Since 61.51 allows more than one pilot to log PIC time at the same time, it’s tempting to think that the same holds true for logging cross country time. If. for example, a rated flying pilot and a non-flying safety pilot who is acting as PIC may both log PIC time, can’t they both log cross country time as well?
For the most part, the answer is no. The FAA Chief Counsel has given an unequivocal thumbs down to more than one plain vanilla Part 91 pilot logging cross country time on the same cross country flight (there is probably an exception for CFIs during dual cross country training flights but even that is not completely clear at this point). The various opinion letters cite different rationales, but ultimately, it comes down to this:
only the pilot who performs the takeoff , en route portion, and the landing
on a cross country flight may log the cross country time
at least when the flight is not a “true” 2-pilot operation (see the Glenn Opinion below).
So, for example:
- A safety pilot may not log cross country time because he or she is not a required crewmember for the entire flight. 2009 Gebhart Opinion.
- When pilots switch sole manipulator duties in the air, neither may log the cross country time. 2009 Hilliard Opinion.
Other opinion letters in the series include the 2009 Glenn Opinion, which reviews multiple similar scenarios. It is Glenn which allows both pilots in aircraft or Part 135 ops required more than one pilot to log cross country time because both are required crewmembers for the entire flight.