Goggle or hood training for Sport Pilots

[Al Downs]

I am not sure if everyone is aware of this regulation but to me it indicates that you must have some goggle or hood type training to complete Sport Pilot training. I have the Gleim syllabus and it is not covered in there. I contacted them and they told me to put a note in any syllabus I have and they will add it in their next reprint.

 

Here is the reg.

61.93(e)(12).

 

Control and maneuvering solely by reference to flight instruments,

including straight and level flight, turns, descents, climbs, use of radio

aids and ATC directives. For students seeking a sport pilot certificate,

the provisions of this paragraph only apply when receiving training for

cross-country flight in an airplane that has a Vh greater than 87 knots

CAS

 

Am I interpreting this correctly? Are you already doing this type of training for Sport Pilot?

[Doug G.]

I think, liking back on it, that my instructor left out a number of things including instrument only flying. I have since done the training with another instructor.

[Jim Meade]

It is generally understood that the referenced Sport Pilot candidate needs the training listed. It is further generally understood but certainly not generally accepted that a Sport Pilot Instructor (Part K CFI) can not give that training. A strict reading of the regs is that you have to have a private pilot license or better and a current medical to act as a required crew member safety pilot which the CFI is when the student is under the hood. I'm willing to make a blind wager that a number of Part K CFIs are giving and endorsing this instruction and if the student ever has a problem it could come back through the FAA, through insurance companies or through civil suits that the CFI was not authorized to do the sign off.

 

Here is an AOPA Counsel discussion of the issue.

http://www.aopa.org/News-and-Video/All-News/2013/August/1/Pilot-Counsel-Safety-pilot.aspx

[Ed Cesnalis]

Jim,

 

You seem to be saying that a Part K CFI may not be qualified to give all the training needed for a sport license with a +87kt endorsement?

[N751JM]

§61.313 does not specify a specific amount of time required for "control and maneuvering solely by reference to flight instruments", only that it is a required training element prior to solo cross country flight for a student pilot (with the exception noted above in the original post). A Part K CFI would be qualified to do this providing they also hold at least a Private Certificate with a current medical. Seems pretty straightforward...

[Tom Baker]

I think, liking back on it, that my instructor left out a number of things including instrument only flying. I have since done the training with another instructor.

 

Doug, I don't know how far back you did your training, but I think the requirement was not added until 2010.

[N751JM]

A clarification: it is not 61.313 that makes it required but 61.93 (student pilot requirements).

[FlyingMonkey]

Sport Pilot training MUST include ONE HOUR of under hood training. It can be done at night with a cap pulled down close to eyes, or done with special equipment to prevent the trainee from using references outside the cockpit. The log book must reflect this endorsement once complete to satisfy the requirement.

 

There is no endorsement for this training, it is simply part of the basic training requirements for the SP certificate, just like you don't need a specific endorsement saying you have learned how to do short field landings, crosswind takeoffs, turns around a point, or any other part of the PTS. You only need endorsements for activities beyond those covered under a certificate, such as operations in B,C,D airspace or flying a tailwheel airplane (assuming you did not train in one for your certificate).

[Anticept]

It is generally understood that the referenced Sport Pilot candidate needs the training listed. It is further generally understood but certainly not generally accepted that a Sport Pilot Instructor (Part K CFI) can not give that training. A strict reading of the regs is that you have to have a private pilot license or better and a current medical to act as a required crew member safety pilot which the CFI is when the student is under the hood. I'm willing to make a blind wager that a number of Part K CFIs are giving and endorsing this instruction and if the student ever has a problem it could come back through the FAA, through insurance companies or through civil suits that the CFI was not authorized to do the sign off.

 

Here is an AOPA Counsel discussion of the issue.

http://www.aopa.org/...fety-pilot.aspx

 

The FAA differentiates between instrument training, and "basic instrument maneuvers" to achieve a pilot certificate.

 

In the example of a private pilot, the instructor rating itself is authorization to perform hood instruction for the purpose of fulfilling the requirements of a certificate. A regular CFI, but not CFII rated instructor, can instruct and fulfil the 3 hour private pilot requirement of hood time. It should be noted however, that since the student cannot log this time, since they are not rated for the aircraft, and the instructor is not rated for Instrument training. The accepted practice that this is logged in a student logbook, is that it can be written in the comments section stating that this requirement is completed, but you cannot log the time under the "simulated" column, since this is typically applied towards an instrument rating.

 

Please see page 2, second paragraph. Pay particular attention to the last sentence in the interpretation.

 

http://www.faa.gov/a...erpretation.pdf

 

Now, as for the sport CFI: If the Sport CFI carries a private pilot certificate, I do not see a conflict with training. If they only carry a sport pilot certificate, this is interesting. However, they are training them towards a pilot certificate, so why wouldn't they be able to teach the student? *EDIT: FlyingForFun below made a point that is a strong technicality. The Sport CFI IS the PIC, and therefore do not need a safety pilot, so the flight is legal.*

 

According to AFS610, the introduction of the sport pilot certificate caused a lot of problems with the rest of the FARs, because they were written with the assumption that an instructor will have a commercial pilot certificate.

[Anticept]

A student can log any time in any aircraft during which he is receiving dual instruction from an instructor.

 

They can log it as total time, and they can log it as dual received, but are you sure a student can log instrument time unless being taught by a CFII? I ask because a student doesn't have a category and class rating, and the instructor does not have the authority to teach instrument flying.

 

It's a really interesting question that is making me think harder on the subject. I can interpret "61.51 (g) Logging instrument flight time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions." as a catch all, saying that you can, but doing so also makes it difficult to separate what time is allowed to be applied for an instrument rating, and what was just logged in general.

[Tom Baker]

If you look at the regulations there is very little training required for the instrument rating. Of the required 40 hours of instrument time only 15 has to be with a CFII, and and the rest can be with anybody that can be a safety pilot. The only required training is 3 hours within 2 calendar months of the checkride and the instrument cross country of 250 miles or more.

[Dan Kent]

I am hardly conversant with the FAR, but I don't believe it has to be hood time, nor at night. My CFII took me into the clouds for my training (daytime). We were fortunate in that in was not turbulent but I got to experience.

 

Without the artificial horizon, I would not be able to maintain level flight for very long.

[coppercity]

Any student must have instrument training prior to solo cross-country. A Sport Pilot instructor is PIC anytime he is giving instruction to a non-licensed student. That would be basic training or instrument training. A student pilot cannot ever be PIC. When a student is flying alone, it's logged as solo, not PIC. When flying with an instructor, it's logged as dual received.

 

A Sport PIlot Instructor can give instrument training to a student in an LSA if the plane is equipped for basic instruments. He does not need a Pivate Pilot certificate or a medical. He is already acting as PIC. An instructor must log your specific training in your log book. There is no specific endorsement for this, but you better have instrument training in your log book prior to your first solo cross country.

 

From 61.51 (Logging Flight TIme)

 

4) A student pilot may log pilot-in-command time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

(ii) Has a solo flight endorsement as required under §61.87 of this part; and

(iii) Is undergoing training for a pilot certificate or rating.

 

A student flying solo with an appropriate endorsment that is undergoing training for a certificate logs solo and PIC time.

[FastEddieB]

I guess that is a change within the past 50 years or so.

 

I think so.

 

My recollection was that a student's first PIC time was on his or her checkride.

[Doug G.]

And, if you are a Sport Pilot you must remain clear of clouds and maintain visual reference to the ground.

[Jim Meade]

Jim,

 

You seem to be saying that a Part K CFI may not be qualified to give all the training needed for a sport license with a +87kt endorsement?

 

Yes, I am saying he/she can not give the training for flight by reference to instruments. There is a school that says you don't need to be under the hood to have flight by reference to instruments, but there is FAA interpretation that the intent is that the pilot have limited vision.

 

I understand that Subpart K CFIs are endorsing the solo cross country requirement, but they have no FAA interpretation to support them if the practice is challenged. I talked to an FAA rep at Oshkosh two years ago and he said the question was being considered but I've heard no resolution since then. It also affects the ability of one Sport Pilot holder to act as safety pilot for another SP certificate holder. Right now, that is not generally considered defensible.

 

It's not what we want the regs to say, it's what they do or are interpreted to say that matters, especially if anyone ever gets audited. When will your records be checked? When you are sued, is one possibility.

 

 

[coppercity]

I have Redbird Simulator for IFR currency and training, although it can be used for IFR currency and up to 10 hours towards an instrument rating, the time I spend in it with my Private students does not count toward the 3hrs of flight by reference to Instruments, that has to be done in the airplane.

 

61.109 (pvt pilot req)

(3) 3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight;

[Jim Meade]

To log instrument time it most certainly needs to be actual, under a hood or other vision limiting device, or in a simulator. A Sport Pilot Instructor can give instrument instruction in an LSA if he has a Private license or greater. He does not need a medical if he is using driver's license, etc. At least that's the last published interpretation I can find.

 

Why don't you post that interpretation so we can all see it.

 

Feel free to post this question in Pilots of America and see what the hangar lawyers there say about it. It's been discussed and rediscussed there several times.

[Joel Severinghaus]

I have the Gleim syllabus and it is not covered in there. I contacted them and they told me to put a note in any syllabus I have and they will add it in their next reprint.

 

I see that the Jeppesen Sport Pilot syllabus (copyright 2009) also omits the new instrument training requirement in 61.93(e). I'll contact them about adding it in their next update.

[Joel Severinghaus]

Sport Pilot training MUST include ONE HOUR of under hood training.

 

I've been squinting at the FARs, but I can't find a requirement for one hour of instrument training, only the mention in 61.93(e)(12) requiring [some] pre-cross country instrument training in an airplane that has a Vh greater than 87 knots CAS.

 

I looked up 75 FR 5220, Feb. 1, 2010, which last amended this section. That Federal Register notice says the FAA proposed requiring "1 hour of flight training on the control and maneuvering of an airplane solely by reference to instruments for student pilots seeking a sport pilot certificate to operate an airplane with a Vh greater than 87 knots CAS..." But after a few paragraphs of discussion, it says "the FAA is withdrawing the proposed change."

 

Or am I missing a cross-reference somewhere?

[Anticept]

Has anyone noticed the reg in question in the first post (61.93(e)(12).) only applies to STUDENT pilots seeking a sport pilot certificate before they do their solo cross country, NOT "sport pilots", period?

 

Anyways, as for pic: yes the pic stuff has changed. I think it was in '07. It's supposed to be that you must be rated for the category and class of aircraft, and student pilots do not actually have that rating.

[Jim Meade]

http://www.nafinet.o...rt aircraft.pdf

 

Page 8. "Unresolved Issues"

 

I'm not making this stuff up.

 

NAFI is just another group of people with an opinion. They give no FAR reference for saying the CFI must have a private but need not have a medical. Their opinion conflicts with the required crewmember provisions which do require a medical.

 

 

[Tom Baker]

There is no specific instrument time requirement for Sport Pilot. You just need instrument training before solo cross country. It would be up to the instructor to make sure you are reasonably proficient before cutting you lose for solo cross country.

 

And only if the Vh is greater than 87 kts.

[Tom Baker]

Every Sport Pilot was a student once.

 

Sport pilot students prior to September 2010

I've been squinting at the FARs, but I can't find a requirement for one hour of instrument training, only the mention in 61.93(e)(12) requiring [some] pre-cross country instrument training in an airplane that has a Vh greater than 87 knots CAS.

 

I looked up 75 FR 5220, Feb. 1, 2010, which last amended this section. That Federal Register notice says the FAA proposed requiring "1 hour of flight training on the control and maneuvering of an airplane solely by reference to instruments for student pilots seeking a sport pilot certificate to operate an airplane with a Vh greater than 87 knots CAS..." But after a few paragraphs of discussion, it says "the FAA is withdrawing the proposed change."

 

Or am I missing a cross-reference somewhere?

 

I think CTLSi is confusing what his school required with what the regulations say.

[Tom Baker]

Every Sport Pilot was a student once.

 

Sport pilot students didn't have to do this before September 2010.