Safety Pilots are Not Allowed Cross Country Experience

Think twice the next time you log a “time share” flight or act as a safety pilot on a cross country flight.  According to legal interpretations from the FAA dated in 2009, only the pilot flying is allowed to log cross country time under § 61.  As explained in the Gebhart Interpretation:

Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time.  Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight.

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GPS Flight Planning – WAAS Going On?

Symbol for Alternate Minimums Not AuthorizedIt’s time to review the rules for planning an IFR flight with GPS navigation.  Maybe the airplane has an old receiver without WAAS capability.  Or maybe the rules have changed too many times to remember the current limitations.  Where to find the answers?

Destination Alternates – Without WAAS

I’m starting with destination rules, because most flight plans begin with that basic question:  Where to go and how to get there?

2013 – If you were aware of these rules a couple years ago, you knew to look them up in Published NOTAM No. GEN13000.  That notice expired in 2014.

2014 – AIM 1-1-18(g)(1) superseded the obscure notice, making the alternate airport rules somewhat easier to find.

2015 – The published 2015 FAR/AIM is already obsolete because the rules changed again on 8 January 2015.  Now, one must look for AIM 1-1-18(b)(5)(c).

I found four basic rules for flying GPS without WAAS:

  1. Pilots “may file based on a GPS-based IAP at either the destination or the alternate airport, but not at both locations.”
  2. Pilots may plan for LNAV or CIRCLING minimums only, unless equipped for baro-VNAV.
  3. A preflight RAIM prediction for the destination or the alternate airport is required.
  4. Language left over from AIM 1-2-3(d) and Notice N 8900.218 indicate the non-GPS approach at the other location is required to “be flown without reliance on GPS.”

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Unmanned Aircraft, See and Avoid?

UAS NPRMThe first proposal for unmanned aircraft regulations appeared in the Federal Register yesterday.  A small unmanned aircraft, less than 55 lbs, could fly for commercial purposes up to 500 feet above the ground.  I am in favor of adopting new technologies, and I took the time to write some constructive comments for the official docket.  This is just a summary.

Unmanned Aircraft at Class G Airports:  I asked the FAA to add coordination procedures for unmanned aircraft operating on or near uncontrolled airports.  It is nice to allow unmanned aircraft to use these airports, but the “see and avoid” rule seems like a bad idea for these tiny machines.

Unmanned Aircraft at Towered Airports:  I asked the FAA to disallow unmanned flights at controlled airports when the ceiling is less than 1,000 feet.  I did not see a reason why manned airplanes should share an airport under instrument flight rules with a visually operated unmanned aircraft.

Flight Instructors Accepting Certificate Applications:  In granting the CFI privilege of accepting certificate applications, the FAA would create an authority similar to a pilot examiner.  I think it is interesting that the assumed price for this application process is $50.  Even without a practical test requirement, the CFI may be obligated to devote time to adequately research the regulations, to evaluate the applicant, and to assist the applicant in this process beyond what might be worth $50.

Re-Thinking Risk Assessment

Assessing Risk, image from Risk Management HandbookThe best tool available for pilots to quantify overall flight risk is the form found in the FAA’s Personal and Weather Risk Assessment Guide.  However, that form is more than 10 years old and needs many improvements.  It is based on the “PAVE” method or checklist, and enables a pilot to assign a predetermined point value to each area of risk.  This helps to minimize subjectivity and encourages detailed preflight planning.  Using this process in connection with Aeronautical Decision Making is a great idea, but I want to illustrate several ways to make it more complete and hopefully more accurate.

PDF Icon Flight Assessment Form Download (29 KB)

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R-ATP Denied at Baylor University

Letter of denial from the FAA to Baylor University.Part 141 flight training graduates have been denied participation in the R-ATP program again, this time at Baylor University.  In its recent denial letter, the FAA explained that even though Baylor’s students are enrolled in an aviation degree program with part 141 ground and flight training, the lack of a ground training certificate in the university’s name prevents the graduates from qualifying under the new regulations.

The FAA reviewed the description that Baylor provided of its arrangement with TSTC for the ground and flight training of students enrolled in its Aviation Science Bachelor degree program. The arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum by virtue of Baylor not holding an air agency certificate issued in accordance with part 141. Baylor does not have control over the curriculum provided by TSTC. As noted in the petition, Baylor students pursuing their instrument rating and commercial pilot training become TSTC students during those phases. Therefore, the FAA has determined that Baylor’s aviation degree program does not meet the minimum level of integrating its pilot ground training with its broader academic curriculum of an aviation degree program.

The FAA also cites the recent denial at MSU Denver as precedent for this new denial at Baylor University.

Update: R-ATP Exemption Follow-Up

Missed Approach Points in Jeppesen Charts

Legend for the missed approach point symbol.
Jeppesen Chart Symbols

The M.A.P. Study Guide is a list of notes I first developed during instrument-flight-instructor training because I needed a concise explanation of various approach profiles.  Now that I’m considering airline jobs, I’ve decided to adapt my study guide to the chart format used by Jeppesen, which is also used by many airlines.  I find the missed approach procedures slightly more intuitive in the Jeppesen format, but it also presents more information that can become overwhelming at first.

PDF Icon Study Guide Download – Jepp Format (1.2 MB)

You might also want the FAA charts format of the study guide.


Reading a missed approach procedure is a critical step toward briefing and flying a complete instrument approach to an airport.  The missed approach point is the position where the pilot must immediately climb away from the airport if the landing criteria of FAR 91.175(c) are not met.  There are two challenges involved in reading the missed approach point:

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Engine Failure with Runway Remaining

ATSB said most immediate forced landings do not result in serious injury.
ATSB said most immediate forced landings do not result in serious injury.

One of the most intimidating parts of flight training is the unlikely possibility that a single-engine training airplane could develop a single engine failure, thereby leaving no other engines available to help bring the airplane to a safe landing position.  While engine failures and emergency procedures are widely discussed and practiced within the general aviation community, not all emergencies are created equal.

It seems I may be teaching a relatively obscure maneuver: The engine failure that occurs after liftoff but before passing the departure end of the runway.  It’s not an engine failure during multi-engine training, not an engine failure in the pattern, and not an “impossible turn” situation.  I’m talking about a loss of thrust right smack in that precarious transition from ground effect to a sustained, best rate climb.  I use the word “obscure” here because I have looked through every guide for maneuvers, FAA handbooks, airplane manuals, and online training resources that I could find, and not one of them contains a detailed description of this maneuver.

I am writing this article for the benefit of flight instructors and single-engine pilots everywhere, and it comes with a big disclaimer:  My detailed procedure is not an adaptation of other work and is not based on existing procedures.  If a more official procedure existed, I would use it!  The information below might not be appropriate to your aircraft, and this procedure should never be attempted in an aircraft without a flight instructor.

Below the fold, you will also find a video that shows a very bad example of what this maneuver looks like when it is practiced without careful consideration for safety or personal minimums.

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Denial of R-ATP Exemption for MSU Denver

Denial of exemption letter to MSU DenverThe Federal Aviation Administration (FAA) this week denied an exemption to the Metropolitan State University of Denver that would allow graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification.  This is a complete reversal from the decision issued last week to Purdue University.  In denying MSU Denver, the FAA writes, “the relief requested is not in the public interest and would adversely affect safety.”

Following that determination is a somewhat bizarre accounting of MSU Denver’s aviation program:

The proposed arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum. MSU Denver does not have any control over the curriculum provided by CNCC and the FAA would have no oversight responsibilities with MSU Denver because it does not hold a part 141 pilot school certificate.

The FAA notes that MSU Denver voluntarily surrendered its air agency certificate on April 19, 2013, and stated in its petition that it will continue to conduct training via part 61 vice part 141. Prior to the voluntary surrender of its part 141 pilot school certificate, MSU Denver held approved ground school training course outlines for the commercial pilot certificate and the instrument rating. Without a part 141 certificate, the FAA will not be able to determine if MSU Denver’s key personnel, facilities, aircraft, equipment, and training syllabus maintain a training standard that is equivalent to part 141. As stated above, the FAA has determined that meeting the part 141 standards are a necessary component to ensuring proper integration of the ground training with the broader academic curriculum and it enables the FAA to oversee the program and ensure continued compliance with the letter of authorization issued on an established 24-month schedule that coincides with the part 141 pilot school renewal. The FAA has concluded this oversight is critical for assuring that the standards set forth by Congress for a reduction in flight time continue to be met.

The FAA also notes that because MSU Denver previously held a part 141 pilot school certificate, graduates who completed their ground and flight training for their instrument rating and commercial pilot certificate under that training program could be eligible for a restricted privileges ATP certificate with reduced aeronautical experience without an exemption. MSU Denver has not yet applied for the authority to certify those graduates.

This decision is a significant setback for MSU Denver graduates, which creates a bad precedent for regulation of flight training in general.  As stated in its petition, “MSU Denver will no longer be able to support industry needs and educational programming to highly diverse populations with the same viability it has sustained for over 45 years.”  If the Part 141 university graduates are unable to qualify for R-ATP certification, then the value of Part 141 training is further reduced at all universities.  Authorization of R-ATP qualification programs began in August 2013 and has reached only 33 States so far, leaving many Part 61 and Part 141 aviation graduates ineligible.

R-ATP Part 61 Exemption for Purdue University

Grant of Exemption letter to Purdue UniversityThe Federal Aviation Administration (FAA) this week granted an exemption to Purdue University allowing graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification with reduced experience requirements.  This exemption is retroactive.  It is effective for all Purdue graduates from 2009 through 2016.  The R-ATP check rides can be conducted through July 2017.  Graduates are now only required to have an eligibility certificate from the university and a copy of the exemption letter from the FAA.

This exemption marks the first time the FAA has accepted R-ATP applicants who did not complete FAA-approved training under Parts 141 or 142.  The requirement for airline pilots to hold an ATP or R-ATP certificate went into effect August 2013 and made no exceptions for university graduates who completed the same training under Part 61.

Purdue’s petition for exemption was dated 24 August 2013.  Petitions from four other universities remain outstanding and were neither granted nor denied.

The FAA gave the following reasons for granting this exemption:

  • Purdue became a Part 141 flight school on 27 September 2013.
  • Purdue received authorization to certify R-ATP eligibility on 31 March 2014.
  • Purdue’s Part 141 ground training “is no different” from its former Part 61 program.
  • “Key personnel, facilities, aircraft, equipment, and training syllabus … also existed when Purdue conducted training under part 61.”
  • Several factors contributed to “an equivalent level of safety … for those who previously completed their ground and flight training.”

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