July 1, 1998
By John S. Yodice
Almost a year ago we went through a major overhaul of Part 61 of the Federal Aviation Regulations. This is the part that deals with pilot and flight instructor certification. In the overhaul, there were some important changes made to the "recent flight experience" requirements of FAR 61.57. You may recall that the changes included, for the first time, the logging and performance of "holding procedures" and "intercepting and tracking courses through the use of navigation systems" to meet the six-month instrument currency requirements. The changes even included what could be a relaxation of the instrument currency requirements. The requirement for six hours of instrument flight every six months was eliminated. Now the only time required is the time necessary to perform the holding and tracking procedures and the minimum six instrument approach procedures. We explained those changes last year (" Pilot Counsel: Recent Experience Requirements," August 1997 Pilot).
What we haven't yet explained is one other change, specifically the additional (maybe) training requirements that a pilot must meet to operate complex airplanes and high-performance airplanes.
Actually, this change is more of a clarification than a substantially new requirement. The old requirement for training and experience in high-performance airplanes is retained, but it is now broken into two requirements: one for complex airplanes, and one for high-performance airplanes. So it is mostly a change in nomenclature, although there are some relatively minor changes that might affect you. There is an update in the "grandfather" dates. The requirement is now imposed on ATP certificate holders. There is a change related to multiengine airplanes. And, there is a new requirement for ground instruction.
The old requirement did relate to the two different kinds of airplanes but gave them a single name — high-performance. Some pilots met the requirement for one kind of high-performance airplane, thinking that it qualified them for both. It did not. The requirement now is more clear.
However, if you met the old requirement for both, and your logbook proves it, you most probably will meet the new one. If you don't, the newly phrased FAR 61.31 (e) and (f) bear some study.
What's the difference in the two terms of the new regulation? A complex airplane is defined as one that has a retractable landing gear, flaps, and a controllable-pitch propeller; or, in the case of a seaplane, flaps and a controllable-pitch propeller. A high-performance airplane is now defined as one with an engine of more than 200 horsepower. In the old version of the regulation, an airplane would be high-performance if the total horsepower of its engines exceeded 200 horsepower, even if each of its engines was 200 horsepower or less.
Clearly, a specific make and model airplane can be both. Take, for example, a Cessna 210 or a Beechcraft Bonanza. Just as clearly, a specific make and model airplane can be one but not the other — for example, a 200-horsepower Piper Arrow or a Cessna Caravan.
Here's the newly phrased requirement. Before you may act as the pilot in command of a complex airplane, FAR 61.31(e) requires that you must have received and logged ground and flight training from an authorized instructor in a complex airplane (or flight simulator or flight training device). You also must have a one-time endorsement from the instructor that certifies that you are proficient to operate a complex airplane.
The requirement for a high-performance airplane tracks this requirement exactly. Before you may act as the pilot in command of a high-performance airplane, FAR 61.31(f) requires that you have the logged ground and flight training and the one-time logbook endorsement.
These requirements are prospective. The training and endorsement are not required if you have logged flight time as pilot in command prior to August 4, 1997, the effective date of the Part 61 overhaul. The grandfather date of the old regulation was November 1, 1973.
Suppose you have logged time prior to August 4, 1997, in an airplane that has retractable gear, flaps, and a controllable pitch prop, but does not have an engine of more than 200 horse-power; does the grandfathering cover the high-performance, as well as a complex airplane? The answer is no. The answer is also no the other way around: If you are grandfathered in a high-performance airplane that does not have retractable gear, flaps, and controllable prop, you are not grandfathered in a complex airplane.
If you have any doubt about your qualifications to be pilot in command of complex and high-performance airplanes, now is a good time to take a look at your logbook in light of the newly phrased requirement. Flight instructors and pilots newly qualifying need to be sure that both terms are used in the logbook endorsement if both terms apply.
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