The FAAï¿½s 1997 change to part 61 added language that limits the number of aircraft that qualify for use in "high performance" aircraft training. The regulatory language utilized in the FAAï¿½s 1997 rewrite of part 61 limits the applicability of the definition of a "high performance" aircraft to airplanes with an engine greater than 200 horsepower.
Under the pre-rewrite definition of a high performance aircraft a pilot operating a PA-34-200 (Piper Seneca) twin-engine airplane could log that time as high performance time because the airplane had a total of more than 200 horsepower (400 horsepower to be exact). However, after the 1997 rewrite of part 61 this same pilot could not log high performance time in a PA-34-200 simply because each engine does not produce more than 200 horsepower. Oddly, under this same definition, a pilot operating an aircraft of comparatively lower total engine performance such as the 210hp Mooney 231 (M20K) would be required to receive additional training and can log that time as high performance time. This lack of consistency in the application of the definition of a high performance aircraft has been the cause of considerable confusion in the general aviation community and has brought about a shortage of aircraft that qualify for use in high performance flight training activities.
AOPA opposes the change to the regulatory language contained in the April 1997 rewrite of part 61. The new regulatory language of ï¿½61.31(f)(1) places a substantial burden on some airman and flight schools by limiting the number of "high performance" aircraft that may be utilized for flight training activities.
FAA letter of denial, July 26, 1999 (requires Adobe Reader)
AOPA petition for rulemaking, March 13, 2000
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