MEI training question.

[avbug]

Going by what you *think* the FSDO, or a particular inspector at the FSDO might do, or even what you're told at the FSDO level, is always a bad idea. Even if you get it in writing, because it carries no weight and is absolutely indefensible in the event that you are violated...what you get from the FSDO has no more value than the opinion of the man on the street.

14 CFR 1.1 provides the definition of Type as follows:

“(1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a specific make and model of aircraft, including modifications thereto that do not change its handling or flight characteristics. Examples include: DC-7, 1049, and F-27; and
(2) As used with respect to the certification of aircraft, means those aircraft which are similar in design. Examples include: DC-7 and DC-7C; 1049G and 1049H; and F-27 and F-27F.
(3) As used with respect to the certification of aircraft engines means those engines which are similar in design. For example JT8D and JT8D-7 are engines of the same type, and JT9D-3A and JT9D-7 are engines of the same type.”

This is an important insight into clarification regarding what is considered when discussing make and model...aircraft which have been modified, but which have not changed flight characteristics, may be considered of the same make and model. However, in the case of the Navajo to Cheyenne II, as mentioned above, significant changes in the handling and flight characteristics have occured...it's certainly not the same make and model.

You cannot go by the Type Certificate Data Sheets, as a number of aircraft have spawned various makes and models established on the original type certificate data sheet. The cherokee line is a great example. Even within the TCDS, a common statement in the notes is that engine changes are acceptable, so long as they're the same make and model spelled out in the TCDS...no varance there without a supplemental type certificate, except where the TCDS specifically permits and cites multiple engines on the same make and model.

When endorsing a student pilot for solo flight in make and model, a Cessna 150 is not the same model as the 152; separate endorsements, or reference to both aircraft specifically, is required. They act similiarly. They look the same. They are different models of the same make.

Look at line 2 of For 8100-2, the Standard Airworthiness Certificate. It will spell out the specific make and model for your aircraft. Compare the airworthiness certificates for your Apache and Aztec. You'll find two different models...they are not the same. Their flight characteristics have been changed by modifications such as the nose extention, weight changes, engine changes, speeds, etc.

The context of the regulation must be considered. In this case, considering 14 CFR 61, we're discussing privileges related to category, class, type (specifically related to a type rating), and also make and model. Make is the manufacturer, and model is the model spelled out in the airworthiness certificate.

Issues regarding holding category and class and type ratings as appropriate, are separate for this discussion, however. Unless you hold a category/class/type on your (pilot) certificate, you can't provide instruction in the aircraft toward a certificate or rating...nor in a multi engine airplane for the same unless you have five hours make and model.

Realistically, you ought not be atempting to provide instruction in a multi engine airplane unless you have a minimum experience level in the aircraft. The regulation is really there for your protection. And that of the student. Five hours isn't much. Significant differences can exist between different aircraft that appear similiar...instructors should have experience in the aircraft in which they instruct, and the Administrator specified this in particular with multi engine airplanes.

Don't look for loopholes. While the regulation specifies make and model for training toward a certificate or rating, trying to skate by when doing a flight review when you lack the experience in type does no one a favor. It doesn't serve professionalism, nor safety. Get some experience in the type aircraft before you offer your services in it. Anything less is unprofessional, regardless of w(h)eather the regulation might permit you to do so. No regulation exists which states that you cannot set your sights higher. Professionalism demands that you do so.

 

[nosehair]

When it comes to the make and model argument, a good litmus test is "Would you call the FSDO and tell them what you did?" If the answer is "Yes" then go ahead and do what you want.

Hmmm...I would never call the FSDO and tell them what I did.



Well, that's a crack at being funny, but seriously folks, calling the FSDO on these gray areas is never a good idea. The only thing good that might happen is if you can get them to point out the specific regulation which makes it crystal clear, but getting an opinion from a FSDO inspector does not make it legal, and saying "The FSDO told me so" does not make it legal. Sometimes they might quote an AC which would hold a lot of weight, but the regulation stands alone and is always subject to the judge's interpretation.

"Make & Model"...that's what it says. Somtimes there are significantly dangerous differences in model, and sometimes you have to look for them.

I think that a 150 is not much different than a 152 and, really, I think the judge would have to look high and low to find enough difference that affected the accident to rule that a "model" difference was a contributing factor. But I still would not let a new student fly solo in a 152, who has trained in a 150, without the additional endorsement. There is also "procedure" to follow.

But I also think that a FSDO Inspector would not attemt to "violate" a student on a ramp check in a 152 who only has a 150 endorsement. He might try (appropriately) a "stern talking to", but not an actual full blown violation.

And then there are the insurance sharks to deal with, and they make a living out of finding little loop-holes like this to at least "put off" paying for as long as the legal system will work for them.

 

[unreal]

Okay, here's a question.

Is a Turbo Seminole the same model as a normally aspirated Seminole? One is a PA44-180T, and the other is just a PA44-180. You'd think that they would be the same model, but using avbug's example of different "handling and flight characteristics," I'm not too sure. One will happily climb to FL200 and do 200 KTAS, and will climb to 15,000 feet single-engine if lightly loaded. The other will basically slowly drift towards earth if an engine gets cut.

The model numbers are very similar, and most of the time the two aircraft handle just the same, but the performance numbers are very different. Same model, or no?

 

[nosehair]

Nope. Turbo is obviously very different. Common sense tells me that.

I can see in this thread how the "legalese" has taken over common sense in our industry.

Sometimes a model change doesn't make much difference, such as C-172A, B, C, etc., and sometimes just a letter change makes a big difference, as in this case.

 

[avbug]

This being a forum on regulation, and this being a thread regarding a regulatory question, you don't suppose that the finer points of regulation are not only germain, but important?

Perhaps we should abolish all regulation and replace it with one that says "use common sense," because we have nothing but case after case in the NTSB files of pilots filled with common sense.

Dýa think?

 

[nosehair]

aaall righty, 'bug, ya got me there. never shudda used the word "common sense". That was inappropriate.

Lemme try that again:

The difference between turbo and normal aspirated engines is a big enough difference in characteristics to be obvious to a judge or insurance agent, or student, for that matter, that you should consider them different make/model. I mean, they are. Like a Model T and a Model A.

But then, sometimes, the difference is so slight, as in a C-172A and a C-172B, that you have to look hard to find a difference, and in this case poses no danger or lack of flight handling experience. This decision must be made by careful analysis of the differences. If you cannot determine the difference, then you don't know what the difference is, and should not attempt flight in an unknown quality.

However, if the difference is only in the shape of the instrument panel, or a key starter instead of a pull starter or some such minor change, then I don't see a problem with instructing in the different model.