimum of 150 nautical miles which shall include 2 full stop landings at points other than the point of departure.

But for the commercial pilot licence:

Requirements - Commercial Pilot Licence - Aeroplane
(ii) following the issuance of a private pilot licence — aeroplane by Canada or another contracting state, have completed 65 hours of commercial pilot flight training in aeroplanes consisting of a minimum of:

(A) 35 hours dual instruction flight time, under the direction and supervision of the holder of a Flight Instructor Rating — Aeroplane, including:

(I) 5 hours night, including a minimum of 2 hours of cross-country flight time;

(II) 5 hours cross-country, which may include the cross-country experience stated in subclause (I); and

(III) 20 hours of instrument flight time in addition to the experience stated in subclauses (I) and (II). A maximum 10 hours of the 20 hours may be conducted on an approved aeroplane simulator or synthetic flight training device.

(B) 30 hours solo flight time including:

(I) 25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure; and

(II) 5 hours solo flight time by night during which a minimum of 10 takeoffs, circuits and landings were completed.

Again no mention of supervision for the 30 hours solo, so 405.32 doesn't apply.

As for 405.33, it applies to a person who conducts flight training, not supervises. The certifying of the solo portion doesn't amount to much. In my case most of the solo time in the PTR was flown at odd hours of the night from an airport 50 nm from the airport my instructor worked at. He had no idea when or where I was flying.

[local_yokel]

As you can see from the discussion here. Probably best to figure out where you will eventually do your CPL and see what they/ or your freelance instructor have to say on the matter. Its basically up to your instructor/ school to decide if they will accept a 300NM flight that is/ is not under their supervision. If you do know where you will train to do your CPL then go ask them to "supervise it" for you, what criteria they want you to meet, then go flying.

[BGH]

Back in the late ‘80’s I had lots of cross country & float time & decided to upgrade my license to a commercial rating - this exact subject came up so I phoned transport & they said at the time to just hilight at least 1 of the cross country flights in my logbook that met their requirements for the 300nm.
When I sent my logbook in for certification of time the person checking my time they put a post it in the front of my logbook saying that I had more than enough cross country time to fill the requirements.
Ripping around BC in my 185 on straight floats was unsupervised by any instructor & the time was accepted.

Daryl

[ShawnR]

This has been discussed more than once here. When I did my CPL a few years ago, I had moved a couple of planes back and forth to Southern Ontario, so had the trips in my book. But it was just under a PPL. Because it seems to be a debatable topic, and I, like anyone asking this question, wanted a definitive answer, I emailed T/C. Not hearing back from them too quickly, I phoned. After getting a reply to my email, I found I had two different answers directly from T/C! My opinion is that it might come down to who reviews your CPL application. Sad, but true. You could wait to see how that goes, and possibly start a discussion with them if they will not accept your trip completed outside of your CPL training, or wait till you actually are connected with an instructor. At that point, you will be flying something, and get it in then. Signed off by your instructor and after you started your official CPL training. Then that is not so debatable.

But, this is just one more opinion in this thread. Here is one other thread about the same topic. Good luck with it!

http://www.avcanada.ca/forums2/viewtopi ... 2#p1225362