Logging hours - in a complex without endorsement

mandm

mandm

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Michael
Want to know what could be logged under the following scenario:

Airplane: Complex ASEL
pilot A: CFI ASE, instrument rated, no complex
pilot B: Commercial ASEL, instrument rated, complex endorsement

I gather that pilot B is complex endorsed must be the PIC. Can pilot A log any time in the airplane while flying with pilot B, and what exactly can be logged.

Can either pilot shoot practice approaches, can pilot B receive any instruction from pilot A, or while flying can pilot B act as PIC while pilot A is flying logging hours but not logging PIC?
 
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The only interesting one there is the instructor with no complex giving instruction in a complex. A question which has only had an FAA answer in the old orphaned FAQ (and I would not want to be that CFI if Pilot B landed gear up!).

Every other one has had clear answers for many years.

In addition to @EdFred's link, you can see if my article in IFR Magazine gives you any answers.
 
My answer, no the person is not rated in the aircraft (no complex) and not the sole occupant of the aircraft.

BTW, there is no such thing as CFI ASEL, you are a CFI ASE.

And how do you get to be a CFI without having been complex rated?
 
Pinecone said:
My answer, no the person is not rated in the aircraft (no complex) and not the sole occupant of the aircraft.

BTW, there is no such thing as CFI ASEL, you are a CFI ASE.

And how do you get to be a CFI without having been complex rated?
Click to expand...


Complex, high HP, etc are not ratings they are endorsements.
Rating would be Aircraft single engine, for which he is rated.

As for the CFI part, flying diamonds or cirrus exclusively I imagine.
 
midlifeflyer said:
The only interesting one there is the instructor with no complex giving instruction in a complex. A question which has only had an FAA answer in the old orphaned FAQ (and I would not want to be that CFI if Pilot B landed gear up!).

Every other one has had clear answers for many years.

In addition to @EdFred's link, you can see if my article in IFR Magazine gives you any answers.
Click to expand...

MauleSkinner said:
A complex endorsement (not a rating, as Justin indicated) has not always been a requirement for a flight instructor certificate.
Click to expand...

And still isn't since you can get the commercial in a TAA, you could have 0 complex time. And complex time isn't a requirement for the CFI in 61.183 just the commercial.

And upon further reading, I don't see anything in Subpart H that precludes an instructor from giving a complex endorsement to a pilot even if that instructor doesn't have the endorsement himself. (Would need to instruct from back seat while a complex endorsed pilot acted as PIC).
 
Pinecone said:
My answer, no the person is not rated in the aircraft (no complex) and not the sole occupant of the aircraft.

BTW, there is no such thing as CFI ASEL, you are a CFI ASE.

And how do you get to be a CFI without having been complex rated?
Click to expand...
Aside from the fact that "complex: is not a rating, there's at least four questions in that post. All of them "no"?
 
EdFred said:
A

And upon further reading, I don't see anything in Subpart H that precludes an instructor from giving a complex endorsement to a pilot even if that instructor doesn't have the endorsement himself. (Would need to instruct from back seat while a complex endorsed pilot acted as PIC).
Click to expand...
You're right about the words of Subpart H.

But the silly back seat CFI scenario (where three pilots log PIC too) ended with the Chief Counsel's 2018 Williams interpretation that the CFI must be at a control station due to the intersection of 61.195 and 91.109.

upload_2022-10-13_15-34-35.png
 
ooo, here's a twist for ya....
did Pilot A get a High Performance endorsement prior to August 1997?
 
Brad W said:
ooo, here's a twist for ya....
did Pilot A get a High Performance endorsement prior to August 1997?
Click to expand...
Or did he go flying with Pilot B in a complex airplane before August 1997 and log it without getting an endorsement, and therefore doesn’t need one now?
 
I fall into that grey area....
High Performance Endorsement back in 1991. That was based on training received in a 200 HP C177RG
Later I flew some aircraft with >200HP...but each engine <200 HP...no matter, they were High Performance when I flew them even if they aren't now :confused:
and I flew several different just plain old "low performance" complex planes too

then in 1997 they changed the rules requiring the second endorsement

in 1999 I got checked out in a single engine >200 HP (the first time I met the requirements for the new HP definition)
I remember having a rather long debate with my CFII as well as some of her coworkers who all agreed that I did not need a separate new endorsement.

The training and endorsement required for operating a high-performance airplane as pilot in command is not required if you logged flight time as pilot in command of a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane prior to August 4, 1997. — AOPA's subject report, " Transitioning to High-Performance Airplanes."​

so according to that opinion anyway, I don't need a separate new endorsement because I flew what was then considered to be high performance even though it's not considered high performance now.... At one point I think I found that elsewhere too...something more official than AOPA... but at this point I can't recall where.
When I think about it I kind of wish the CFI would have just made the endorsement even though I "didn't need it"... seems like it would just be 'cleaner' that way
 
What if I logged it prior to 1997, but lost the logbook showing I was PIC?
 
Brad W said:
I fall into that grey area....
High Performance Endorsement back in 1991. That was based on training received in a 200 HP C177RG
Later I flew some aircraft with >200HP...but each engine <200 HP...no matter, they were High Performance when I flew them even if they aren't now :confused:
and I flew several different just plain old "low performance" complex planes too

then in 1997 they changed the rules requiring the second endorsement

in 1999 I got checked out in a single engine >200 HP (the first time I met the requirements for the new HP definition)
I remember having a rather long debate with my CFII as well as some of her coworkers who all agreed that I did not need a separate new endorsement.

The training and endorsement required for operating a high-performance airplane as pilot in command is not required if you logged flight time as pilot in command of a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane prior to August 4, 1997. — AOPA's subject report, " Transitioning to High-Performance Airplanes."​

so according to that opinion anyway, I don't need a separate new endorsement because I flew what was then considered to be high performance even though it's not considered high performance now.... At one point I think I found that elsewhere too...something more official than AOPA... but at this point I can't recall where.
When I think about it I kind of wish the CFI would have just made the endorsement even though I "didn't need it"... seems like it would just be 'cleaner' that way
Click to expand...
Your instructors were incorrect…the current reg clearly states that if you did not log PIC time in an airplane with >200 hp prior to August 1997, you need the current endorsement. It has nothing to do with what endorsements you may or may not have had prior.

Which is probably why the reg makes absolutely no mention of the endorsement required prior to 1997.
 
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yeah, that was the rub....
I did log time in aircraft >200 HP...just not in one engine....so high performance by the definition then. just not PIC in them....
but.... I have logged PIC in High Performance Airplanes prior to 1997..... so there is that!

I actually got checked out some time later in a different >200HP single...different instructor, different school...same opinion.
 
MauleSkinner said:
The horsepower requirement prior to 1997 was each engine also.
Click to expand...

nah.... I don't believe it did....
I suspect that the "an engine" verbiage was probably not intended...and is now a rule grown out of an unintended and careless word choice.... just my opinion....

back in those days it made a little more sense.
from a document found online, dated in 1991:
Section 61.31(e) states, in pertinent part, that: High performance airplanes. A person holding a private or commercial pilot certificate may not act as pilot in command of an airplane that has more than 200 horsepower, or that has a retractable landing gear, flaps, and a controllable propeller, unless he has received flight instruction from an authorized flight instructor who has certified in his logbook that he is competent to pilot an airplane that has more than 200 horsepower, or that has a retractable landing gear, flaps, and a controllable propeller, as the case may be.​

Think about it... how is a twin with 400 horsepower not considered high performance when a single with 201 HP is?
How about a fictional 4 engine aircraft (let's say a scale model of a B-17 to make it cool in the mind's eye..) It has 800 HP total?
back then... the 400 HP twin was considered high performance. Today it is not. Yeah, that makes sense
 
MauleSkinner said:
A complex endorsement (not a rating, as Justin indicated) has not always been a requirement for a flight instructor certificate.
Click to expand...
You used to have to have complex time to get a commercial, which is a prerequisite for the instructor, but now you can do it in a TAA (glass panel) instead.
 
flyingron said:
You used to have to have complex time to get a commercial, which is a prerequisite for the instructor, but now you can do it in a TAA (glass panel) instead.
Click to expand...

You're 2 hours late.
 
Brad W said:
nah.... I don't believe it did....
I suspect that the "an engine" verbiage was probably not intended...and is now a rule grown out of an unintended and careless word choice.... just my opinion....
Click to expand...
If you hunt up documentation/interpretations, you’ll find that the change was intentional to match what they required/intended.
 
well maybe so...I'll take your word for it....maybe it was intended for some reason that escapes me....
but I will say that logic doesn't hold water with me. Can't believe they intended it. Doesn't make sense to me.
What does seem plausible though is interpretations doubling down on it trying to justify it....
Just like the Audi service writer did to me just yesterday telling me a certain tire was not approved for my car because it's a heavy car.... even though the load rating was the same as the OEM tire....just talking non-sense trying to justify a silly requirement.
 
Brad W said:
well maybe so...I'll take your word for it....maybe it was intended for some reason that escapes me....
but I will say that logic doesn't hold water with me. Can't believe they intended it. Doesn't make sense to me.
What does seem plausible though is interpretations doubling down on it trying to justify it....
Just like the Audi service writer did to me just yesterday telling me a certain tire was not approved for my car because it's a heavy car.... even though the load rating was the same as the OEM tire....just talking non-sense trying to justify a silly requirement.
Click to expand...
They had to draw the line somewhere. They chose 200 hp on an engine. And I would certainly not consider the 360hp Dutchess I did my multi in to be a high performance airplane.
 
And then there’s the fixed gear turbo prop. 750hp, high performance, not complex, gets you commercial.
 
MauleSkinner said:
A complex endorsement (not a rating, as Justin indicated) has not always been a requirement for a flight instructor certificate.
Click to expand...

I haven't looked at the requirements, but when I got my CFI (MANY years ago) you needed a Commercial for CFI. And Commercial needed Complex
 
I used to refer to the 320 I used to fly as having a normally aspirated engine with a 24 blade fixed pitch prop. Of course, that applied to all the transport planes I flew.
 
Brad W said:
I fall into that grey area....
High Performance Endorsement back in 1991. That was based on training received in a 200 HP C177RG
Later I flew some aircraft with >200HP...but each engine <200 HP...no matter, they were High Performance when I flew them even if they aren't now :confused:
and I flew several different just plain old "low performance" complex planes too

then in 1997 they changed the rules requiring the second endorsement

in 1999 I got checked out in a single engine >200 HP (the first time I met the requirements for the new HP definition)
I remember having a rather long debate with my CFII as well as some of her coworkers who all agreed that I did not need a separate new endorsement.

The training and endorsement required for operating a high-performance airplane as pilot in command is not required if you logged flight time as pilot in command of a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane prior to August 4, 1997. — AOPA's subject report, " Transitioning to High-Performance Airplanes."​

so according to that opinion anyway, I don't need a separate new endorsement because I flew what was then considered to be high performance even though it's not considered high performance now.... At one point I think I found that elsewhere too...something more official than AOPA... but at this point I can't recall where.
When I think about it I kind of wish the CFI would have just made the endorsement even though I "didn't need it"... seems like it would just be 'cleaner' that way
Click to expand...
Why is that a grey area? I don't understand.

Before August, 1997, the definition of a high performance airplane was:
an airplane that has more than 200 horsepower, or that has a retractable landing gear, flaps, and a controllable propeller​

In August 1997, the definition of a high performance airplane became:
an airplane with an engine of more than 200 horsepower​

with a grandfather clause in the same section that exempted those who
logged flight time as pilot in command of a high-performance airplane​
before the change.

Seems pretty straightforward to me. Were some arguing that in evaluating a flight for compliance in 1999 (or today for that matter), one would use the pre-1997 definition? IOW, I flew and got endorsed in a Cutlass in 1996 ("high performance" then) but never flew something having an engine with more than 200 HP until last week, I would apply the 26 year old definition and not need an endorsement?
 
Larry in TN said:
The intent was for the pilot to have training on operating higher-powered engines.
Click to expand...

ok, yeah I can see that being something of interest
but the way it was worded for the revision doesn't seem very well thought through, which is why I'm doubtful about that as an intent
the earlier definition seems to better capture the concept of differentiating a higher performance aircraft from a lower performance one...

midlifeflyer said:
Why is that a grey area? I don't understand.

Before August, 1997, the definition of a high performance airplane was:
an airplane that has more than 200 horsepower, or that has a retractable landing gear, flaps, and a controllable propeller​

In August 1997, the definition of a high performance airplane became:
an airplane with an engine of more than 200 horsepower​

with a grandfather clause in the same section that exempted those who
logged flight time as pilot in command of a high-performance airplane​
before the change.

Seems pretty straightforward to me. Were some arguing that in evaluating a flight for compliance in 1999 (or today for that matter), one would use the pre-1997 definition? IOW, I flew and got endorsed in a Cutlass in 1996 ("high performance" then) but never flew something having an engine with more than 200 HP until last week, I would apply the 26 year old definition and not need an endorsement?
Click to expand...

I think the "grey area" is evident based on the confusion that exists around it. I've been told in this thread that the instructors were wrong, (at least 4 CFI's had come to the same conclusion). To be honest, I think they were wrong too, but ..... they are more qualified than me.
...and your last paragraph...steps all into that grey....when they say in the current regulation "representative of a high performance airplane". What is a high performance airplane?
to get that answer do they mean to go to a current definition or to an obsolete definition?
The training and endorsement required by paragraph (f)(1) of this section is not required if -
(i) The person has logged flight time as pilot in command of a high-performance airplane, or in a full flight simulator or flight training device that is representative of a high-performance airplane prior to August 4, 1997; or​
I can see that logic playing out both ways.
Way back 30 years ago or whatever, if a CFI endorsed me to fly an aircraft >200HP....so even though I never actually logged PIC time in such a thing, I was instructed and found worthy so I could have any time I had an opportunity. In a similar way, someone that passed their PPL checkride sometime in the past but never flew again is STILL to this day a PPL holder.
But on the other hand they would not intend to use obsolete definitions in a current rule. That just destroys any logic of continuity.
 
Brad W said:
I've been told in this thread that the instructors were wrong, (at least 4 CFI's had come to the same conclusion). To be honest, I think they were wrong too, but ..... they are more qualified than me.
Click to expand...
It doesn’t matter what any of us “think”. The current regulatory language is quite clear. If one agrees with it, he’s right. If not, he’s wrong. “At least 4 CFI’s” disagree with it.
 
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