High Performance Definition Vague?

[districtpilot]

Chew on this. The aircraft I currently fly is a Seneca II. Its rated horsepower is 200 HP at sea level and then 215 HP at 12,000 feet. So is this high performance?
61.31(F)(1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high performance airplane(an airplane with an engine of more than 200 horsepower),....
I think they should have written this as an engine of more than 200 rated horsepower at sea level.
Any thoughts, ideas, opinions?

 

[avbug]

From the Frequently Asked Questions listing, supplied by John Lynch of the FAA General Aviation Certification Branch ([email protected]):

QUESTION: What if you have an airplane with a 185 HP engine that is rated for 205 HP on take/off. Someone mentioned that a Navion qualifies for this. I realize that it also would be a complex aircraft. If I had a complex sign-off but no high performance am I legal?

ANSWER: Ref.§ 61.31(f)(1)(ii); You'll need to have ". . . (ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane."

As for whether a Navion that is rated for 205 horsepower on takeoff and that qualifies it, as per the definition of a high performance airplane, the rule § 61.31(f) just says a high performance airplane is ". . . (an airplane with an engine of more than 200 horsepower) . . ." If someplace in the airplane's flight manual if the engine specifications says "more than 200 horsepower" it qualifies as a high performance airplane. Section 61.31(f) doesn't qualify the definition of ". . . more than 200 horsepower . . ." it just says ". . . (an airplane with an engine of more than 200 horsepower) . . ."

If Navion's engine specifications show ". . . more than 200 horsepower . . ." it meets the definition of a high performance airplane per § 61.31(f) and the appropriate endorsement is required unless the provision of § 61.31(f)(2) is met.

For the Just-In-Case-You-Were-Curious file:

QUESTION: Does 61.31(f) apply only to single-engine airplanes? Almost all multiengine airplanes have more than 200 total horsepower. In the definition of a high-performance airplane what about a multi-engine aircraft with two engines of 200 hp? Was it your intention that a 400 hp aircraft not qualify as high-performance because it derives that 400 hp from more than one engine?

ANSWER: Reference § 61.31(f). It is says airplane. It doesn't say single-engine airplane, it doesn't say multiengine, it says "airplane" and in pertinent part, ". . . an engine . . ." As long as some place on that airplane you can find at least ONE engine that is more than 200 horsepower then it is a high performance airplane. In your example, you state that both engines are exactly 200 horsepower. Therefore, IT IS NOT A HIGH PERFORMANCE AIRPLANE.

And finally, the answer you've all been waiting for, so patiently in the wings, brought to you by our sponsors Maxwell House, Alvins Land of Bannanas, and the Letter B...

QUESTION: Is a Piper Senaca II a high performance airplane. The Piper Senaca II AFM says its engines are rated at 200 horsepower at sea level and increase in altitude up to 215 horsepower at 12,000.

ANSWER: It is a high performance airplane. The rule states, in pertinent part, “ . . . (an airplane with an engine of more than 200 horsepower) . . .” And as you stated, the Piper Senaca II is “an airplane with an engine of more than 200 horsepower.” The rule does not differentiate where the engine has to be more than 200 horsepower, it just says “an engine of more than 200 horsepower.”

 

[UndauntedFlyer]

This stuff about and engine greater than 200 HP is really funny because it makes so little sense once you read about simulators and FTDs. But of course, the FAA is not required to make sense; they are only required to make policy. That is the case here.

After all has been written here and it is determined that a naturally aspirated 200 HP Arrow or a 400 HP Seneca is not a HP airplane. By the word of the FAR that is true and I presume that is because there is not enough thrust to weight ratio to really sock-it-to-the-pilot in terms of acceleration on takeoff to give that feeling of performance that a Bonanza for example would give with 285HP engine. If you think that this all makes some degree of sense then how can it be justified in 14CFR61.31(f)(1)(i) where it says:

(No person may act as pilot in command of a high performance airplane unless the pilot) “Received and logged ground and flight training from an authorized instructor in a high performance airplane or a flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane.”

In other words, the 400 HP Seneca is no good for this but a FRASCA FTD with no motion at all is OK. Just turn the settings to BE-35.

Go figure.

 

[SkyWestCRJPilot]

I got my high performance endorsement in a Frasca or similar FTD. It was set to the settings of a Chieftain (350 hp a side).

 

[FOD]

Is this a turbocharged Seneca?

 

[districtpilot]

yes it is.