AMEL pilot, do I need a complex endorsement to log multi
- Thread starter henryqs1
- Start date
Blackhawk
Well-Known Member
You did not finish the paragraph:
"(1) A commercial pilot certificate with the appropriate category and class rating.
(2) An instrument rating with the appropriate aircraft rating
(3) A type rating."
Nothing at all about the appropriate HP endorsement, nor the complex endorsement. You might say "but the HP/complex endorsement are ratings"... but they are not. "Under the plain language of the regulation, the additional training requirements specified in 61.31 (e) through (j) are not ratings limitations. (Taylor Grayson letter dated Jan 4 2010... yes, that Grayson).
Again, 61.31(e) and (f) are very clear and do not contain any exceptions for military experience. "... no person may act as a pilot in command... unless that person has- (ii) Received a one-time endorsement in the pilot's logbook..." Yet 61.31(g) does contain an exception for military experience. If 61.73 was a blanket to cover any and all related flight training a military pilot might have had, 61.31(g) would not have an exception. Yet it does.
Blackhawk
Well-Known Member
And they normally won't. The only time it might come up is after an accident when the FAA asks to see your logbook with the required endorsements.
Blackhawk
Well-Known Member
There is not one that I am aware of that deals with this specifically, but there are plenty that deal with logbook endorsements not being correct or not being present:
http://www.ntsb.gov/alj/alj/O_n_O/docs/aviation/4634.PDF
This case is pertinent as the pre-solo training was obviously done but the training was not properly endorsed. In finding against the CFI the NTSB judge rules that it is pointless to have clear language stating an endorsement must be present if you then don't have to put the endorsement in the logbook. Again, I cite 61.31(e)(f) that are quite clear on the required endorsement that must be present. You have yet to give me a reference that it does not need to be present. You are recommending on a public website that pilots risk possible enforcement action and legal fees by ignoring a very explicit FAR with nothing to back it up but "it's not logical"???
z987k
Well-Known Member
Huh, a google of his name - or rather his name with 4 Jan 2010 gives 2 letters from the FAA as top results.
Blackhawk
Well-Known Member
Hacker15e
Who am I? Where are my pants?
All I'm doing is asking the question. How are you getting that I'm "recommending" something?
You are the one stating that there were clear NTSB legal decisions on this matter, and I was asking if you could provide specific citations of which ones they were.
Clearly I do believe that the position doesn't make sense, but I'm not arguing that it's not correct by the books. I don't know. If I did know for certain, don't you think I'd provide something?
Blackhawk
Well-Known Member
I have seen a number of incidents where situations like this came up.
1. Going for my 135 CP ride with a company that flew 210s and 310s. The POI wanted to see my HP/complex endorsements even though I had type ratings. He said it was silly, but required for our operations. For those who think you do not need a HP/complex endorsement to fly 135 I would strongly differ. If the aircraft does not require a type rating, then it would require an endorsement if it meets the requirements of 61.31.
2. I did a contract to train a military pilot for his CFI. Pilot needed the complex endorsement to take his check ride with the FSDO and the FAA inspector did check. In addition, even though this pilot had flown military TW aircraft (yes, the military does have one or two around), he needed a TW endorsement to fly the civilian TW aircraft. Just as there was nothing in the regulations to cover the complex/HP endorsement, there was nothing to cover the TW endorsement.
There are no legal decisions or interpretations on the endorsements required for military pilots. There is only the regulation and legal precedents on log book endorsements in general. In the absence of the former and the presence of the latter I would strongly encourage pilots to get the endorsements unless you want to be the guinea pig. Being the guinea pig before an NTSB judge can be very expensive and detrimental to a career.
1. Going for my 135 CP ride with a company that flew 210s and 310s. The POI wanted to see my HP/complex endorsements even though I had type ratings. He said it was silly, but required for our operations. For those who think you do not need a HP/complex endorsement to fly 135 I would strongly differ. If the aircraft does not require a type rating, then it would require an endorsement if it meets the requirements of 61.31.
2. I did a contract to train a military pilot for his CFI. Pilot needed the complex endorsement to take his check ride with the FSDO and the FAA inspector did check. In addition, even though this pilot had flown military TW aircraft (yes, the military does have one or two around), he needed a TW endorsement to fly the civilian TW aircraft. Just as there was nothing in the regulations to cover the complex/HP endorsement, there was nothing to cover the TW endorsement.
There are no legal decisions or interpretations on the endorsements required for military pilots. There is only the regulation and legal precedents on log book endorsements in general. In the absence of the former and the presence of the latter I would strongly encourage pilots to get the endorsements unless you want to be the guinea pig. Being the guinea pig before an NTSB judge can be very expensive and detrimental to a career.
Nihon_Ni
Well-Known Member
Hacker, I think the point you may have overlooked is that T-6, C-12, F-15 etc. are not registered airplanes, which is why military pilots can fly them without a FAA pilot license. The FAA gives military pilots some short cuts to get civil ratings based on their military experience. I agree with you, it doesn't make sense that the complex & high performance endorsements aren't included, but it's not the first time I've disagreed with the FAA.
ryan1234
Desensitized Member
Not sure that makes a difference for these practical purposes (endorsements):
(j) Aircraft requirements for logging flight time. For a person to log flight time, the time must be acquired in an aircraft that is identified as an aircraft under §61.5(b), and is—
(1) An aircraft of U.S. registry with either a standard or special airworthiness certificate;
(2) An aircraft of foreign registry with an airworthiness certificate that is approved by the aviation authority of a foreign country that is a Member State to the Convention on International Civil Aviation Organization;
(3) A military aircraft under the direct operational control of the U.S. Armed Forces;
I believe that this shows the FAA gives credit of logging time in military aircraft towards aeronautical experience for rating/certificates
Furthermore, many endorsements do not pertain to military pilots because they are implied:
Spin Endorsements for CFI (mil-comp)
Specific rating/certificate testing requirements.
drunkenbeagle
Gang Member
If he had logged tailwheel PIC time before April 1997, even military, I believe he would be exempt from requiring the endorsement.
fftopic: ...BUT check out this 
Blackhawk
Well-Known Member
Nope, it was only recent. We're not talking about an old timer.
ryan1234
Desensitized Member
Any multi engine jet is not technically a complex airplane.
elmetal
Ain't nobody got time for that
Lord Technicality back again!
That is so true though, but who learns multi/complex in a multijet anyway?
Autothrust Blue
Welcome aboard the Washington State Ferries
I think that was the subject of Avweb's FAA versus Airman-Be Afraid story...(This one)
Blackhawk
Well-Known Member
Thanks- that's the one. I could not find it.
Autothrust Blue
Welcome aboard the Washington State Ferries
The particularly ironic/tragically hilarious part of that whole affair is that the student crashed precisely on the centerline of his planned route. Considering that the flight instructor in question was being accused of failing to provide navigation training...I think it's safe to say the training was given...
Hacker15e
Who am I? Where are my pants?
What I got out of that article had absolutely nothing to do with the topic of this thread. What I got was, if the FAA decides they want to do something, the entire "system" is set up to support the FAA and not give the certificate holder any reasonable means of fighting the initial decision.
Meaning, even if you do follow the rules to a T and beyond, that is no guarantee that certificate action will not or can not be taken.
The fact that this case dealt with a former military pilot was simply a side issue.
Autothrust Blue
Welcome aboard the Washington State Ferries
The tl;dr of it is: "It's probably best that nobody you are responsible for crashes, no matter how much you've done your job or covered yourself, it'll still be your (possibly ticket punching) problem."
Like everything else on JC, the thread topic and thread content are divergent...