ppl training question

[jnmeade]

Certified IFR means it can legally work in the system, but the AOI still prohibits flight in IMC. 91.327 says you must follow the AOI.

It's in the Operating Limitations

Now there is a path within the rules to get to the private pilot checkride with out a medical. You have to get your sport pilot first, then you can finish all the other requirements while flying as a sport pilot.

You can do it this way, but you don't need to. You can get a CFI to sign you off for solo work as a sport pilot student and accomplish any solo private pilot requirements that way. Dual requirements - no need for any medical or driver's license.

As was pointed out elsewhere, you need the third class medical to fly the PPL checkride, be we all agree on that.

Again, as has been said before, if doing it this way the CFI must be a Subpart H.

[jnmeade]

4) You can always find a CFI to go along and be legal.
5) It would be nice to fly high-performance aircraft (which you can rent or own) and have the CFI come back and say, "Oh, as usual he just took me for a ride. It's nice to relax sometimes." Plus it's good to have the company and help with the chores.
6) If you are really that good and competent you can always find someone to sit in the right seat to fill the legal requirements.

Be just a little cautious in doing this, lest the FAA decide that the CFI is actually being a charter pilot. Now, I will be the first one to say that there is little chance of a problem, but remember, the guy who says he won't sue you never does - his widow does.
Where the problem can arise is if you are going to various locations and conducting business there or even pleasure to the point where the main issue is not your training but your transportation. You don't fly from St. Louis to Chicago especially to train but to attend the reading of your great aunt's will. As I said, the FAA almost never finds out about these kinds of things and when they do it's almost always as the result of an accident or someone ratting you out. For example, the charter outfit at the local airport tells the FSDO that the CFI is performing Part 135 work without a certificate.
The real message of this little discussion is simply to apply the Three S's. That is, when a neighbor's dog starts chasing your sheep, you shoot, shovel and shut up. It's the latter part that is our downfall.

[designrs]

Thanks jnmeade. I was not aware of the training vs. commercial charter regulations. Something to keep in mind. If I ever get to that point I'd probably be actually training anyway.

There's probably a lot of gray area.
Suppose 2 students said to a CFI, "We want to do extended cross country training to the Bahamas for a week" (maybe that's still training)?

But if a guy said, "Hey, I want to do an extended cross country to the Bahamas, maybe three times this year, and take the wife & kids too." (that's probably way over the line into charter)?

On a related note, what does Cirrus do with their program, I forget exactly what they call it but it is basically "Buy the plane, use it for business trips with our CFI, and turn every flight into a training opportunity". Guess that CFI has to be commercial and plane insured for charter & training?

[3Dreaming]

Certified IFR means it can legally work in the system, but the AOI still prohibits flight in IMC. 91.327 says you must follow the AOI.

It's in the Operating Limitations

Now there is a path within the rules to get to the private pilot checkride with out a medical. You have to get your sport pilot first, then you can finish all the other requirements while flying as a sport pilot.

You can do it this way, but you don't need to. You can get a CFI to sign you off for solo work as a sport pilot student and accomplish any solo private pilot requirements that way. Dual requirements - no need for any medical or driver's license.

As was pointed out elsewhere, you need the third class medical to fly the PPL checkride, be we all agree on that.

Again, as has been said before, if doing it this way the CFI must be a Subpart H.

The problem is I am the CFI that is signing it off, and I know it is not right. I sure wouldn't want one of my students to have problems down the road because I tried to let them skirt the rules. I don't want any problems with the FAA either. If they are a sport pilot student I have no problem signing them off to solo in the LSA. If the student decides after solo they want to get their private they need to get the medical before they complete any additional solos requirements, and not right before the checkride. If they are going for the private from the begining they are going to have to get the medical anyway, so you just as well follow the regs and get it before solo in this case as well.

[3Dreaming]

Jim, I tried to look for the answer on when the "No Flight in IMC" went into effect, and couldn't find it. I found several references from September of 2010 that said the comitee had forwarded it for approval with expected acceptance from the FAA by the end of the year. I didn't find anything beyond that. I guess I'm getting old because I was thinking that happened earlier than that. The CTLS up there is about the same vintage as mine, and that was from before 2010.

[drseti]

Tom, I recall that a handful of SLSAs were approved for IMC before 2011. Then, that loophole got closed, but not retroactively. So, there are a few SLSAs still able to fly in IMC, but no more will be so approved.

[jnmeade]

Tom, I recall that a handful of SLSAs were approved for IMC before 2011. Then, that loophole got closed, but not retroactively. So, there are a few SLSAs still able to fly in IMC, but no more will be so approved.

I saw the owner, Tim Busch, at an AOPA Safety Meeting tonight and he confirmed that his CTLS was legal for IFR flight into IMC. He ordered the plane with the required equipment, including a 430. It is correct that this option is no longer in effect.

[jnmeade]

The problem is I am the CFI that is signing it off, and I know it is not right. I sure wouldn't want one of my students to have problems down the road because I tried to let them skirt the rules. I don't want any problems with the FAA either. If they are a sport pilot student I have no problem signing them off to solo in the LSA. If the student decides after solo they want to get their private they need to get the medical before they complete any additional solos requirements, and not right before the checkride. If they are going for the private from the begining they are going to have to get the medical anyway, so you just as well follow the regs and get it before solo in this case as well.

No more. I'm sick of discussing this. You are misreading the regulation. Hopefully anyone reading this far will have enough doubts about what you say to investigate further and make up their own mind.

[3Dreaming]

The problem is I am the CFI that is signing it off, and I know it is not right. I sure wouldn't want one of my students to have problems down the road because I tried to let them skirt the rules. I don't want any problems with the FAA either. If they are a sport pilot student I have no problem signing them off to solo in the LSA. If the student decides after solo they want to get their private they need to get the medical before they complete any additional solos requirements, and not right before the checkride. If they are going for the private from the begining they are going to have to get the medical anyway, so you just as well follow the regs and get it before solo in this case as well.

No more. I'm sick of discussing this. You are misreading the regulation. Hopefully anyone reading this far will have enough doubts about what you say to investigate further and make up their own mind.

Jim, my opinion is based on the way the FAA has done things for years before the sport pilot was introduced. The FAA medical has always defined what privileges you could exercise. If you are a commercial pilot and your 2nd class medical was isseud more than 12 calendar months before you can only exercise private pilot privileges. You have always had to have at least a 3rd class medical to exercise the privileges of a student pilot certificate while seeking private pilot privileges in an airplane.

I have shown the specific wording that I have based my opinion on in previous post. You keep saying I am misreading it, so show me the quotes from the regulations and highlight the important parts. Prove me wrong, and I will gladly change my opinion. If you don't I assume you couldn't find the quotes. I guess we could put it to FAA legal, but then we might find out it is like sub part "K" instruction time not counting towards the private pilot certificate. Tom

[drseti]

Two rules about putting questions before FAA Legal:

1) If there's any chance they might give you an answer you're not going to like, don't open up that can of worms.

2) If there's any chance they might give you an answer everybody else is not going to like, don't open up that can of worms.

[3Dreaming]

Two rules about putting questions before FAA Legal:

1) If there's any chance they might give you an answer you're not going to like, don't open up that can of worms.

2) If there's any chance they might give you an answer everybody else is not going to like, don't open up that can of worms.

I'm not going to ask the FAA for a ruling, because I think I know what the answer will be. Unlike the ruling on the sport pilot instruction time not counting towards a private pilot certificate, the intent on the use of a drivers license for a student pilot to meet the sport pilot training requirements is pretty clear to me.

[drseti]

I left one out:

3) If there's any chance they might give you an answer, don't open up that can of worms

[jnmeade]

You keep saying I am misreading it, so show me the quotes from the regulations and highlight the important parts. Prove me wrong, and I will gladly change my opinion. If you don't I assume you couldn't find the quotes. I guess we could put it to FAA legal, but then we might find out it is like sub part "K" instruction time not counting towards the private pilot certificate. Tom

I've shown this a half a dozen times and am not going back over it. Your mind is closed and it is a waste of my time.

Sayonara on this subject.

[dstclair]

Tom,

A simple question. If a student pilot is seeking a PP under a subpart H CFI then later changes his mind to go for an SP, does the applicable training/solo time already completed apply towards the SP? Conversely, if another student was seeking his SP under the same instructor then changes his mind to go for a PP, does the applicable time apply towards his PP? This assumes all training is done in an SP-eligible plane.

What if the student doesn't know what rating they want so they train under a subpart H CFI, in an LSA and solo without a medical? Can they apply this time towards a PP?

Basically, you're equating the word seeking with intent. Check your Websters -- seek does not imply intent in any of the 5 definitions I read.

[3Dreaming]

Tom,

A simple question. If a student pilot is seeking a PP under a subpart H CFI then later changes his mind to go for an SP, does the applicable training/solo time already completed apply towards the SP? Conversely, if another student was seeking his SP under the same instructor then changes his mind to go for a PP, does the applicable time apply towards his PP? This assumes all training is done in an SP-eligible plane.

What if the student doesn't know what rating they want so they train under a subpart H CFI, in an LSA and solo without a medical? Can they apply this time towards a PP?

Basically, you're equating the word seeking with intent. Check your Websters -- seek does not imply intent in any of the 5 definitions I read.

As for applying time flown I think you should be OK as long as you are following the regulations. As I have said before the point in you training that you decide or start to complete the additional requirements for the private pilot is the point you should have a medical to exercise your student pilot privileges.

Let me explain my thought process to get to my view. For this I want to just talk about airplanes because some other aircraft have different requirements. I have been a CFI for 23 years, and a pilot for 33. So my view is from an "Old Timers" point of view. Prior to 2004 when Sport Pilot was introduced you needed a 3rd class medical to exercise the privileges of a student pilot certificate even if you were flying a J3 Cub. This is the way it had always been. I know I had to have a medical when I soloed 34 years ago. In 2004 the FAA added subpart "J" Sport pilot and "K" Sport Pilot Instructor to part 61 of the regulations. When they did this they needed to make a changes to may other regulation that were already in place, and there are some places that still need fixed. The FAA already had subpart "C" for student pilots, and your still a student pilot regardless of what rating you are trying to get. An area they needed to change was 61.23 that deals with medical certificates. The 2 new subparts needed the added use of being able to use a drivers license to exercise the privileges. Then the stepped back and said how does a student pilot that wants to be a sport pilot get there without getting the medical required by 61.23 (a), (2), (iii) that they have always needed. They allowed those students wanting to become a sport pilot a way to get there without a medical and using their drivers license by adding 61.23 (c),(1),(i). That is why I think the exemption only applies to those training to be a sport pilot and not those training to be a private pilot. I'm not just looking at the words, but the fact that they were added because of new sport pilot rules. The other thing to remember is the medical certificate that is required is base on what you are doing, and not what kind of aircraft you are flying. Case in point is you would need a commercial pilot certificate and a 2nd class medical if being paid to tow ultralight or light sport gliders with a LSA. You just can't say if your flying a LSA you don't need a medical.