Spin Training and Parachutes

[tonycondon]

I was going through a FIRC last weekend put on by the Soaring Safety Foundation. While discussing regulations, we came to 91.307:

(c) Unless each occupant of the aircraft is wearing an approved parachute, no pilot of a civil aircraft carrying any person (other than a crewmember) may execute any intentional maneuver that exceeds—
(1) A bank of 60 degrees relative to the horizon; or
(2) A nose-up or nose-down attitude of 30 degrees relative to the horizon.
(d) Paragraph (c) of this section does not apply to—
(1) Flight tests for pilot certification or rating; or
(2) Spins and other flight maneuvers required by the regulations for any certificate or rating when given by—
(i) A certificated flight instructor; or
(ii) An airline transport pilot instructing in accordance with §61.67 of this chapter.

He said that the SSF had received an interpretation from the FAA stating that this exempted ALL spin training from parachute requirement, not just spin training specifically for the CFI license. It has been my long time understanding that spin training done for the CFI was the only training that was exempt. At first I was thinking he was talking about a practice of giving people who arent really going for the CFI license spin training without parachutes and calling it spin training towards the CFI, making the endorsement, etc. According to the presenter, the key words were "any certificate or rating" and that since spin training was required by the regulations for one certificate, that spin training while working on any certificate was permitted without chutes.

Hope I havent been too confusing.

Anyone hear of this? or anything similar? Im just trying to figure out how I (apparently) got misinformed.

And I am working on finding the presenters email address so that I can read the interpretation myself. If I get it, I will post.

 

[Diana]

While discussing regulations, we came to 91.307:
It has been my long time understanding that spin training done for the CFI was the only training that was exempt.

Anyone hear of this? or anything similar? Im just trying to figure out how I (apparently) got misinformed.

Tony this has been discussed on several forums before, and these are a few of the threads from AOPA with clarification on your question:

http://forums.aopa.org/showthread.php?t=7637&page=2

http://forums.aopa.org/showthread.php?t=9392

Hope that helps.

 

[tonycondon]

excellent diana. thanks!

 

[midlifeflyer]

Im just trying to figure out how I (apparently) got misinformed.

That part's easy. Just read all the other posts here and elsewhere where folks received and passed on incorrect interpretations on a variety of regulations. Then go back to your training and try to recall the incorrect things that were passed on to you by your CFI (unless he was one of the few perfect ones).

So, why should this one be any different?

 

[tonycondon]

yea, i know mark. i definitely didnt have a perfect CFI, especially for the initial, but my CFI instructor was pretty good and I thought he had all this stuff figured out...
at least i can stop passing crap along to my students now

 

[Grumman79L]

yea, i know mark. i definitely didnt have a perfect CFI, especially for the initial, but my CFI instructor was pretty good and I thought he had all this stuff figured out...
at least i can stop passing crap along to my students now

Tony;
Don't be too hard on your instructor(s)...I wouldn't expect to have ANY single CFI to have this or any question "figured out". It's all going to depend on who they were trained by and what they were told. You will pass on your wisdom to students and others down the line may well think it's "crap".
Why?
Because the FAR's are full of changes, revisions, exemptions and ambeguaties ( (SP)...I was attacked by a 6 pack of Coors Light) put together over the 80 years they have been written since the CAA (1920's) changed into the FAA. Even the FAA FSDO's don't agree on what is legal and/or allowed!
Remember; a Giraffe is a Horse built to the US Government specs!


JMPO and YMMV
Chris

Chris

 

[Lance F]

I'd like to turn this thread a bit. I wore a chute for something like 600+ hours while I was actively flying gliders. I always wondered if I'd really be able to use it if it became necessary. To me getting out of a glider after popping the whole canopy seems a whole lot easier than getting out of say the back seat of a Citabria.

So the question is, how practical is it wearing a chute in a small ASEL while practicing spins? Are there ANY documented cases of successful egresses in botched spin practice. I am not talking about specific aerobatic practice, just upset type training.

 

[tonycondon]

I also wear a chute when in the glider, but I am two pins, unlatch harness and stand up from getting out. My CFIG, who i am transitioning to power flying, likes to fly power with parachute as well. I cant really come up with an argument not too, he is especially adamant about it at night. I think it would be difficult at best to push the door of a 172 open enough in flight to be able to egress. This is why aerobatic airplanes have quick release pins on the INSIDE of the doors so the pilot can just chunk the whole stupid thing and not have to worry about opening it. I dont know of any egresses during spin training.

diana wrote a good article in sport aerobatics (?) about egress training kids for acro rides in the citabria. after some practice they got the time down to a few seconds i believe.

 

[Steve]

I have two red handles in the overhead.

 

[CJones]

The RV has one handle to twist. Slide the canopy back 3 inches and let the wind do the rest. Unless you are in an inverted flat spin. *yikes*

-Chris

 

[Scott 'Gunny' Perdue]

I'd like to turn this thread a bit. So the question is, how practical is it wearing a chute in a small ASEL while practicing spins? Are there ANY documented cases of successful egresses in botched spin practice. I am not talking about specific aerobatic practice, just upset type training.

Lance-

A good question.

Let me just say about the first part of this thread.... unless you have an interpreataion letter from a FSDO or the FAA HQ then you have an opinion that will not stand up at your violation hearing. Interpret the FAR's strictly and you'll be better off. In the case of spin training without chutes I think it is pretty clear... only for CFI training... but in my opinion not a good idea. (I made my CFI instructor come fly with me in my Stearman and do REAL spins... for that 'sign off').

Now whether you can get out or not.
-The short answer is if you were in a situation where you could get out... it would be great to have that chute rather than ride the airplane to the crash site.
-Getting out depends on the rotational rates... there are instances where the accelerations are so high that you would have to be VERY strong to overpower them.
-For most GA spins that is not so much of a problem... in aerobatic aircraft (in the Citabria/Decathlon line it is more difficult due to the high wing).
-The real problem is decision recognition and execution... I've written several articles on this for the IAC Sport Aerobatics Magazine... and the bottom line is that you have to decide on the ground what your decision points are... and then if you hit those in the air... you execute... have a bailout altitude floor... practice your egress... go over your plan in your mind... then go fly... and I'd say with that chute... it might just save your life.

 

[poadeleted20]

Let me just say about the first part of this thread.... unless you have an interpreataion letter from a FSDO or the FAA HQ then you have an opinion...

The FAA interpretation consistent with what was stated above is on record -- no chutes needed for spin training as described in 14 CFR 61.183(i) even if the trainee is only a Student Pilot. Beyond that, it's up to your own personal risk tolerance.

 

[Ed Guthrie]

...I think it would be difficult at best to push the door of a 172 open enough in flight to be able to egress...

It isn't as difficult as you might think if you slow the aircraft. There is a local skydiver at Smoketown who exits the airport's C172 all the time with the doors attached.

 

[Scott 'Gunny' Perdue]

The FAA interpretation consistent with what was stated above is on record -- no chutes needed for spin training as described in 14 CFR 61.183(i) even if the trainee is only a Student Pilot. Beyond that, it's up to your own personal risk tolerance.

Would it be possible to get a copy of that interpretation?

 

[poadeleted20]

Would it be possible to get a copy of that interpretation?

Sure...write to:

Federal Aviation Administration
Office of the Chief Counsel
General & Commercial Aviation Division (AGC-230)
800 Independence Avenue
Washington DC

 

[Diana]

-The real problem is decision recognition and execution... I've written several articles on this for the IAC Sport Aerobatics Magazine.

Scott, which issues? I'd be interested in going back through my old issues and reading them.

Thanks.

 

[wesleyj]

actually if you read all of that, it makes it pretty clear that they mean any training, how you might ask,

the referance to training given by an ATP, the only training an ATP can give is to an ATP candidate.

 

[Scott 'Gunny' Perdue]

Scott, which issues? I'd be interested in going back through my old issues and reading them.

Diana-

I wrote fairly frequently for the magazine from about 96, 97 till around 2002... especially for the May Safety issue. Bruce Johnson and I did the accident review colmun for a number of years.

For the specific issues I'd have to dig them out of the stack in my hangar... the ones I get paid for I list on my website<g>.

 

[Scott 'Gunny' Perdue]

The FAA interpretation consistent with what was stated above is on record -- no chutes needed for spin training as described in 14 CFR 61.183(i) even if the trainee is only a Student Pilot. Beyond that, it's up to your own personal risk tolerance.

Well... I think if you read 14 CFR 61.183 you will see that it is part of Sub-Part H... the entire section addresses Flight Instructors (other than Sport Pilot). In particular 61.183i lists items that must be accomplished for a flight instructor certificate with an airplane or glider rating.

To me that is pretty clear-cut to only apply to training leading to a CFI.

Perhaps another reference?

 

[poadeleted20]

Well... I think if you read 14 CFR 61.183 you will see that it is part of Sub-Part H... the entire section addresses Flight Instructors (other than Sport Pilot). In particular 61.183i lists items that must be accomplished for a flight instructor certificate with an airplane or glider rating.

To me that is pretty clear-cut to only apply to training leading to a CFI.

Perhaps another reference?

As I said before, the question was asked of and answered by the FAA. If you need a copy of that answer, contact the Chief Counsel's office at the address above. There's nothing that says you have to accept that answer, i.e., you can insist on wearing parachutes when doing spin training with someone other than a CFI candidate, but the FAA is on record as saying it's not legally necessary, and that the spin training may be given without parachutes at any time in the pilot's training career, not just when specifically in training for the CFI ticket.

 

[Scott 'Gunny' Perdue]

As I said before, the question was asked of and answered by the FAA. If you need a copy of that answer, contact the Chief Counsel's office at the address above. There's nothing that says you have to accept that answer, i.e., you can insist on wearing parachutes when doing spin training with someone other than a CFI candidate, but the FAA is on record as saying it's not legally necessary, and that the spin training may be given without parachutes at any time in the pilot's training career, not just when specifically in training for the CFI ticket.

Ok, I choose to wear the chutes. One less thing to worry about.

 

[midlifeflyer]

To me that is pretty clear-cut to only apply to training leading to a CFI.

Okay. And does that start after the pilot files something with the FAA that says, "I'm planning to be a CFI"? Or does the student pilot sign something in the flight school to say, "this is leading up to my CFI?" Or, perhaps you know the regulation that says that one can't obtain training leading up to the CFI until a certain number of hours or certificates have been accomplished?

I know the interpretation that Ron refers to, but I've always been curious how folks who insist they need to be worn answer these questions.

 

[Scott 'Gunny' Perdue]

Okay. And does that start after the pilot files something with the FAA that says, "I'm planning to be a CFI"? Or does the student pilot sign something in the flight school to say, "this is leading up to my CFI?" Or, perhaps you know the regulation that says that one can't obtain training leading up to the CFI until a certain number of hours or certificates have been accomplished?

I know the interpretation that Ron refers to, but I've always been curious how folks who insist they need to be worn answer these questions.

Seems to me that this is in the realm of 'How many angels can dance on the head of a pin." type question. I am not familiar with Ron's interpretation reference... and it really doesn't matter to me.

1) I can't see how the verbiage in one section can be imported into another... 61.183 applies only to candidates for the CFI.

2) The FARs are, more often than not, minimums. I chose to wear chutes for many reasons... probably the least of which is an FAR requirement. If you came to me for a CFI spin training... we would wear chutes and I would go into more detail as to the whys (again i've written on this subject in Sport Aerobatics). If you don't want to wear a chute when you fly with me... then I suppose we won't fly together.

I choose to wear chutes... and if that exceeds the FARs and subsequent intrepretations... then that's ok.

 

[tonycondon]

sounds fine to me Scott, no one is saying its wrong to wear chutes, just dont have to. Heck I wear a chute every time i fly my glider, and I rarely exceed 50 degrees of bank or 10 degrees pitch. But, the thing is 40 yrs old, made from wood, and I just put it together and hooked up the flight controls. I just hope that if something decides to let go, it waits until ive got enough altitude to bail

 

[jesse]

it waits until ive got enough altitude to bail

What altitude would that be? Do you tell yourself when you climb through that altitude that in the event of a loss of control you will jump? Do you tell yourself as go below that altitude that in the event of a loss of control you will fly it to your grave?

Something tells me a lot of parachuting wearing pilots probably don't, and wouldn't be sure if they could jump or not when the **** hit the fan...effectively making the parachute worthless.

 

[tonycondon]

good point jesse. From what ive heard, modern chutes will be able to come out with 1000 feet. I dont have a hard floor, but i think im going to now! Im thinking no jumping below 1500, give me time to get out and remember where the ripcord is, etc. Any jumpers on board with better ideas?

 

[midlifeflyer]

1) I can't see how the verbiage in one section can be imported into another... 61.183 applies only to candidates for the CFI.

I'm not sure what you mean by "imported." Are you suggesting that every section of the FAR that talks about "aircraft" can't rely on the definition in FAR 1.1?

The FAA's interpretation has to do with the words used in 91.307(d). 91.307(c) sets out the general parachute requirement, and then (d) dives the exception:

==============================
Paragraph (c) of this section does not apply to ... Spins and other flight maneuvers required by the regulations for any certificate or rating...
==============================

The FAA is looking at the words and saying that if a maneuver is required for "any certificate or rating," you don't need a parachute to teach it.

You are adding the words, "but only when the pilot is actively pursuing the certificate or rating that requires the maneuver at the time the maneuver is performed." That's a lot of extra words and requires the pin dance you are talking about. That's why I asked those questions.

The FAA is unwilling to do your pin dance:

==============================
Regardless of what certificate or rating the applicant is seeking, an acrobatic maneuver required for any pilot certificate or rating (even one not presently sought by the applicant) may be performed without parachutes when done by, or at the direction of, a certificated flight instructor.

- 1977 FAA Legal opinion
==============================

 

[Scott 'Gunny' Perdue]

I'm not sure what you mean by "imported.".... The FAA is unwilling to do your pin dance:

Mark-

In this case it is you doing the pin dance.... I suggest you re-read this thread to get a better feel for who said what and what it related to. I responded to someone's assertion that 61.183i allowed spin training without a parachute for any other student... my response was don't see how you can make that connection... and asked if perhaps there wasn't another FAR reference... the response to that question was advice to seek an interpretation from the FAA... and now you lecture me that I am dancing on the head of a pin.... sorry Mark, but you got it backwards.

In point of fact I tried to make it clear that I don't really care whether the FAA requires a parachute for training for a certificate or rating... I choose to wear them anyway... and if you fly with me you'll wear them as well.

So, congratualtions that you have found another reference that supports the idea that it is ok to do spin training without a chute... but you are directing at the wrong audience.

 

[midlifeflyer]

Mark-

In point of fact I tried to make it clear that I don't really care whether the FAA requires a parachute for training for a certificate or rating... I choose to wear them anyway... and if you fly with me you'll wear them as well.

Point taken. I thought you were arguing that the FAA requires them and suggesting that taking the position that you must be "going for" a specific rating at the time requires the pin dance indicated by my series of questions.

As CFI teaching any maneuver, aerobatic or normal, you are entitled to (in fact, to be congratulated for) setting your own higher standards for safety.

Sorry for the misunderstanding.

 

[Scott 'Gunny' Perdue]

Sorry for the misunderstanding.

No worries.

 

[Dave Siciliano]

good point jesse. From what ive heard, modern chutes will be able to come out with 1000 feet. I dont have a hard floor, but i think im going to now! Im thinking no jumping below 1500, give me time to get out and remember where the ripcord is, etc. Any jumpers on board with better ideas?

Tony:

My perspective isn't completely up-to-date. I jumped in the military from static lines and our lowest allowable was 800 feet---from a static chute. There wasn't a lot of time in the air until ground impact at that altitude. This was in a training environment--in combat conditions, a jump could be from a lower altitude. There was little time to think through things.

Having just flown in an Extra, I can see where it could take some time to make the bail out decision, release the canopy, climb out of the front seat and jump from the plane; from there, one would have to get oriented, stabilized and deploy the chute. All this would be right after something else of an emergency nature occurred which lead to the exit decision.

My point is, I would set a higher floor, even with the jump experience I have--unless you just need adrenaline rush after adrenaline rush and can think and act completely clearly through those. Even assuming that, you're not allowing for anything to delay you or complicate things like exit difficulty, confusion, anything slowing exit, etc.

We used 3,000 feet yesterday, which I thought was much more reasonable.

Best,

Dave

 

[tonycondon]

jumping form 800? Thanks for the input Dave.

 

[bbchien]

So the question is, how practical is it wearing a chute in a small ASEL while practicing spins? Are there ANY documented cases of successful egresses in botched spin practice. I am not talking about specific aerobatic practice, just upset type training.

There was one over Monterey Bay last summer, IIRC. I haven't tried to look it up, though.

I would like to have a copy of that letter. REALLY.

 

[gibbons]

Sure...write to:

Federal Aviation Administration
Office of the Chief Counsel
General & Commercial Aviation Division (AGC-230)
800 Independence Avenue
Washington DC

I dropped the letter in the mail yesterday. I'll post their response when/if I hear back.

Chip

 

[SkyHog]

OK - what about this:

You have every single rating there is. Does that mean you can no longer claim it as a training towards a rating?

 

[midlifeflyer]

OK - what about this:

You have every single rating there is. Does that mean you can no longer claim it as a training towards a rating?

LOL. I like that one.

 

[gismo]

OK - what about this:

You have every single rating there is. Does that mean you can no longer claim it as a training towards a rating?

Since one of those "ratings" ought to be a CFI certificate, you should be able to claim that you were giving training towards a rating as long as there was another pilot on board with fewer ratings.

 

[poadeleted20]

You have every single rating there is. Does that mean you can no longer claim it as a training towards a rating?

I did not see an exclusion for refresher training. Note that it doesn't say you're training for a certificate/rating, just that it's training which the regs say is required for some certificate/rating, whether you're currently pursuing that certificate/rating or not.