Ask a Flight Instructor

Archive for the ‘FAA’ Category

Nick has two questions about currency:

If I do 3 full stop landings at night, do I have to do 3 T&G’s and/or full stop landings in the day time time to fly as PIC during the day or do my night landings take care of the day requirement?

Do I have to complete 3 FS landings in both a tailwheel aircraft and non tailwheel aircraft to be current to act as PIC at night in both types of aircraft?

To answer your first question, your three takeoffs and landings to a full stop at night will also fulfill the recent flight experience requirements for day currency. If you never flew during the day, and did a full stop landing at night weekly, you’d still be legal to carry passengers day or night. Remember, you aren’t maintaining currency to act as PIC, you’re staying current to carry others in your airplane.

As for your second question, to be current in a tailwheel airplane, you must do landings in a tailwheel airplane. There is no such limitation on tricycle gear (or bicycle gear, for that matter). It’s like the old rectangle/square rule—tricycle currency doesn’t apply to tailwheel aircraft, but tailwheel currency works for tricycle aircraft. If you want to dig through the regs, FAR § 61.57 (a)(1) and (b)(1) is the place to look. There’s a lot in there, but most of it is aimed at pilots with instrument ratings or with jobs flying jets.

It’s easy to get lost in the FARs, as most instructors will agree. Clayton asks a question that I had myself a few months back:

I cannot find a clear explanation in the regs saying that a CFI w/asel privileges can teach sport pilot students. Everything I am seeing is referring to someone that wants an initial CFI with sport pilot ratings. I would think that an instructor that already has an ASEL certificate satisfies all the requirements for sport pilot. Am I thinking about this correctly?

Clayton, you’re right—as a CFI, you can teach Sport pilot students. The place to look is FAR § 61.193—flight instructor privileges, which states:

A person who holds a flight instructor certificate is authorized within the limitations of that person’s flight instructor certificate and ratings to give training and endorsements that are required for, and relate to:

(a) A student pilot certificate;
(b) A pilot certificate;
(c) A flight instructor certificate;
(d) A ground instructor certificate;
(e) An aircraft rating;
(f) An instrument rating;
(g) A flight review, operating privilege, or recency of experience requirement of this part;
(h) A practical test; and
(i) A knowledge test.

The key part of the regulation is that you can provide training required for a pilot certificate, not a specific certificate. Even if you only hold a Commercial rating yourself, as a CFI you can provide training towards an ATP certificate; you can likewise train a Sport pilot. The only requirement is that you’re training somebody within the categories and classes listed on your pilot certificate. You will need to become familiar with FAR § 61 subpart J. Like Private pilots, CFIs can also use their driver’s license in lieu of a medical, and operate as a CFI-SP, limited to Sport rules and regulations.

A CFI teaching Sport pilots will also need to check out FAR  § 61.419, which further explains that you’ll need a small amount of ground and flight instruction – similar to a flight review – before you can teach Sport topics. There is an endorsement for each part of the training; once you’ve been endorsed, you’re good to go.

Whether you’re an instructor or a student, you can get more Sport Pilot information at the EAA’s sportpilot.org.

Mike is looking into regaining his currency and asks:

I’m thinking about doing the Recreational Pilot flight review instead of the Private Pilot this time around. I haven’t been able to fly much in the last 15 yrs. but want to restart. Can I do the Rec Pilot and then get a medical and redo a check to Private later?

The short answer is that it doesn’t really matter. The long answer is that since it’s been a while, it could be that you’re actually thinking of Sport pilot, rather than Recreational. This is totally understandable—the FAA doesn’t always make it easy to determine requirements for, and privileges of, different types of pilot certificates. However, recreational pilots still must hold a current medical, as required by the FAA, and (as of 2006) there were fewer than 250 of them left in the country. While there are some caveats, a sport pilot does not need to hold a medical.

However, a flight review is a flight review, regardless of what pilot certificate you hold, and it must consist of at least one hour of flight and one hour of ground. You could do your flight review in a light sport aircraft without a medical, and that would allow you to exercise sport pilot privileges, but you’ll also have to learn new regulations that apply only to sport pilots, and you’d also have to operate within some (potentially significant) limitations.

Given that relatively flew FBOs offer Light Sport aircraft for rental or for training, it may make more sense to simply get a Third Class medical and stick with the Private certificate, and not necessarily in that order. You can certainly start the flight review process without a current medical. I’ve done several flight reviews with pilots who haven’t flown (at all) in over 10 years, and the amount of time it takes them to get used to flying the airplane—and, often more significantly, new regulations—is fairly reasonable, ranging from 2 and 10 hours of flight and ground time.

Just received another good question from Todd who asks:

I passed my IFR written and failed the checkride. The written expires in a few days. Is it extended until I re-take the flight test?

Well Todd, I might have some bad news for you.  Your practical test must be completed within 24 calendar months of the completion of your written test.

I looked through the Designated Pilot Examiners’ Handbook, the Practical Test Standards and of course the FARs looking for an exception for you but couldn’t find anything to help you out. The only exception that I did find for this rule is found in 61.39(b) which allows an applicant to take the ATP practical with an expired written so long as he or she is employed by a 121, 125, or 135 carrier (with some further requirements).

The same FAR (61.39) makes it pretty clear when that the knowledge (written) test is to be done:

Pass the required knowledge test within the 24-calendar-month period preceding the month the applicant completes the practical test, if a knowledge test is required;

So hurry up and complete your practical before your written expires!  Once you get that instrument rating be sure to…

Fly Safe!

This question comes from Sylvia:

This came up recently at the airfield coffee shop: what qualifies a pilot to act as a safety pilot? Specifically in terms of the 3 take-offs and landings every 90 days in order to stay current … is it ok to take a pilot with you for safety? Or do you have to do have a qualified instructor if you are nervous about doing your circuits solo, having gone out of date?

Safety Pilot.  As you hang around an airport, you’ll hear this term quite a bit and if you listen to how this word is used you’ll notice that the term has taken on a life of it’s own.  Some people use it to define flying around the pattern with another pilot friend or has someone who works the radios on a cross country flight.  If you are looking for a safety pilot, there is even a Safety Pilot Club website!  However,  I think it is important to begin with the official definition and designation from the FAA.

A safety pilot is mentioned only in a couple of places in the regulations.  The primary reg being 14 CFR 91.109 .  In this reg. you find the official definition and designation of a safety pilot.  The reg says:

(b) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

The only other regulation that mentions a safety pilot is 61.51 which deals with logging of instrument time.  In summary this reg says that you have to record the name of the safety pilot if required by the aforementioned 91.109.

So basically, a safety pilot has one purpose:  Look out the window for traffic when the other pilot isn’t!

So getting back to the question from Sylvia.  It would be my interpretation that you cannot use a safety pilot to get current on landings.  Why?  Because unless they are required for flight in simulated instrument conditions they are not a required crewmember and then would fall into the category of passenger, not pilot.  And in order to fly passengers, you of course, need to meet the requirements of 61.57 – recent flight experience.

Some may argue that you could use a Safety Pilot if the Safety Pilot was fully qualified and current to be PIC and allowed the pilot to take the controls for the 3 required landings.  My question however is then, how would that time be logged?  You couldn’t log it as PIC in your log book (only one crewmember required) and you couldn’t log it as dual received or SIC.

I think the only answer the regulations provide is that you either have to fly by yourself or take a CFI in order to meet the recency requirements of 61.157.   I promise I’m not just saying that because I am a CFI   Again, this is just my humble interpretation and that a $.50 still won’t buy you a coffee.

I think this stresses the need to stay current and the continuing maintenance aspect of becoming a pilot, whatever your level.  I don’t know about you, but I get rusty after not flying for two weeks, I can’t imagine how rough it would be after 3 months!

So make sure you are flying frequently and always

SAFE!

The FAA has just released a new web tool / service called “Lessons Learned” and it is worth checking out.  The idea behind the site of course, is learning lessons from aviation accidents.  And although the site focuses mainly on commercial transport category accidents, there is still something to be taken away for even an ultralight pilot.   Think of “Lessons Learned”  has “I Learned About Flying From That” but with a airliner theme (and online instead of in print).

http://accidents-ll.faa.gov/

Here’s a good example.  Take for instance Eastern Airlines Flight 401 that crashed into the Florida Everglades when the autopilot was accidentally disconnected and went unnoticed as the flight crew tried to diagnose a unsafe landing gear position indicator.  The FAA website now breaks this accident snyposis down so that we can see the chain of events that lead to this horrific accident.  For instance, a lesson learned would be “false assumptions” regarding who (or what) is flying the plane.  At the time of this accident, there was no CRM (or crew resource management) training given by any airline.  If there had been, it might have addressed procedures and policies for this kind of malfunction and delegated who had responsibility for flying the airplane while another crew member focused on the problem.

I’d encourage you to visit this new website and let me know what you think.

Stories like these remind us all that we need to work hard to…

Fly SAFE!

Here’s a good question concerning logging of pilot time that I received from Don:

Can one log time as a safety pilot? If so, under what heading, eg, PIC, or a separate category “safety pilot“? Thanks.

First a quick review.

A “safety pilot” is a required flight crew member when another pilot is flying under simulated or actual instrument conditions in order to meet the IFR recency requirements of 14 CFR 61.57.  FAR 61.57 requires that in order to file and fly on a IFR flight plan you have to be instrument current, which means that within the past 6 months you have logged 6 approaches, holding and intercepting and tracking procedures.  If for some reason, those 6 months pass, the pilot has another six month grace period in which he can fly with a safety pilot under simulated instrument conditions in order to become fully instrument current again.  In simulated instrument conditions the pilot wears a view limiting device that blocks the pilot’s view of the outside world so that he can only see the instrument panel (we call them foggles).  This can present a problem for other airplanes as the flying pilot is unable to see where he is going!  The FAA found a solution to this problem by creating the safety pilot.  A safety pilot is simply that, someone who looks out for other airplanes (safety) while the other pilot is flying blind “under the hood”.

Instrument Training Glasses “Foggles”

So how do you log time flown as a safety pilot?

Because you are a required crew member when flying with a pilot under simulated instrument conditions the FAA allows you to log this time as SIC or second-in-command (61.51(g)).   If you agree to be the “acting” PIC you and the other pilot could both record the time as PIC but only when the other pilot is under the hood and the other pilot is the “sole manipulator of the flight controls.”   In order to be the “acting PIC” you will have to make sure that you meet the full PIC requirements for that flight and aircraft, which will include any necessary medical, category, class, type, recency and ratings requirements.

Don’t forget!  If you use a safety pilot to gain instrument currency the FAA requires that you record the name of the safety pilot in your logbook.

As always…fly safe!

Here is a question I received this morning regarding required equipment for over water flights:

I’d like to fly to the Florida Keys. Of course, we all know the FAR about flying high enough to get to land power off. I can’t find the rule about flying over water and what the requirements are for equipment. Can you help? I did find a bit about it in the ATP section but what applies to private? I know people fly it all the time and just want to be on the right side of this. Thanks.

Thanks for the question. The funny thing is that I asked myself this exact same question this past week when preparing for an upcoming trip. I know that airline and charter operations are governed by regulations in 14 CFR 121 and 135. But where do the regulations say specficially what equipment is required to be on board for overwater flights for flights operated under 14 CFR 91?

The two most common quoted regulations for over water equipment requirements are 91.205 and 91.509. 91.205 states that:

If the aircraft is operated for hire over water and beyond power-off gliding distance from shore, approved flotation gear readily available to each occupant and…at least one pyrotechnic signaling device.

91.509 which is titled, “Survival equipment for overwater operations.” has similar requirements. Paragraph (a) & (b) says:

(a) No person may take off an airplane for a flight over water more than 50 nautical miles from the nearest shore unless that airplane is equipped with a life preserver or an approved flotation means for each occupant of the airplane. (b) No person may take off an airplane for flight over water more than 30 minutes flying time or 100 nautical miles from the nearest shore, whichever is less, unless it has on board the following survival equipment: (it then goes on to list the equipment)

Here’s the interesting thing though. FAR 91.205 (b) [12] applies only to “for hire” operations and FAR 91.509 falls under 14 CFR 91 subpart F which is for large (over 12,500 lb) and turbine-powered multiengine airplanes and fractional ownership programs. I am honestly having a hard time finding a federal aviation regulation that mandates any kind of required survival equipment to be on board for over water operations if you are in a small airplane (12,500 lbs or less) not operating for hire. I specified FAA reg. because I know that certain states like Alaska mandate certain survival equipment to be on board at all times. Also certain countries, like the Bahamas, mandate flotation devices to be on board for over water flights as well.

So what it is a prudent and safe pilot to do?

If the regulation requires for hire operations and turbine powered airplanes to have flotation gear than I think it would be wise to operate your aircraft in a similar manner. Although purchasing a flotation device for each passenger may seem costly, it would be a small price to pay in the unfortunate event that you would need them. If you are worried about the cost and don’t fly in an area where you would utilize them that often, you can also consider renting them. I know a lot of FBO’s in south Florida offer over water survival kits, including personal flotation devices or life rafts for rent. If you are planning a fuel stop at a particular airport I would inquire about the availability and cost of renting this equipment. If you are considering purchasing any kind of over water survival equipment, one of the go-to-places for many operators is Eastern Aero Marine out of Miami, Florida. They have been in business since 1952, so they know a thing or two about the business. You can visit their website at http://www.theraft.com. They also have developed a nice table where you can see what equipment is required to be on board for your particular operation. The required equipment table covers everything from small airplanes to transport category aircraft in an airline operation.

Again, excellent question and let me know what you decide to do. My best advice for you would be to…

Fly Safe (and prepared).

Here is a flight training question from Frank:

Recently forced to retire from an airline career due to age 60; had 22 years of military flying before that, including appx 1500 hours of instuctor time in various military aircraft.
Do you know if the FAA has changed their rules to allow the military instructor time to count toward a CFI rating? Am going to pick up the CFI, but it would be nice to cut the program down some if the FAA gives credit for the instruction time.

Hi Frank, great question.

The federal regulations dealing with flight instructor certification are listed in subpart H of 14 CFR 61.  When you read through the requirements for becoming a flight instructor, the only flight experience requirement listed is that you have 15 hours of PIC in the category and class you are going to instruct in.  The other requirements to becomming a CFI, according to 14 CFR 61.183 are:

• 18 years of age (you meet that one!)
• Read and write English (check)
• Commercial or ATP pilot (not a problem)
• Instrument Rating (you have it)
• Logbook endorsement for a written test on the fundamentals of instruction.
• Pass the aforementioned written test (the only way out of this written test is if you are already a flight or ground instructor, have a teaching certificate or you are employed as a teacher at an accredited college or university).
• Logbook endorsement saying you are competent and have instructional proficiency in stalls awareness and spins (entry and recovery)
• Logbook endorsement for the practical test
• Pass the required practical test

The other regulation that may apply here (because you are an ex-military pilot) is FAR 61.73 which allows you to take your military certificates and apply for the FAA equivalent of those certificates.  However, that is limited to the commercial pilot certificate, instrument rating and any other category and class ratings you may have as a military pilot.  There is nothing mentioned in this regulation about applying military flight instructor experience to apply for a FAA flight instructor certificate.  I can only guess at the FAA’s reasoning behind this, but I would think it has to do with the vast differences in the training mindset and cultural environment between military and civilian flight training.

I think your making a great decision to become a flight instructor.  General aviation needs flight instructors, especially those with experience and wisdom that a lifetime of career flying brings.  With a little bit of searching, you can find a job that pays pretty well too.  Granted not as much as you were making at the airlines but you won’t go hungry.

Thanks again for your question and….

Fly Safe.

This question comes from Karl:

I’m thinking about buying a retractable gear aircraft with 250 HP engine from a CFI who lost his medical. I am certified in high perfomrance AC (C-182) but I only have under 2 hrs of retract time.

I’m interested in taking a flight in the AC and he tells me that since I have a current medical and rating in a high performance AC, that I could be the legal PIC, even though I am not checked out in this plane. He would fly along with me, of course.

This doesn’t seem right to me. What do you think?

Hi Karl.  Thanks for your question. There are a few things that you need to think about here 1) Legality and 2) Insurance and 3) Safety.

Legality

According to FAR 61.31paragraph f, in order to act as a pilot in command of an aircraft which has an engine of more than 200 horsepower you must have received and logged ground and flight training from an instructor AND you must have an high performance endorsement from that instructor in your logbook.  In addition, if you want to be pilot in command of a complex aircraft, FAR 61.31(e) says that you must also have ground AND flight training in complex airplanes with logbook endorsement.  And just as a reminder, a complex aircraft has flaps, retractable gear and a controllable pitch propeller.  So that means if the airplane you are wanting to buy is a complex, high performance airplane you need 2 separate logbook endorsements (not ratings).  As a side note, these endorsements are one time events.

Insurance

Every insurance company and policy is different.  I would recommend checking with the policy on the aircraft to make sure you meet the open pilot provisions.  It might require you to have so much time in the make and model or it may require a proficiency check in the make and model by an authorized instructor.  Like I said, every policy is different.  It is best to call and talk with the insurance company or broker if you have any questions about your policy.

Safety

If you feel uncomfortable flying this airplane with this other pilot, don’t do it, even if is “legal”. Find a pilot or instructor who meets all the provisions above PLUS someone you feel comfortable flying with.  There are countless stories of pilots getting themselves killed flying unfamiliar aircraft.  In case you missed it,  here is my personal story of flying a unfamiliar airplane.

Hope this helps.  Let me know what you decide to do and if you buy it.

Fly Safe (and legal)