RussR
En-Route
This question was prompted by question about 8's on pylons on FB, but I want to take it in a little different direction, plus this place is slightly less of a cesspool than FB is, so... 
I've never really liked teaching 8's on pylons. Not because it's hard - actually it's one of the easier maneuvers I think. But because in some planes the pivotal altitude is REALLY close to the ground, and there's stuff out there - like windmills and antenna towers.
Any time you have a ground speed of 75 knots or less, your pivotal altitude is 500 ft AGL or less.
We are kind of known for wind here in OK. 15 knots is a pretty average day, no exaggeration needed. Pretty common for 20+, and that wouldn't even cause a question of "are we going to fly or not". So in any plane that you would fly this maneuver at around 90 knots or so, you're likely at or below 75 knots GS on any given day, during the upwind part of the maneuver, and so at 500 ft AGL or less.
The least restrictive minimum altitude rule in 91.119 requires you to stay at least 500 ft away from "any person, vessel, vehicle, or structure".
"Structure" is pretty broad and I don't see it defined in the FARs. The dictionary says it's anything that's "constructed". So unless you actually surveyed the ground before the flight and looked for any fences, abandoned cabins, outhouses, port-a-potties, deer stands, treehouses, abandoned cars, etc., you're probably violating 91.119 if you go slower than 75 knots GS. I know around here it would be really hard to fly this maneuver and not at least fly over some barbed-wire fence during part of it.
I don't do a lot of Commercial Single training, and the last two I did were in a Cirrus and a Mooney, so both were much faster than the 90-ish kt minimum.
But as far as I know, this maneuver is performed every day and on checkrides in airplanes like a Cherokee 140, Cessna 152, older 172s, or even slower airplanes like a Cub. This seems to be tacit FAA and DPE approval of a 91.119 violation, doesn't it? How is that justified?
Granted, if the DPE asks for 8's-on-pylons the applicant could just say "unable" and explain why. But since 8's on pylons are a required maneuver, there should be a discontinuance issued and the applicant would have to come back with a different airplane, or a calmer day.
But I "suspect" none of this happens very often and the 91.119 requirement is simply ignored. I could be wrong about this, and I would welcome any input - especially from our DPEs - about whether 91.119 is even considered if the applicant shows up with a slower airplane. Is this discussed at DPE training and forums?
I've never really liked teaching 8's on pylons. Not because it's hard - actually it's one of the easier maneuvers I think. But because in some planes the pivotal altitude is REALLY close to the ground, and there's stuff out there - like windmills and antenna towers.
Any time you have a ground speed of 75 knots or less, your pivotal altitude is 500 ft AGL or less.
We are kind of known for wind here in OK. 15 knots is a pretty average day, no exaggeration needed. Pretty common for 20+, and that wouldn't even cause a question of "are we going to fly or not". So in any plane that you would fly this maneuver at around 90 knots or so, you're likely at or below 75 knots GS on any given day, during the upwind part of the maneuver, and so at 500 ft AGL or less.
The least restrictive minimum altitude rule in 91.119 requires you to stay at least 500 ft away from "any person, vessel, vehicle, or structure".
"Structure" is pretty broad and I don't see it defined in the FARs. The dictionary says it's anything that's "constructed". So unless you actually surveyed the ground before the flight and looked for any fences, abandoned cabins, outhouses, port-a-potties, deer stands, treehouses, abandoned cars, etc., you're probably violating 91.119 if you go slower than 75 knots GS. I know around here it would be really hard to fly this maneuver and not at least fly over some barbed-wire fence during part of it.
I don't do a lot of Commercial Single training, and the last two I did were in a Cirrus and a Mooney, so both were much faster than the 90-ish kt minimum.
But as far as I know, this maneuver is performed every day and on checkrides in airplanes like a Cherokee 140, Cessna 152, older 172s, or even slower airplanes like a Cub. This seems to be tacit FAA and DPE approval of a 91.119 violation, doesn't it? How is that justified?
Granted, if the DPE asks for 8's-on-pylons the applicant could just say "unable" and explain why. But since 8's on pylons are a required maneuver, there should be a discontinuance issued and the applicant would have to come back with a different airplane, or a calmer day.
But I "suspect" none of this happens very often and the 91.119 requirement is simply ignored. I could be wrong about this, and I would welcome any input - especially from our DPEs - about whether 91.119 is even considered if the applicant shows up with a slower airplane. Is this discussed at DPE training and forums?
