March 1, 2000
By John S. Yodice
A recent legal interpretation of the FAA Chief Counsel’s Office gives us an opportunity to review an important set of regulatory requirements. These requirements sometimes go unnoticed because they are one-time requirements. They also tend to get obscured by the more commonly understood "recent flight experience" requirements of FAR 61.57. You know—the ones for takeoffs and landings during the preceding 90 days in the same category and class of aircraft (see " Pilot Counsel: Recent Experience Requirements," August 1997 Pilot).
What we are talking about now are the additional training requirements for acting as pilot in command of a "complex airplane" and a "high-performance airplane." These are terms that are specifically defined in the FAA regulations.
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 defined by only one parameter; it is an airplane with an engine of more than 200 horsepower.
Obviously, there are many makes and models of airplanes that are both complex and high performance—for example, a Beechcraft Bonanza or a Cessna 210. Just as obviously, there are makes and models that fit one classification but not the other. For example, a Piper Cherokee Six is high-performance but not complex because its gear is not retractable. Many of the Mooney models are complex but not high-performance because the single engine is 200 horsepower or less. The difference is important, because even though the training requirements are similar for both classifications, meeting the requirements with respect to one classification does not meet the requirements with respect to the other classification.
With respect to a complex airplane, FAR 61.31(e) requires both training and a logbook endorsement. A person may not act as pilot in command of a complex airplane unless that person "received and logged ground and flight training from an authorized instructor in a complex airplane...and has been found proficient in the operation and systems of the airplane." The instructor must endorse the pilot’s logbook, certifying that the person is proficient to operate a complex airplane. This is a one-time endorsement that is good indefinitely. The training is usually given in an airplane, but the requirement also can be met in a flight simulator or flight training device that is representative of a complex airplane.
Similarly, subsection (f) of FAR 61.31 says that in order to act as pilot in command of a high-performance airplane, a person must have received and logged ground and flight training from an authorized instructor in a high-performance airplane. And there is also the requirement for an instructor endorsement in the pilot’s logbook. The requirement can be met in a flight simulator or flight training device that is representative of a high-performance airplane.
There is a grandfather clause that waives these requirements if a person has logged flight time as pilot in command of a complex or high-performance airplane prior to August 4, 1997. That date was the effective date of the first version of these requirements. Notice that being grandfathered in one of the two classifications does not satisfy the requirements for the other classification.
The FAA interpretation that prompted this column addresses an interesting question, and in doing so focuses on the difference between logging PIC time and acting as PIC. The situation presented to the FAA was that of a private pilot with an airplane single-engine land rating who is receiving training in a complex or high-performance airplane specifically for the purpose of complying with these additional training requirements. The question is: May the pilot log the training time as pilot in command even though the pilot does not yet meet the requirements of FAR 61.31(e) or (f)? The FAA answered the question, "Yes," such a pilot may log the training time as PIC during the time that he or she is the sole manipulator of the controls.
In reaching this answer, the FAA referred to FAR 61.51(e), which governs the logging of pilot-in-command time. It says that a recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. The term rated refers to the pilot holding the appropriate aircraft rating (category, class, and type, if a type rating is required). In the situation presented, the private pilot had an airplane single-engine land rating, and so may log the time as PIC.
The interpretation was careful to draw the distinction between acting as pilot in command and logging pilot-in-command time. This is a subtle distinction not always well understood in the pilot community, except among those involved in flight training. The FAA explained that in order to act as pilot in command (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a person must not only be properly rated in the aircraft but must also be authorized to conduct the flight. In order to log PIC time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.
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