bob loblaw said:
I know that a CFI can give spin training to a CFI candidate without wearing a parachute. But I don't see anywhere in the regulation an exemption provided for a CFI giving spin training to a private pilot. I will be the first to admit that I don't know it all, but the reg speaks for itself. If I am correct and you may not call filming spins "training" then you may have some splaining to do since you have a great shot of your face while doing the spins.
Another JC member PM'd me over this exact same issue. Here is a copy of my response to him:
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I'm well aware of the regulations regarding parachutes during aerobatics. In fact, I discuss the regulatory use of parachutes with my students before we do spins, and I point out specifically why we are exempt from the regulation requiring parachutes.
The FAA is quite clear about the fact that if a flight is an instructional flight, parachutes are never required for spins, even though it is not spelled out very clearly in the regs. It doesn't matter if the student is using the flight to train for a CFI certificate or not. The logic behind this stance is that every rating requires spin awareness and actually doing spins is a valid way to become aware of them.
Advisory Circular 61-67C, Stall and Spin Awareness Training, is the most authoritative document that I know of that outlines the FAA's stance on performing spins. On page 14 of that document, it says:
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b. Because spin entry, spins, and spin recovery are required for a flight instructor certificate or rating, a person receiving instruction from a CFI (or an ATP instructing in accordance withsection 61.167) need not wear an approved parachute while instruction is being provided in these maneuvers.
This provision applies regardless of the certificate or rating for which the person is receiving training and also if the person is receiving instruction that is not being provided for the purpose of obtaining any additional certificate or rating. The instructor providing the training is also not required to wear an approved parachute while providing this flight training.
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(my emphasis added)
Here is a link to the AC in PDF form:
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/a2fdf912342e575786256ca20061e343/$FILE/AC61-67C.pdf
I know this is a commonly debated issue, but I'm very confident I did not break any regs.
Now, had we just gone out to goof around, I was not acting as an instructor, I performed a spin, and my friend just sat there, being a passenger, that would be a problem...
I hope I cleared things up. If you still aren't convinced of my position, please let me know. I'm willing to look at more evidence, but I think the advisory circular spells it out pretty well.
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As for videotaping the spins...since when does videotaping training make it no longer training? The clips don't include anything other than the actual spins. You don't hear the discussions we were having over the intercom, discussing the various elements of each spin. You don't hear the points I was making before and after each spin.
And for plastering my face on the video...I'm not trying to hide anything. If somebody really wanted to find out who made the video, they could find me, face or no face. We didn't break any regs, so what would I try to hide?