Takeoffs and Landings in non-LSA towards passenger currency

Paul Hamilton is one of the first persons to become a DPE (Designated Pilot Examiner) for sport pilots. As a full-time author and sport pilot expert, he writes books and produces DVD's for Aviation Supplies and Academics (ASA). Now Paul has graciously agreed to answer your questions here. Thanks Paul! For more information about Paul, please visit www.Paul-Hamilton.com and www.Sport-Pilot-Training.com.

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AviatorCrafty
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Takeoffs and Landings in non-LSA towards passenger currency

Post by AviatorCrafty »

I may be doing some flying with my old CFI in a 172 just for fun and a little bit of an intro to flight instructing/instructing (won't be counting it since he hasn't been an instructor for 24 months) in general since I'm getting my AGI for now, but will eventually get my CFI-S and I'll be training with an appropriate CFI for that when the time comes. My question is would I be able to count the landings in the 172 towards my passenger-carrying currency? I read on the AOPA sport pilot page that a sport pilot could do a flight review in a non-lsa so I thought maybe these would count too but just making sure.
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drseti
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

I can't cite an FAR on this, but I believe passenger currency TOLs have to be done as PIC. Since you can't be PIC in a non-LSA without a CFI onboard or a solo endorsement (which your friend can't give you as a lapsed CFI). So, the answer would be no.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

I think I found the answer on FAR 61.57(a):
(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required),
If the category and class of aircraft in which you wish to carry passengers is SLSA, Airplane, the TOLs would more count.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by FastEddieB »

Here's what the regs say:

[1]..no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and—

(i) The person acted as the sole manipulator of the flight controls; and

(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel.[/i]

So, you'd have (i) covered. Now regarding (ii) the question is, are a C172 and a Light Sport in the same category and class. This still confuses me sometimes with the introduction of Light Sport, but I think the Professor has a pretty good handle on this and can opine.

Note: composed and posted before the Professor responded.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

FastEddieB wrote:the question is, are a C172 and a Light Sport in the same category and class. This still confuses me sometimes with the introduction of Light Sport, but I think the Professor has a pretty good handle on this and can opine.
Oh, the professor can always opine. Whether he's right or wrong, Eddie, is another question. :wink:

The situation is confusing, because there are three different definitions of Category and Class - one for training, another for maintenance, and a third for pilot privileges. If in doubt as to which applies, my tendency is to go with the most restrictive interpretation, until shown otherwise.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by AviatorCrafty »

drseti wrote:I can't cite an FAR on this, but I believe passenger currency TOLs have to be done as PIC. Since you can't be PIC in a non-LSA without a CFI onboard or a solo endorsement (which your friend can't give you as a lapsed CFI). So, the answer would be no.
Realized I may have added some confusion here, he is an active CFI, just hasn't held it for the required 24 months to count for CFI instruction. I also thought I couldn't log PIC while dual in a non-LSA.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by bryancobb »

Paul & Crafty,

Unless things in Part 61 have changed, Category = Airplane, Class = SEL. The AOPA says a Sport Pilot can do their Flight Review in a non-LSA. That would make me believe ANY recurring requirements for currency in LSA's can be done in non-LSA's of the same Category and Class.

Off AOPA Q&A page..."Do I need to perform the flight review in a light-sport aircraft?

No. According to 14 CFR 61.56, a flight review must be performed in an aircraft for which the pilot is rated. Rated is interpreted as category and class."
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

I respectfully disagree with AOPA on this one. As stated in an earlier post, according to FAR 1.1, Category and Class have three different sets of meanings, one that applies to aircraft certification, the second to pilot privileges, and a third that deals with maintenance privileges. Bryan, the definition you cited, ASEL, is correct for a standard airworthiness certificate. But, for Sport Pilot privileges, the category is "Light Sport," and the Class is "airplane." (This is what it says on the Sport Pilot Certificate.) Since you must take a flight review in an aircraft you're rated for, a Sport Pilot must take it in an LSA.

As for the question about passenger currency, it does stand to reason that the same would apply.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by bryancobb »

On the 8710-11 Application for Sport Pilot's License, the "categories" are:
* Airplane
* Rotorcraft (gyro only)
* Glider
* Lighter-Than-Air
* Weightshift Control
* Powered Parachute

Paul Hamilton's website aligns with this.

Also with class being:
* land
* sea
Bryan Cobb
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

Well, that kind of makes sense. On the back of my Pilot Certificate, it says:
Commercial.Pilot
Airplane Single Engine Land; Instrument Airplane

Sport Endorsement(s) Airplane Single Engine Sea
The only thing that doesn't make sense to me is the reference to Single Engine in my Sport seaplane endorsement, since there are no multi-engine Sport Pilot privileges!
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by bryancobb »

"Airplane Single Engine Sea"

Even within the Sport Pilot/LSA Realm...Aircraft are placed in CATEGORIES (Airplane) and in CLASSES (SES).

Like you said, you will never find a multiengine LSA but every LSA fits in some category, and some class.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by MrMorden »

It's even murkier with an E-LSA, as "Experimental" is its own category. The Category on my CT's airworthiness certificate is "Experimental".

Does that mean I'm good to go if I do my currency checks in a Cozy, which is experimental but decidedly NOT an LSA?

Thanks FAA! :lol:
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

MrMorden wrote:It's even murkier with an E-LSA, as "Experimental" is its own category. The Category on my CT's airworthiness certificate is "Experimental".
That's exactly what I meant at the outset, about the FARs having different definitions of Category and Class.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by drseti »

For those who haven't seen them, here are the General Definitions from FAR 1.1:
Category:

(1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a broad classification of aircraft. Examples include: airplane; rotorcraft; glider; and lighter-than-air; and

(2) As used with respect to the certification of aircraft, means a grouping of aircraft based upon intended use or operating limitations. Examples include: transport, normal, utility, aerobatic, limited, restricted, and provisional.
Class:

(1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a classification of aircraft within a category having similar operating characteristics. Examples include: single engine; multiengine; land; water; gyroplane; helicopter; airship; and free balloon; and

(2) As used with respect to the certification of aircraft, means a broad grouping of aircraft having similar characteristics of propulsion, flight, or landing. Examples include: airplane; rotorcraft; glider; balloon; landplane; and seaplane.
So, your aircraft's airworthiness certificate may define it as Category: Light Sport (or Experimental, or maybe, Experimental, operating Light Sport), and Class: Airplane. But your Pilot Certificate may authorize you to fly Category: Airplane, and Class: Single Engine Land. (Of course, if you hold only a Sport Pilot certificate, or are operating under Sport Pilot privileges, any Airplane, Single Engine Land you fly also has to be of Category: Light Sport, and Class: Landplane.)

Now, getting back to the original question, it is clear that a Sport Pilot practicing takeoffs and landings in a non-LSA cannot possibly be Pilot in Command. But the Currency rules state that the person flying for currency must be Sole Manipulator of Controls [14 CFR 61.57(a)(1)(i)]. So, can you legally log as Sole Manipulator of Controls and not be Pilot in Command? I maintain that this is possible only if the Pilot in Command is a current Certified Flight Instructor (in which case, you would log Dual Received). This would therefore preclude a Sport Pilot going up with his or her non-CFI buddy in a non-LSA and satisfying passenger currency requirements.

But I'm sure there are other opinions on this one. Fire at will, folks.

(BTW, the reason AOPA said a Sport Pilot can do a flight review in a non-LSA is probably that the PIC in that case is the CFI, and a flight review requires a minimum of one hour of flight instruction, which would require an instructor on board, and thus allow the applicant to log Dual Received. So, I withdraw my objection to the AOPA opinion.)
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Takeoffs and Landings in non-LSA towards passenger currency

Post by 3Dreaming »

drseti wrote: So, your aircraft's airworthiness certificate may define it as Category: Light Sport (or Experimental, or maybe, Experimental, operating Light Sport), and Class: Airplane. But your Pilot Certificate may authorize you to fly Category: Airplane, and Class: Single Engine Land. (Of course, if you hold only a Sport Pilot certificate, or are operating under Sport Pilot privileges, any Airplane, Single Engine Land you fly also has to be of Category: Light Sport, and Class: Landplane.)
Paul, I don't think that Category should be Light Sport. I think it should be Airplane Single Engine Land/sea, Rotorcraft Gyroplane, Ect. The fact that you can only fly a light sport aircraft is a simply a limitation, and not reflective of the TYPE of aircraft you are certified to fly.
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