Splitting PIC Time (FAR 61 discussion)

[jrenwick]

...Your "I don't see how an instructor could make that statement" I believe is an interpretation, not a reading. (I've been recently cautioned not to "interpret" but to "read as plain language" the FARs.)....

You're right, there. I was actually speculating about how OK City might see it. As I said, I don't see how they could accept an 8710 for an MEL add-on where there was zero flight time logged in the preceding 60 days, per 61.39. I'll bet you couldn't even find an examiner who would send that in! Not for Joe Bagodonuts PPMEL applicant, anyway. Might be another matter if a PPMEL wanted a SEL add-on.

John

[GAHorn]

Of course it was under the old Pt 61, but in '73 I wanted to obtain my instrument rating added to my Comm-ASMEL certificate, but the instr. rating cost $1475 at the flight school (ACME Aviation) and I noticed the ATP-MEL only cost $1350, so I applied for an ATP-AMEL without holding an instrument rating. This made sense to me since an ATP has the same privileges as a Comm with an instrument rating. (Old 61 allowed Comm. Pilot certs. without Inst rating.)
I took the req'd trng at the approved school in a D-model Aztec and passed the written, knowledge, and practical tests and was issued the ATP, MEL, with "commercial privileges, SEL".
Here I was an ATP, ASMEL, and had never actually filed/flown an instrument flight plan.
My local GADO (predecessor to the FSDO) in HOU said I could not fly IFR when in a single engined airplane. The issuing FTW-GADO said I could. OKC trumped HOU and said I could. (Good thing too, because my first actual IFR flight occured before the final rule in the pipeline-patrol company's 172, when I found myself caught with low weather and had to get home by obtaining a clearance. Single engine and single radio with no transponder, from Houston area to FTW-Meacham, Localizer approach, break-out at 500', and a special VFR across town to land at the grass Russell Field. Lindbergh would have snubbed his nose at the risk.)

[Bruce Fenstermacher]

George there is flight time requirements that must be meet for a MEL.
They are found in 61.109 (B). Granted most of if it can be done in an SEL except the following.

61.109 (B)(1) (1) 3 hours of cross-country flight training in a multiengine airplane.

61.109 (B)(3) 3 hours of flight training in a multiengine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight;

61.109 (B)(4) 3 hours of flight training in preparation for the practical test in a multiengine airplane, which must have been performed within the 60-day period preceding the date of the test; and

I may be wrong but I believe the phrase "flight training" in the three previous paragraphs refers to actually be flying in the air, not hanger flying. I could be wrong.

[jrenwick]

Bruce,

I believe George is right about this. 61.109 specifies the aeronautical experience requirements for a student pilot applying for a Private certificate. 61.63 applies if it's a PPSEL going for MEL, because it is stating the requirements for an additional category and/or class. 61.63(c)(4) says the applicant "Need not meet the specified training time requirements prescribed by this part [61] that apply to the pilot certificate for the aircraft class rating sought...."

So the specific flight time requirements in 61.109 only need to be done the first time the applicant goes for a Private or Commercial certificate, and only in the category/class specified in that application.

[Bruce Fenstermacher]

Very interesting John. I've never put that together to mean what it appears to mean.

Darn it. Where was this forum 25 years ago when I asked the FSDO guy what were the requirements to get a PPSEL after I was already a COM Rotorcraft-Helicopter; Inst helicopter.

HIs answer. Read the FARs. It was my first contact with the Friendly Folks Association and I was not impressed and just a bit mad at his attitude.

Anyway I've been reading these FARs from time to time just like I was instructed and sure glad I have. Funny thing is the Friendly Folks Association doesn't seem to read them the way I do.

[jrenwick]

Well, as George said, Part 61 has all been rewritten since we were kids. The ink is still drying on my temporary CFI certificate, so I've been into this lately. I basically had to do the Commercial work from scratch too, because the criteria have almost completely changed from when I first did it in 1971. Stuff sneaks up on you!

John

[voorheesh]

The CFI endorsing a person for an additional class rating must "attest that the applicant has been found proficient in the areas of operation appropriate to the ratiing sought. The areas of operation involve flying skills and the only way a CFI can attest to that is to fly with and instruct the applicant. As someone pointed out, some of this "training time" must have been received within the preceding 60 days. The rules do not require a minimum training time for an additional class rating but some flight training must occur. OKC would not be the FAA office that would reject an application with no training time. The DPE or inspector giving the practical test would reject it. If there was no training time recorded, the test would not begin.

[BenWlson]

Ben you are required to establish that you are cleared through the class D (or C) airspace. Flight following and being vectored does not alleviate you of the responsibility though it would be uncommon to be vectored into or through airspace not owned by the controller without his getting prior clearance for you.

I'm very sorry for bringing this cat back out of the bag...

I'm studying for my instrument rating and am readying the Instrument Flying Handbook published by the FAA. On page 9-6 of the latest version, I find this:

"The local controller also coordinates flights in the local area with radar controllers. Although Class D airspace normally extends 2,500 feet above
field elevation, towers frequently release the top 500 feet to the radar controllers to facilitate overflights. Accordingly, when a flight is vectored over an airport at an altitude that appears to enter the tower controller’s airspace, there is no need to contact the tower controller—all coordination is handled by ATC."

[HA]

like was said before Ben, if you're talking to ATC then they'll tell you if they want you to switch frequencies and talk to another ATC facility. Otherwise they are handling it for you, don't take it upon yourself to switch to tower.

[Bruce Fenstermacher]

Ben, HA is right I wouldn't switch to tower but ask the controller you are talking to if you are cleared in to the airspace if there is any doubt.

This is usually not an issue if IFR but IFR or VFR is your responsibility as the pilot to get a clearance not the controllers.

[jrenwick]

I learned something today, relative to the original question about a PPSEL flying a Searey. If the Searey in question fits under the weight, speed, etc. limitations of a light-sport aircraft, a PPSEL can fly it as a Sport Pilot. http://www.sportpilot.org is full of information about Sport Pilot certification. To see the "FAQs," go there and click on "Ask the Expert." One of the questions answered under "Existing Pilots" is

As an existing private pilot operating as a sport pilot, how do I add a new category and class?

In other words, how do I become Sport-pilot rated in a Searey? The answer is that you need to get instruction (both land and water) and an endorsement from a Sport Pilot CFI or better, and then get a proficiency check from a different Sport Pilot (or better) CFI, fill out an FAA form, and get an endorsement from the instructor who gave you the proficiency check.

Then, still being PPSEL, you can fly the Searey on land and water, with a passenger if you want, as long as you obey the Sport Pilot restrictions listed here: http://www.sportpilot.org/learn/final_r ... opsis.html. Basically, the only things you can do as PPSEL but not as Sport Pilot are flights to further a business, and night flight.

The Sport Pilot regs are in Part 61 Subpart J, beginning at 61.301. The EAA has done a lot of work clarifying questions that aren't directly answered by the FAR text, such as this one, so the sportpilot.org site is really a more informantive source for this.

Best Regards,[/i]

[Bruce Fenstermacher]

John one significant difference between a sport pilot and a PSEL pilot is the private pilot can fly any SEL that doesn't require a type rating or other endorsement while a sport pilot must have an endorsement for every model airplane he wants to fly.

For example as a PSEL you can fly your 170, your Cub and a Champ if you had the opportunity with no further instruction assuming you had a tail wheel endorsement.

If you never had a PSEL, as a sport pilot you can't fly your 170 because it doesn't fit the light sport category. You could fly your Cub IF you had an instructors endorsement for that aircraft and you could fly a Champ if you had another endorsement for the Champ. Sport pilot training can be given by a regular CFI or a Sport Pilot CFI in the Cub or Champ.

So in your scenerio a PSEL can fly the Searey off land with the PSEL with a medical or without a medical under the sport pilot rating. But with no medical he would be restricted to sport pilot standards. If the pilot got a sea plane add on from a Sport Pilot CFI he could only operate the Searey off water under the Sport Pilot standards. But if the pilot had a medical and took his instruction from a regular CFI then he could operate any SES aircraft light sport or not with a medical as a PSES or PSEL and also operate any light sport seaplane with no further endorsements.

Or said another way once you have a private or higher rating in a category and class, you don't need an endorsement for each model of aircraft even light sport aircraft flown under the Sport Pilot rating.

Pretty easy to understand actually.

[jrenwick]

Bruce,

Yes to all that. The thing that surprised me is that you don't need to add the SES category/class to your private (or better) certificate in order to fly a light-sport seaplane as a Sport Pilot. You just need to satisfy the Sport Pilot requirements for it. Since the Sport Pilot certificate doesn't specify category and class like the others, you just need the training, proficiency check and endorsements that you would need to add any other light-sport type to what you're permitted to fly as a Sport Pilot.

Sheesh!

[GAHorn]

Bruce,

Yes to all that. The thing that surprised me is that you don't need to add the SES category/class to your private (or better) certificate in order to fly a light-sport seaplane as a Sport Pilot. You just need to satisfy the Sport Pilot requirements for it. Since the Sport Pilot certificate doesn't specify category and class like the others, you just need the training, proficiency check and endorsements that you would need to add any other light-sport type to what you're permitted to fly as a Sport Pilot.

Sheesh!

Think of Sport Pilot training in a particular airplane type ... as a "type rating" added to your Pvt-or-better certificate.

[Bruce Fenstermacher]

Ok maybe in all that a point was missed. As a Private or higher rated pilot I understand you don't need the individual endorsements for each model of aircraft when exercising the more limited privileges of a Sport Pilot.

I have a CMEL rating. If I let my medical lapse I can still fly my Cub, A Light Sport qualified aircraft under the Sport Pilot privileges with no further instruction or endorsements. I don't need any endorsements because I will always hold a higher rating than a Sport Pilot rating.

Interesting that there is no classes of aircraft in the Sport Pilot rating. So I could put my Cub on floats and let my medical lapse and fly it off water with no further instruction. But with a current medical I would be exercising at least my private privileges and need the sea plane rating. Doesn't make much sense does it.