Cri Cri license endorsement ?

Discussion in 'General Experimental Aviation Questions' started by MadProfessor8138, Oct 31, 2019.

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  1. Oct 31, 2019 #1

    MadProfessor8138

    MadProfessor8138

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    If this question has been asked before I apologize but my search didn't turn up an answer to my question.
    To legally fly an aircraft like the Cri Cri....do you need a twin engine endorsement on your license ?

    The reason I'm asking this question is because I'm getting close to finishing my plans for an A-10 Warthog and it occured to me that a twin engine endorsement may be necessary if I ever build the plane.

    Kevin
     
  2. Oct 31, 2019 #2

    Patrickh99

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    If the plane has more than one engine, you need a multi-engine rating on your pilot's certificate. Cri-cri, Seneca, A-10; aircraft model does not matter, only engine quantity.

    Excluding of course, any aircraft requiring type ratings. You can't fly a B737 or A320 with just a multi-engine rating.
     
  3. Oct 31, 2019 #3

    Hot Wings

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    This is a very debatable question and depends on several variables, one of which is the operating limitations for that particular plane. Another is the FAA's regulations one of which suggests that if the plane is licensed Experimental, and flown solo, you will not need more than a private or solo endorsement.

    IMHO it is kind of like the situation we find with part 103 - don't do anything dumb, stay out of the way and no one will care.
     
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  4. Oct 31, 2019 #4

    Vigilant1

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    It depends on what is written in the airplane's operating limitations. Hot Wings is correct, there is a way to read the regulations so that multi-engine E-AB aircraft, if flown solo, does not require that the pilot have a multi-engine rating or endorsement. However, the DAR has a lot of latitude to include various restrictions and requirements in the OLs, and could require that anyone flying it have a multi-engine rating or endorsement.
    Check the Micromaster thread for details.

    Edited to add: There are about 10 posts that you'll find useful in the Micromaster thread regarding legalities. The fun starts here, later posts include snippets from some of the appropriate regs, and Post 734 provides an EAA response to this issue that is specific to the Cri-Cri. BBerson helpfully suggested that a multiengine solo endorsement (rather than a rating) might do the trick, but I'm hopeful, at least in the case of the Micromaster (which would be true centerline thrust) even that can be avoided. I haven't found the right DAR to ask, though.

    If you re interested in a Cri-Cri, see if you can ask the question of a US-based Cri-Cri pilot (there aren't many).
     
    Last edited: Oct 31, 2019
  5. Oct 31, 2019 #5

    Victor Bravo

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    There is also the "centerline thrust" Twin Engine rating, created originally because of the Cessna Skymaster. This was a simplified and less difficult twin engine rating.

    The Cri-Cri's engines, and the A-10's engines, are close enough to the aircraft centerline that you might be able to get an approval to include those airplanes into the "centerline thrust" category, because while not on the centerline they are much closer than traditional twins with the engines further out on the wings.

    An engine failure in a Cri-Cri (Or possibly an A-10 replica) is not likely to cause the wild yawing moment and incpient spin that you would have in a "normal" twin engine airplane like a Baron, Seneca, Twin Comanche, etc.

    I'm guessing that the full-size A-10 has enough thrust available from those big fans that you would need a fair amount of rudder and a minimum speed, which is closer to having an engine out in a conventional twin.
     
  6. Oct 31, 2019 #6

    Dana

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    The FARs are clear, they don't require any particular rating for a experimental aircraft being flown solo. BUT...

    I don't think the DAR has any latitude any more; the operating limitations are supposed to be issued according to the template in FAA order 8130.2, one line in which says, "The pilot in command must hold all required ratings or authorizations and endorsements required by part 61." But if an aircraft has older op lims that don't include that language, then the rating is not required.

    The old limitations for my Hatz didn't include that line; the current ones do.
     
  7. Oct 31, 2019 #7

    Vigilant1

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    If the DAR doesn't ave any discretion and must use the boilerplate, isn't that good news in this case? The specific language of Section 61 helps us, I think, as the pilot of an E-AB flown solo doesn't need to meet the category and class requirements. From a previous post:
    ++++++++++++++++++++++++++++++++++++++++++++++++++s ++++++++++++++++++++++++++++++++++++
    The boilerplate language often used for the Operating Limitations these days says:
    Well, anyone with a PPC/SEL meets that requirement.
    And the next line of boilerplate reads:



    Section 61.31 is all about type rating requirements, additional training, and authorization requirements. (e) is for complex airplanes, (f) is for high performance airplanes, (g) is pressurized airplanes, (h) is "additional type-specific training, (i) is tailwheel acft, and (j) is gliders. At the end of that section we have this which would seem to exclude E-AB aircraft from the requirements of § 61.31 (since they aren't type-certified):
    And to make it more clear:
    EAA's answer to a question about whether a Cr-Cri pilot requires an MEL rating cited the above regs, but then said:
    So, it seems to me (and I'm not a lawyer), that if the new "boilerplate" used by the DARs is read as requiring a pilot to have an MEL for a Cr-Cri, then that is contrary to § 61.31 (l)(2)? Instead, the boilerplate OL's should be read to mean that the pilot of the plane must hold all applicable category and class ratings as provided in Section 61 (to include exclusions a provided in § 61.31 (l)(2) )
     
    Last edited: Oct 31, 2019
  8. Oct 31, 2019 #8

    MadProfessor8138

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    The answers given so far validate the reason I proposed the question in the first place.
    While not trying to start a finger pointing campaign or anything,I will make this statement.......the FAA rules & regs. are confusing and open to interpretation.
    I think the FAA does this intentionally...that way they can have a "Gotcha" in their pocket if they ever decide to come talk with you....you're damned if you do and damned if you don't....the call is at their discretion.
    I'm wondering if it's possible to be cleared on the subject by one representative and then snagged by another that doesnt agree with the initial clearance......

    Kevin
     
  9. Oct 31, 2019 #9

    BBerson

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    1. The current operating limitation seems to exclude a new student with only a student pilot certicate from ever doing a solo flight in a Homebuilt. Of course, any student pilot can still solo a Certificated C-150.
    I mentioned this to Joe at EAA and he said student solo was still allowed in homebuilts but he didn't explain.
     
  10. Nov 1, 2019 #10

    dino

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    I think most Cri Cri can't maintain altitude on one engine.
     
  11. Nov 1, 2019 #11

    Victor Bravo

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    Yes, they do have that card to play, but IMHO it is not intentionally done to impose Draconian terror on the masses.

    The FAA ASI's (Air Safety Inspectors) are truly the last line of defense between Uncle Budweiser's Duct Tape Special and that schoolyard full of children singing Kum-Ba-Ya 500 feet underneath. For the most part, they really do take it very seriously, and they do have the weight of public safety on their shoulders. So when they see something or somebody that they really don't think should be in the air, the "flexibility" interpreting the rules is something they can use for the right reason.

    Are there cases where they go too far, or get power-mad and Draconian, or are having a bad day and come down on someone like a ton of fertilizer? Of course, we've all heard the stories.
     
  12. Nov 1, 2019 #12

    bmcj

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    I know the DAR can approve flight profiles, but do they ever specify pilot qualifications? Doesn’t that normally default to the written regulation?
     
  13. Nov 2, 2019 #13

    MadProfessor8138

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    Victor Bravo..... i agree with your viewpoint.... there are times when they should step in and take action and you will get no arguments from me on that issue.

    My viewpoint is from the common mans perspective though......how do you expect the masses to play by the rules and be good little aviators when 95% of the people "THAT ARE PAID" to know and enforce the rules "DON'T UNDERSTAND THE RULES THEMSELVES" ???
    Everything seems to be written in the fashion that calls for interpretation per situation.
    Nothing with the FAA ever appears to be black or white....right or wrong.

    I did quite a bit of searching for an answer to my original question,before I posted it here, and came up with a yes/no/maybe answer.....depends on who you ask.

    The whole thing really should be much easier to navigate.........

    Kevin
     
  14. Nov 2, 2019 #14

    Victor Bravo

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    Are you talking about life in general, the menu at Starbuck's, getting some tail in high school, the business world, or just the FAA in particular ? :)
     
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  15. Nov 2, 2019 #15

    MadProfessor8138

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    Just the FAA in general......lol
    A simple yes/no or black/white approach with their written regulations would make everyone's life so much easier......

    Kevin
     
  16. Nov 2, 2019 #16

    Vigilant1

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    The US tax code is even more complicated, and taxpayers aren't protected (from fines or penalties) even if they follow guidance that is provided by an IRS employee. To address the most serious areas of uncertainty, the IRS will issue a "letter ruling" that does serve as definitive guidance.
    We could use something like that concerning multi-engine, single seat E-AB aircraft, and it would be great if the EAA would ask the question. Because we'll only get to ask it once, and if the answer comes back against us, we're done.
    It seems to me that the words in Section 61 are clear (if convoluted) and that no multi-engine rating is required for a private pilot to fly a multi-engine E-AB if there is no passenger aboard. If the FAA wants things to be different, then they should change the CFR (specifically, they should eliminate the exception provided in § 61.31 (L)(1) and § 61.31 (L)(2) (that's a lower case "L" in the reg)
     
    Last edited: Nov 2, 2019
  17. Nov 2, 2019 #17

    BBerson

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    EAA said Operating Limitations supersede FAR 61.31
    61.31 gives the local office flexibility with experimental, but it doesn't apply to all experimental.
    In other words an X-15 over Edwards is treated different than an EA-B in class G.
    So the FAA can do as they want.
    We can interpret the rules as we choose until something happens.
    Plenty of EA-B owners have never heard of operating limitations.....
     
  18. Nov 2, 2019 #18

    Vigilant1

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    Okay, but Dana (Post 6) indicated that the OLs are now very uniform, and they say "
    Well, that would be fine, right? Because Part 61 (specifically Part 61.31(L) (1). and Part 61.31(L)(2) allow a person with a valid pilot certificate to operate an E-AB solo without the category and class restrictions.
    Or, are you saying that the OL boilerplate says/means "If this airplane has two engines then only a person with a MEL or multi-engine solo endorsement may operate it, despite the specific language allowing such operation as found in Part 61". If that's the case, I'd sure go to the mat for a single-seat centerline thrust plane like the Micromaster concept, as requiring time ( or a checkride) in an Aztec (or even a Skymaster) is just silly.
     
  19. Nov 2, 2019 #19

    BBerson

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    That operating limitation needs to be read carefully. I don't think it even mentions the words solo endorsement.
    The word "endorsement" means the same as "rating" for a Sport Pilot. It's all absurd. I can't give any further useful comment and I don't think anyone can. Best not to ask for clarification sometimes.
     
  20. Nov 2, 2019 #20

    GeeZee

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    Not sure how helpful this is but I recall reading an article written by a Cri Cri builder who was using it to build multi engine time.
     

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