Are 8's on pylons in slower aircraft even legal?
- Thread starter RussR
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Bro do you even lift
lol he'd be kinda correct about that
455 Bravo Uniform
Final Approach
Just twist the altimeter knob a few turns, that’ll fix everything inside the cockpit.
RussR
En-Route
The checkride no longer requires either a complex aircraft or TAA. Training does, but not the checkride. As a result, I see a lot more slower, “basic” aircraft being used for Commercial checkrides than in the past, which is what brought this question up in my mind.
And you’re right, an Examiner could refuse to do it in an aircraft with a low speed and therefore pivotal altitude. I’m just curious if this actually happens or is a point of discussion in any forum.
Up until 2018 when the rule changed, most Commercial checkrides were conducted in complex aircraft like Arrows and 172RGs, which are fast enough for this to not be an issue. Now you can do it in a 150 or a Cub, and people do.
RussR
En-Route
Are you sure you're talking about the Commercial 8's on pylons maneuver? How can you restrict the altitude? That would throw off the whole maneuver. It would be like saying "I want you to do S-turns across a road, but instead of crossing the road, stay on this side."
Lindberg
Final Approach
Yep. I did nothing on my commercial checkride that couldn't be done in a cub.
Yes, I am positive. It has been done with students of mine, that's how positive I am.
RussR
En-Route
Interesting! But how does that work? If you level off above the pivotal altitude, the pylon is going to move forward, and there's no way to keep it from moving, at least by otherwise flying the maneuver as it's supposed to be flown.
455 Bravo Uniform
Final Approach
Never shy of going astray on topic - The poor 172RG at this flight-school is getting no love. All the other 172s, especially the G1000s are almost all fully booked (TAA).
Tuesday I passed my Commercial written. First time that I’ve completed the written before any related flying. I thought it was harder than the IR. Last night I booked the RG to get a complex endorsement in my logbook. I was thinking of rounding out the rest of my 10 hours with TAA, but TAA is more expensive. I think I’ll fly some TAA after the Complex endorsement just to get a feel, but if I need to kill more hours, I might go back to the RG. Then hammer on maneuvers with my own plane and do the 8s-on-Pylons at my Va of 110 kts or just above 1k AGL...
Tuesday I passed my Commercial written. First time that I’ve completed the written before any related flying. I thought it was harder than the IR. Last night I booked the RG to get a complex endorsement in my logbook. I was thinking of rounding out the rest of my 10 hours with TAA, but TAA is more expensive. I think I’ll fly some TAA after the Complex endorsement just to get a feel, but if I need to kill more hours, I might go back to the RG. Then hammer on maneuvers with my own plane and do the 8s-on-Pylons at my Va of 110 kts or just above 1k AGL...
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Bro do you even lift
You do it just like you were trained. You do the maneuver just the same way, descend or climb to keep it on your wing tip. It works the same, any difference is really not that noticeable or significant. All the DPE wants to see is that you can perform the maneuver, which you can at the higher altitude.
You also have to consider in your scenario if the plane enters at 300 ft, how low do you let it go while descending to keep on the pylon? Depends on the wind, even entering at 500 ft, how low do you wanna go?
That video was unwatchable and unintelligible for the average dude.
I did not hear an explanation of what this looks like out the window and the control inputs needed to maintain the pylon position. I stopped listening to the math after two minutes.
This is the video I would recommend:
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RussR
En-Route
That video wasn't intended to describe how to do the maneuver. If you watched it for that reason, it's no wonder you didn't finish. It is a video that derives the equation for pivotal altitude. I actually found it quite interesting, I've wondered why ground speed is the ONLY variable in the equation, and that answered it.
It's an altitude adjustment maneuver pretty much by definition. But that doesn't automatically mean you never need to adjust bank.
Perhaps he's actually doing turns around a point.
dmspilot
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Flew with a brand new commercial pilot that had no idea how to do most of the commercial maneuvers. No idea how he got signed off for a check ride and passed other than the problem must be systemic
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That looks a lot like mine
RussR
En-Route
I'm not trying to be argumentative here, but I just don't see how you can properly fly the maneuver if you set yourself a hard floor you won't go below. You can't just do 8's on pylons at any altitude. Your altitude must vary through the maneuver, and your altitude at any instant has to be the one pivotal altitude that is dependent only on your groundspeed. If that groundspeed is 75 knots, your pivotal altitude is 500 AGL. You can't arbitrarily fly it at 800 or anything else, it won't work, the pylon will move (forward since you're too high).
Your second paragraph, though, is the whole reason I'm asking the question. But if you're at at 300 ft, it's because your ground speed is 58 knots. If you're faster than that, you need to be higher or the pylon will be moving back on you. But if your groundspeed really is 58 knots, then to do the maneuver you need to be a 300 ft at that point, there's no way around it.
Yes, there is wiggle room, and conditions are never perfect nor are pilots, so there's going to be some variation above or below the calculated pivotal altitude that will be considered "good enough". But you can't just say "we're going to do the maneuver at or above 1000 ft in a Cub" - there's no way that's going to work.
elephant212
Filing Flight Plan
Sorry to veer off topic, but do you have a link for that interpretation? I've been out of the game for a while and was recently considering going for my Commercial cert, so I'm curious what further aeronautical experience I need to be eligible for commercial.
RussR
En-Route
There are three main interpretations, best to read them in order:
https://www.faa.gov/about/office_or.../2010/Theriault_2010_Legal_Interpretation.pdf
https://www.faa.gov/about/office_or...0/Hartzell-AOPA_2010_Legal_Interpretation.pdf
https://www.faa.gov/about/office_or.../2018/Oord-AOPA_2018_Legal_Interpretation.pdf
Lindberg
Final Approach
What's really unclear about this? The mere fact that you have an IR doesn't obviate the instrument training requirements in 61.129. But if you've met those training requirements, which you may have done while training for your IR, you're good to go. You just have to have that documented, like every other aeronautical-experience and training requirement for a certificate.
RussR
En-Route
Because these are the instrument training requirements in 61.129: "attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems". Tell me how you can get an instrument rating without already being trained on these skills. They are basic skills in the instrument rating, and naturally anyone who has an instrument rating has already had significant training on them. More than 10 hours in fact.
For many, many years it was well-established that the instrument rating automatically met the requirements of 61.129, and the only people who had to do the instrument training in 61.129 were Commercial applicants who did NOT already have an instrument rating. It made sense, DPEs had no problem with it, and even the FAA said it was okay (through the "unofficial" FAQ but also through FSDO checkrides and such). The FAA admits this in the Hartzell letter: "It has been brought to our attention that information previously available on our own website appears inconsistent with this interpretation."
Although the Theriault interpretation is from 2010, it wasn't until the last few years that it became a well-known thing, being briefed at DPE training and such (especially since the 2018 Oord letter came out). The problem this creates (and the letters clearly state) is that if you did your instrument rating more than a few years ago, it likely wasn't documented with this memo in mind, and so you have to go do ANOTHER 10 hours of instrument training as you work on your Commercial. Solely because of the documentation. Sure, more training is never bad, but we're talking about a situation here where two pilots could have the exact same training - except for one doesn't have to do the additional 10 hours of instrument training simply because their instructor, knowing of this letter, wrote "meets 61.129" in each instrument training entry. No difference in training, just a stroke of the pen, as required in the 2018 Oord letter: "and documented in a manner that demonstrates the time counts towards the commercial pilot certificate and ratings".
Lindberg
Final Approach
1) You don't have to say "meets 61.129, you just have to document attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. If that's documented, you're good. If it was accomplished and the CFI or II didn't include what was accomplished in the logbook, that's a mistake.
2) you would not need an additional 10 hours. 61.129 requires 10 hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. So if you already have 10 hours of instrument training using a view-limiting device but haven't documented all of the specific 61.129 requirements, log another hour and cover whatever's missing from the logbook.
RussR
En-Route
I agree. That's how it should be, is reasonable and complies with what I feel is and always has been the intent of the regulations. And that is EXACTLY the argument I used last time with a DPE. However, at least in this FSDO, that's not how the FSDO has told the DPEs to interpret it. I had several heated discussions with DPEs last year after one of my applicants wasn't allowed to start his Commercial checkride for this reason and they all said the same thing (as if they were briefed it by the FAA directly):
"The instrument training needs to be documented one of two ways:
- The training during the Instrument rating must be documented as meeting the requirements of 61.129 (i.e. complying with the Oord letter's "documented in a manner that demonstrates the time counts towards the commercial pilot certificate and ratings") by specifically saying "meets the requirements of 61.129" or similar.
or
- If they have 10 hours of training after the Instrument Rating, it would therefore be considered "de facto" training for the Commercial (I think this was an attempt of theirs to find a work-around for the other requirement)."
I 100% don't like it, disagree with the implementation, and think it is an example of the FAA lawyers not understanding the (at least formerly) obvious intent of the regulations. But now to comply, if I provide instrument training for either an instrument rating or just for refresher for someone who doesn't have a Commercial rating already, in the remarks I write "meets 61.129" in addition to listing whatever we do.
Capt. Geoffrey Thorpe
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Light and Sporty Guy
It's for the children.
elephant212
Filing Flight Plan
So I received my Instrument Rating in 2001, so none of my CFI's log entries contain the FAA's magic 61.129 language that they'd want for the commercial. But are you saying they'd be OK with me counting any of my dual hood time after getting the Instrument Rating towards the commercial requirement? Including things like IPCs? Even if those log entries are also lacking 61.129 references?
RussR
En-Route
That's what our local DPEs are telling us, yes. Your local DPEs/FSDOs may vary. It would be helpful if those entries included specific reference to the four instrument tasks in 61.129 - attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Yes, you and I know that an IPC explicitly requires those tasks, and should therefore implicitly count as credit for them, but this whole thing is so wrapped up in absurdity that I no longer know what to expect. If your logbook doesn't specifically mention those four things, well, it's your logbook, if you know you did them then go back and make your previous entries more detailed. If you are still in contact with the CFI you flew with, they may be able to help you on that.
Lindberg
Final Approach
Do these DPEs say that every instrument training flight to count for commercial must be instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems? So every hour must cover attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems? Every minute? Find a different DPE because yours don't understand the FARs or the FAA's letters.
The reason why training for the IR doesn't automatically count for the 10 hours of instrument training required for commercial is because there are non-overlapping training requirements. For example, 61.65(c) doesn't explicitly require training on partial panel skills or recovery from unusual flight attitudes. So you could be eligible for IR having received zero hours of that instruction, so if what you did on each training flight isn't documented other than "in accordance with 61.65," there's no evidence you received any of that instruction. But neither 61.65 nor 61.129 requires a certain amount of instruction in any particular area, they just require some.
dmspilot
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Bingo.
The interpretation letters are a "legaleese" way of saying that simply having an instrument rating is insufficient to automatically satisfy the requirement. In fact the third letter basically says exactly that: "simply holding an instrument rating...cannot be automatically assumed to meet the training required under §61.129". For example, if you obtained your instrument rating, and then lost your logbook, and wanted to apply for a commercial pilot certificate, you would still need to meet 61.129(a)(3)(i) using new or acceptably reconstructed logbook entries.
The second letter also states, "we anticipate that for commercial pilot applicants who already hold an instrument rating, the hours of instrument training used to obtain that rating will...quite often, meet all the requirements for instrument aeronautical experience as required under §61.129."
If your logbook has documented training "using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems" then you meet 61.129. The letters of interpretation invent no requirement that these log entries state something like "training in accordance with 61.129" (though it's not a bad idea to do so).
This is all that needs to be said. Don't confuse the issue with trivia and just simply reconstruct the hours from logbook entries.
RussR
En-Route
@Lindberg @dmspilot you guys crack me up. I literally said several posts ago that I agree with you (on most counts at least) and used the same arguments to more than one DPE in the last year. But then you seem to be arguing with me, about something we agree on...
It's really easy to say "find a new DPE", but a little harder to do in practice, since they are literally following what the FSDO has told them to do (as stated before). The consistency between the DPEs was amazing. One even outright said he doesn't agree with the way they're being told to do it, but they have to do it that way. And that way is "10 hours of instrument training past the IR checkride, OR training during the IR prep specifically documented as "meeting 61.129."" As frustrating as this is, I'm not making this up. It prevented an applicant of mine from taking a checkride.
Complain to the FSDO? The DPEs have already done that, according to them. So maybe it IS just our FSDO, but I'd be interested in input from DPEs in other FSDOs too.
The point I don't necessarily agree with you on is this. Yes, the areas in 61.65 and 61.129 are slightly different. However, all the areas in 61.129 are tested as part of the instrument checkride, and are required to be tested as part of the ACS. And the CFI has to sign an endorsement saying they provided training toward the checkride. So by extension and necessity, all the areas in 61.129 had to have been trained on during the instrument rating training. So I don't understand why the Chief Counsel said that simply holding an instrument rating is not proof of meeting the requirements. It sure seems it to me.
It's really easy to say "find a new DPE", but a little harder to do in practice, since they are literally following what the FSDO has told them to do (as stated before). The consistency between the DPEs was amazing. One even outright said he doesn't agree with the way they're being told to do it, but they have to do it that way. And that way is "10 hours of instrument training past the IR checkride, OR training during the IR prep specifically documented as "meeting 61.129."" As frustrating as this is, I'm not making this up. It prevented an applicant of mine from taking a checkride.
Complain to the FSDO? The DPEs have already done that, according to them. So maybe it IS just our FSDO, but I'd be interested in input from DPEs in other FSDOs too.
The point I don't necessarily agree with you on is this. Yes, the areas in 61.65 and 61.129 are slightly different. However, all the areas in 61.129 are tested as part of the instrument checkride, and are required to be tested as part of the ACS. And the CFI has to sign an endorsement saying they provided training toward the checkride. So by extension and necessity, all the areas in 61.129 had to have been trained on during the instrument rating training. So I don't understand why the Chief Counsel said that simply holding an instrument rating is not proof of meeting the requirements. It sure seems it to me.
Lindberg
Final Approach
You've also said the letters are wrong and that the suggested fix is wrong. I say your DPEs are wrong. Next time this comes up, instead of making your student pay for ten more hours of instruction, come to a DPE in North Texas.
dmspilot
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The problem is not the FAA lawyers or the letters of interpretation which you called "ridiculous". I wrote a post explaining there is nothing wrong with them. It's your DPE(s).
flyingpreacher
Pre-takeoff checklist
Zombie Thread, I know. My question is, this is now 17 years old. Has the FAA done anything or issued any new interpretations about this? Does the magic wording of "Meets the requirements of 61.129" have to be in the logbook or am I good to go? My IR was finished in 2022, and I have plenty of time under the hood doing the things they want you to do.
GaryM
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Now I'm distracted from the topic of the thread because I'm struggling to visualize what that fence would look like.
aftCG
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aftCG
Sorry, where I work in rural Alaska we are routinely 50+NM from the nearest sign that humans even exist. We joke about hitting a fence post, but they don't have fences out here.
Rockymountain
Pre-takeoff checklist
I have a similar sign in front of my house.
GROUND speed, so wind does affect things.