Rough Ground Flight Review

Southpaw said:
So my question is : Can one fly personal AC not for hire more then 100 hours a year with out a 100 hr. Inspection ?
Say you pass 100 hours and the annual is not due for another month.
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There are no 100-hr inspections for private-use only aircraft. The 100-hr inspection comes in when you are renting your aircraft out or if you are providing instruction in your aircraft.

ETA references:
  1. I'm not sure why, but this number is "undeletable". :confused:
§ 91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had -

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.
(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

Paragraph c exempts airplanes with other inspection schedules (part 121 and 135 ops), and a variety of other planes with special kinds of airworthiness certs, including ferry permits and light-sport certs.
 
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If I did a 2 hr ground session for what I assume is a BFR and the subject of the 100 hour rule cropped up I'd be finding a new CFI. Never had one of those things go more than an hour.
 
SkyChaser said:
There are no 100-hr inspections for private-use only aircraft. The 100-hr inspection comes in when you are renting your aircraft out or if you are providing instruction in your aircraft.
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This is incorrect. Please read the regulation and the numerous threads on this subject, including this one. Pure rental does NOT require a 100 hour.
 
Southpaw said:
So my question is : Can one fly personal AC not for hire more then 100 hours a year with out a 100 hr. Inspection ?
Say you pass 100 hours and the annual is not due for another month.
Click to expand...
Eh? Again, a 100-hour inspection gets you nothing nor is it required unless you're carrying passengers for hire or providing instruction.
 
jordane93 said:
I think we’re talking past each other. I know a 100 hour is not necessary if you are just going to rent the plane. The point I was trying to make is it’s not unreasonable for someone to know when /what basic inspections are required wheb conducting a flight review. It’s just basic airworthiness knowledge.
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I'd not argue the latter point, but that's not the excuse previous posters gave as to why it is important.
 
Southpaw said:
So my question is : Can one fly personal AC not for hire more then 100 hours a year with out a 100 hr. Inspection ?
Say you pass 100 hours and the annual is not due for another month.
Click to expand...

Let me see if I can help.

If all that your aircraft is used for is for personal, private flying by a certificated pilot, no 100 hour inspection is ever required, just the annual. You can even let me fly your plane for free or even charge me a bucket of money to fly it. Still, no 100 hour inspection requirement.

However, if you provide instruction in your aircraft, do an air tour business, or a 135 operation then a 100 hour will be required before doing any of those operations if the plane has exceeded 100 hours in service since its last annual.

What causes a snag in some people's thinking for some reason or another is what happens in particular situations once that 100 hour threshold occurs with mixed use aircraft. Let me explain what I mean by mixed use. Let's assume that you use your plane for your own personal flying, rent it to me for whatever amount, and you also provide instruction in it for which you are paid.

Now let's say that your plane has accumulated 100 hours since its last annual inspection. In that case, you can still fly it for your own use and I can still rent it from you without a 100 hour being accomplished. Both of these would be in compliance with the regulation. You could also provide free instruction to your grandkids or anyone else without doing the 100 hour. However once it does hit that 100 hour mark, it must be inspected prior to you providing compensated flight instruction.

I hope that wasn't too convoluted of an explanation for the simple concept that it really is.
 
There is something I have never quite understood about 100-hour inspections, and that's the rules regarding "overflying" the 100-hour to get it to maintenance, and the subsequent effect on further inspections.

"The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service."

I buy a plane with 0 hours and a fresh annual.
I provide flight instruction in it and sometimes just fly it around myself. So it DOES need 100-hours.
Once I reach 100 hours, I can't provide flight instruction. I get that.
At 99 hours I'm up on a flight and land with 102 hours, at which time the 100-hour inspection is performed. This seems okay.
I think this means that I still have to get the next 100-hour inspection at 200 hours, not 202.

But I COULD still fly it around myself if I wanted to.
So instead of taking in for the 100-hour, I land with 102 hours and then fly it around myself for another 48 hours (total of 150 hours now), then I decide I want to flight instruct again.
I get a 100-hour inspection. Is this good for another 100 hours, or only 50?

And why the difference? In the second scenario I could have flown it around myself for another 1000 hours, 10 hours, 2 hours, whatever. So maybe I just don't understand how this rule works.
 
SkyDog58 said:
This is incorrect. Please read the regulation and the numerous threads on this subject, including this one. Pure rental does NOT require a 100 hour.
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(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
**********
I think I see how your interpretation of the bolded part of the above paragraph works but not sure. Basically you're saying that unless you fly your own plane and charge your pax, renting the aircraft doesn't trigger that clause?
 
RussR said:
As a CFI, I've never treated any part of a flight review, but especially not the ground part, as anything close to confrontational. That surprises me.

I mean, if I was asking about 100-hours and annuals, and we disagreed, my response would be "well, let's look it up" right there. And maybe we'd both learn something.

At least in my opinion, it's a ground "review", not a ground "test". There should be nothing to "go downhill" about.
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Absolutely perfect. That's professionalism in action right there... the proper way to handle these matters.

There's no need to "die on a hill" when it comes to matters like these; simply go to the reference materials and work through it together. Everyone wins.
 
RussR said:
There is something I have never quite understood about 100-hour inspections, and that's the rules regarding "overflying" the 100-hour to get it to maintenance, and the subsequent effect on further inspections.
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The reg simply provides ample room to get an airplane to somewhere that the inspection can be accomplished, and assumes the airplane is used 100% for hire. It’s preventing the equivalent of the 13-month annual inspection.
 
SkyDog58 said:
You could also provide free instruction to your grandkids or anyone else without doing the 100 hour. However once it does hit that 100 hour mark, it must be inspected prior to you providing compensated flight instruction.
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I would have agreed up until last year when the FAA decided that "good will" was a form of compensation. If free instruction results in the grandkids loving grandpa and giving him a hug, today's FAA would likely decide that gramps had been compensated.

As uncontrolled bureaucracies go, only the BATFE begins to rival the FAA....
 
Jaybird180 said:
I’m going to have to deal with him a lot in the future. Our personality types could conflict where we disagree. I’m looking for advice on how to handle situations like this when the instructor is misinformed. Anything other than “you’re wrong” is preferable, but I’m certain that he has no hesitation in saying it.
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What do you tell a CFI with two black eyes?
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NOTHING! You already told him TWICE! :p:p:p:p:p
 
Half Fast said:
I would have agreed up until last year when the FAA decided that "good will" was a form of compensation. If free instruction results in the grandkids loving grandpa and giving him a hug, today's FAA would likely decide that gramps had been compensated.

As uncontrolled bureaucracies go, only the BATFE begins to rival the FAA....
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The FAA declared goodwill to be compensation long before last year. But not just any form of goodwill, but rather goodwill in the form of expected future economic benefit. So just making someone warm and fuzzy would not qualify.

And while, the FAA sometimes take it a little too far, your example is bonkers, though I suspect it was meant to be. You old nut!
 
SkyChaser said:
There are no 100-hr inspections for private-use only aircraft. The 100-hr inspection comes in when you are renting your aircraft out or if you are providing instruction in your aircraft.
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Again, wrong. Rental does not require 100 hour inspections. Carrying persons or hire OR providing the aircraft with flight instruction does.

91.409 :

Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter...
 
Just to throw a monkey wrench in here... if you own certain Cessnas, you do need to do the 100 hour seat rail ADs to be legal.
 
flyingron said:
Again, wrong. Rental does not require 100 hour inspections. Carrying persons or hire OR providing the aircraft with flight instruction does.

91.409 :

Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter...
Click to expand...

I believe my brain has officially quit for the day. Hopefully it comes back to work tomorrow. :crazy:
 
SkyDog58 said:
@RussR I believe your questions are answered in the above CC interpretation under Scenario 6.
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Sooo close, but just not quite there. The very last sentence of Scenario 6 sums up what I think, but what I don't understand. They say that after someone uses it for "non-100-hour-required use", the company "must perform an annual or 100-hour maintenance inspection prior to using the aircraft to provide flight instruction for hire."

Which says to me that if I fly it around for 50 hours past the 100-hour or any other number, then doing a 100-hour "resets the clock". But it doesn't actually word-for-word say that. And I can see where if I just flew it around for 5 hours past the 100-hour (or any value between 1 and 10), the big question would be "that doesn't reset the clock, you only get 95 more hours". I don't see the difference, if there is one.

The interpretation mentions the airplane being "marked" for rental use only, no instruction allowed, and if you "mark" it for this once you get to 100 hours, then you are allowed to get more time out of it before it has to go into inspection. But it could be marked for 2 hours or 200 hours. If the clock is reset if it's "marked" for 200 hours, then why not reset for 2 hours of this use?

My question, of course, is getting dangerously close to "why" territory, which is unanswerable in my experience, but I am interested in the practical application of this for flight schools that also rent their aircraft for personal use. 100-hour is due on Friday. Flight school marks it "no training allowed" for the weekend. Pilots rent it for 9 hours on the weekend and it goes into inspection on Monday. Does the clock reset? Pilots rent it for 11 hours over the weekend. Does the clock reset?
 
RyanShort1 said:
Just to throw a monkey wrench in here... if you own certain Cessnas, you do need to do the 100 hour seat rail ADs to be legal.
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There are a few ADs that are repetitive and are due at various intervals including 100 hours. Sometimes an interval is selected so that they fall concurrent with the 100 hour or other required inspection so as to alleviate burden on the operator. Sort of nice of the FAA imho. They frequently even have the same 10 hours of cushion built in. For instance the fuel line AD for Lycoming engines is set at 110 hours but will almost always get done at the 100 hour inspection if an aircraft gets one.
 
RyanShort1 said:
Just to throw a monkey wrench in here... if you own certain Cessnas, you do need to do the 100 hour seat rail ADs to be legal.
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There are numerous ADs that require compliance at various intervals. Those may or may not line up with other required inspections, and are separate from the 100 hour inspection being discussed in this thread.

Off the top of my head, I can think of two ADs that require daily compliance. In both these cases a pilot can perform the check and sign the AD off. Those ADs are often without documented compliance as the pilot and/or owner doesn't understand their responsibilities.
 
hmm...a confrontational lesson. Not good.
Generally speaking though I'm in the camp of pick your battles. Seems to me that except as a point of basic knowledge, this point really does not matter one way or the other in getting your flight review done. It's just a discussion....make your counter point...even flip open to the page if that's handy and discuss it a bit...but beyond that if the instructor is willing to die on that hill.... you don't have to be the one to "kill him" on that hill.
say "Oh. that's interesting. I read it differently...but ok, if you say so...."...and then move on. You know what you know...and can research for your own satisfaction later.
 
Of course, when I was involved in the rental/flight instruction biz, we never did 100 hours. We just did annuals every 100 hour (or the year ended which ever came first). The shop didn't have any discount for just doing 100hr (The IA signed either one off).
 
So I am genuinely very curious about how much of this was a review, how much was teaching, and if there were other things that you were rusty over.

My experience as an instructor is that most flight review participants who have a chance to prepare aren’t going to have too many hangups on the required portions of the ground review which are the actual regulations of part 91 per 14 CFR 61.56 (a)(1). I personally prefer to work through various scenarios to see if they have a working knowledge of the rules and their application. It’s not rocket science but sometimes somebody is rusty. That said, it would be a rusty individual who I felt needed 2 hours.
 
Is it a valid question for a flight review? Sure. Is it a stupid question for a flight review? Yes, in my opinion.
Better question - How many VOR's around here work, how do you tell, and what does that mean to you? And that's not just my opinion, pretty sure FAA is leaning toward scenario based discussions that speak to safety, rather than Barney Fife stuff.
 
MauleSkinner said:
Sounds like we as instructors are dropping the ball on this.
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I don’t see how a CFI has any relevance of what a renter looks through to verify airworthiness. I am going to a very large percentage of pilots have had what is required for airworthiness. Like most things learned most pilots just toss that knowledge out the window.
 
First post here.

I'm Coming back to flying after been gone for about 8-9 years, with that said.

I'm working on my BFR with this new flight instructor, we had a chat about what I expected of him, he learned my past flying experience and how long I've not flown, one if the things I told him was that my flight review was not going to be the typical 1hr ground and flight, nope! I made it clear that I wanted more training than that, with all that he tailored my flights and ground portion, so far two flights on the same day, a very short one to gage my skills, the second one a short flight 25 miles away from the home airport through class C, D and back to D plus a night landing, just what I needed, all that has been nothing but fun, going up soon for a 50+ miles through class C, D, non towered Airport, a diversion to a D airport, back through class B, D and finally home, can't wait
 
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TommyG said:
I don’t see how a CFI has any relevance of what a renter looks through to verify airworthiness. I am going to a very large percentage of pilots have had what is required for airworthiness. Like most things learned most pilots just toss that knowledge out the window.
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Renters tend to toss the same things out the window that their instructors do. How often do you look at the records with your students prior to a lesson?
 
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RussR said:
There is something I have never quite understood about 100-hour inspections, and that's the rules regarding "overflying" the 100-hour to get it to maintenance, and the subsequent effect on further inspections.

"The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service."
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This provision is for people who continue to use it for the operations that require 100 hour inspections past the 100 hours. You get a ten hour grace period but it counts against you for the next 100 hour interval. Once you do an annual, everything resets to zero.
 
TommyG said:
I don’t see how a CFI has any relevance of what a renter looks through to verify airworthiness. I am going to a very large percentage of pilots have had what is required for airworthiness. Like most things learned most pilots just toss that knowledge out the window.
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This is a bigger issue that wondering about the nits like 100 hours. In fact, I think there has been a change in emphasis on checkrides since I started. When I got my instrument rating (30 years after I got my private), I had to show all the things that proved the flight was going to be legal:

1. Annual
2. Other required inspections: static/transponder/alitimeter/encoder/ELT
3. W&B
4. Required paperwork: manuals/supplements/airworthiness certificate/registration
5. Pilot certificate/medical
6. Pilot currency
 
flyingron said:
This provision is for people who continue to use it for the operations that require 100 hour inspections past the 100 hours. You get a ten hour grace period but it counts against you for the next 100 hour interval. Once you do an annual, everything resets to zero.
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An annual (vs a 100-hour inspection) does not automatically reset the 100-hour clock. That's explained in Scenario 6 of the Chief Counsel letter linked upthread.

"However, if you perform an annual inspection on an aircraft that has exceeded the 100-hour limitation, you are still required to subtract the excess time from the next 100 hours of time in service."

and

"Therefore, the next annual or 100-hour maintenance inspection would be due in 95 hours, regardless of whether an annual or 100-hour maintenance inspection was last performed - the fact that you deemed the inspection in the second part of your hypothetical an annual rather than a 100-hour inspection makes no difference."
 
flyingron said:
This is a bigger issue that wondering about the nits like 100 hours. In fact, I think there has been a change in emphasis on checkrides since I started. When I got my instrument rating (30 years after I got my private), I had to show all the things that proved the flight was going to be legal:

1. Annual
2. Other required inspections: static/transponder/alitimeter/encoder/ELT
3. W&B
4. Required paperwork: manuals/supplements/airworthiness certificate/registration
5. Pilot certificate/medical
6. Pilot currency
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yes we teach students all this stuff, and prior to checkride we comb through the books. But once they are on their own. They aren’t going to do it it.
 
TommyG said:
yes we teach students all this stuff, and prior to checkride we comb through the books. But once they are on their own. They aren’t going to do it it.
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Again, because we “teach” it rather than “do” it.
 
TommyG said:
yes we teach students all this stuff, and prior to checkride we comb through the books. But once they are on their own. They aren’t going to do it it.
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A lot of places don't make it particularly easy. I can only think of one place I rented over the years that kept the logs at the rental counter. Usually, one had to rely on the "status board" for the times, etc...

Still that makes it fair game for the review. Nothing says what has to be in the review. I always figured that the FAA should probably give some periodic emphasis points sorta like they do on the tests. When we were having a lot of busts of the DC SFRA/FRZ from pilots transitioning from longer distances, making such awareness at a BFR a recommendation would have improved thing. The asinine "training for those who fly near DC" didn't help much because those who regularly were near DC already knew about it. It's Joe from Scranton, PA on his way to Sun 'n' Fun who creates the problems.
 
mondtster said:
Those ADs are often without documented compliance as the pilot and/or owner doesn't understand their responsibilities.
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This got me thinking about something else. AD’s where the pilot documents compliance, but either doesn’t know nuance or officially can’t sign off on compliance.

Example: When I do my oil change under owner maintenance, I always inspect my oil filter adapter- I look at the torque putty, make sure it’s in place with no loosening, and make sure the safety-wire is in place. Then I log the oil change, PLUS say that I complied with the oil-filter adapter AD by inspection of the torque putty.

One person has told me I can’t log the AD inspection. I can understand why; I may not have the training and background to know that particular AD, how ADs work, and mechanic stuff in general. Is my logbook now stained forever, dropping the value of my aluminum contraption?
 
455 Bravo Uniform said:
This got me thinking about something else. AD’s where the pilot documents compliance, but either doesn’t know nuance or officially can’t sign off on compliance.

Example: When I do my oil change under owner maintenance, I always inspect my oil filter adapter- I look at the torque putty, make sure it’s in place with no loosening, and make sure the safety-wire is in place. Then I log the oil change, PLUS say that I complied with the oil-filter adapter AD by inspection of the torque putty.

One person has told me I can’t log the AD inspection. I can understand why; I may not have the training and background to know that particular AD, how ADs work, and mechanic stuff in general. Is my logbook now stained forever, dropping the value of my aluminum contraption?
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The AD and regulations say that you not only can but that you must make the log entry. What is their stated reason for saying that you can’t?

(d) The repetitive inspections of the torque putty as required by this AD may be performed by the owner/operator holding at least a private pilot certificate as authorized by section 43.7 of the Federal Aviation Regulations (14 CFR 43.7), and must be entered into the aircraft records showing compliance with this AD in accordance with section 43.11 of the Federal Aviation Regulations (14 CFR 43.11).
 
Half Fast said:
I would have agreed up until last year when the FAA decided that "good will" was a form of compensation. If free instruction results in the grandkids loving grandpa and giving him a hug, today's FAA would likely decide that gramps had been compensated.
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SkyDog58 said:
The FAA declared goodwill to be compensation long before last year. But not just any form of goodwill, but rather goodwill in the form of expected future economic benefit. So just making someone warm and fuzzy would not qualify.

And while, the FAA sometimes take it a little too far, your example is bonkers, though I suspect it was meant to be. You old nut!
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Yeah, but what if you are expecting the grandkids to take care of you in your old age? That's an expected future economic benefit!
 
SkyDog58 said:
Let me see if I can help.

If all that your aircraft is used for is for personal, private flying by a certificated pilot, no 100 hour inspection is ever required, just the annual. You can even let me fly your plane for free or even charge me a bucket of money to fly it. Still, no 100 hour inspection requirement.

However, if you provide instruction in your aircraft, do an air tour business, or a 135 operation then a 100 hour will be required before doing any of those operations if the plane has exceeded 100 hours in service since its last annual.

What causes a snag in some people's thinking for some reason or another is what happens in particular situations once that 100 hour threshold occurs with mixed use aircraft. Let me explain what I mean by mixed use. Let's assume that you use your plane for your own personal flying, rent it to me for whatever amount, and you also provide instruction in it for which you are paid.

Now let's say that your plane has accumulated 100 hours since its last annual inspection. In that case, you can still fly it for your own use and I can still rent it from you without a 100 hour being accomplished. Both of these would be in compliance with the regulation. You could also provide free instruction to your grandkids or anyone else without doing the 100 hour. However once it does hit that 100 hour mark, it must be inspected prior to you providing compensated flight instruction.

I hope that wasn't too convoluted of an explanation for the simple concept that it really is.
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Yes that is my interpatation also .

If one is in a 135 or other operation for hire , if you exceed the 100 hour rule by 10 hours the next 100 hour inspection is due in 90 hours or when the Annual is completed . Which ever occurs first.
 
RyanShort1 said:
So I am genuinely very curious about how much of this was a review, how much was teaching, and if there were other things that you were rusty over.

My experience as an instructor is that most flight review participants who have a chance to prepare aren’t going to have too many hangups on the required portions of the ground review which are the actual regulations of part 91 per 14 CFR 61.56 (a)(1). I personally prefer to work through various scenarios to see if they have a working knowledge of the rules and their application. It’s not rocket science but sometimes somebody is rusty. That said, it would be a rusty individual who I felt needed 2 hours.
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I do classify myself as a rusty pilot. I'd last flown about 2 months ago with a regular instructor to help me get back on step. It's been several years since I'd flown solo and I am now mentally at the point where I even want to go solo again. Having a new instructor was a backstop for missing anything that might affect skin, tin or ticket and the fact the regular guy wasn't available was a bonus. The ad-hoc ground review was just to salvage the day because our flight was scuttled by a paperwork snafu. I considered that my regular guy would sign me off for FR when we were done with the agreed upon curriculum and I was legal again.

I, like everyone else have a bucket of knowledge in my head. Most of it I don't think about until/ unless someone asks. In the past, I've always relied on just staying current in the cockpit and investing time on PoA. The IFR course I took a few months ago had very little overlap on PPL (VFR) knowledge stuff.
 
Southpaw said:
Yes that is my interpatation also .

If one is in a 135 or other operation for hire , if you exceed the 100 hour rule by 10 hours the next 100 hour inspection is due in 90 hours or when the Annual is completed . Which ever occurs first.
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So let's say you're due for the 100 hour, but you don't perform it and just fly the plane personally for fun for 90 hours. Then you decide to give a flight lesson, so you have a 100 hr performed. Is that new 100 hr inspection only good for 10 hours before you have to do another one?
 
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