Instrument Rating Plan Of Action
I. Preflight Preparation
A. Pilot Qualifications
B. Weather Information
C. Cross-Country Flight Planning
II. Preflight Procedures
A. Airplane Systems Related to IFR Operations
B. Airplane Flight Instruments and Navigation Equipment
C. Instrument Flight Deck Check
III. Air Traffic Control Clearances and Procedures
A. Compliance with Air Traffic Control Clearances
B. Holding Procedures
IV. Flight by Reference to Instruments
A. Instrument Flight
B. Recovery from Unusual Flight Attitudes
V. Navigation Systems (Note – The ACS requires a current database for the checkride. The GPS supplement in the POH may allow for IFR operations with an expired database).
A. Intercepting and Tracking Navigational Systems and Arcs
B. Departure, En Route, and Arrival Operations
VI. Instrument Approach Procedures
A. Nonprecision Approach
B. Precision Approach
C. Missed Approach
D. Circling Approach
E. Landing from an Instrument Approach
VII. Emergency Operations
A. Loss of Communications
B. Approach with Loss of Primary Flight Instrument Indicators
VIII. Postflight Procedures
A. Checking Instruments and Equipment
Eights On Pylons
The eights-on-pylons is the most advanced and difficult of the ground reference maneuvers. Because of the techniques involved, the eights-on-pylons are unmatched for developing intuitive control of the airplane. Similar to eights around pylons except altitude is varied to maintain a specific visual reference to the pivot points.
The goal of the eights-on-pylons is to have an imaginary line that extends from the pilot’s eyes to the pylon. This line must be imagined to always be parallel to the airplane’s lateral axis. Along this line, the airplane appears to pivot as it turns around the pylon. In other words, if a taut string extended from the airplane to the pylon, the string would remain parallel to lateral
axis as the airplane turned around the pylon. At no time should the string be at an angle to the lateral axis. In explaining the performance of eights-on-pylons, the term “wingtip” is frequently considered as being synonymous with the proper visual reference line or pivot point on the
airplane. This interpretation is not always correct. High-wing, low-wing, sweptwing, and tapered wing airplanes, as well as those with tandem or side-by-side seating, all present different angles from the pilot’s eye to the wingtip.
The visual reference line, while not necessarily on the wingtip itself, may be positioned in relation to the wingtip (ahead, behind, above, or below), and differs for each pilot and from each seat in the airplane. This is especially true in tandem (fore and aft) seat airplanes. In side-by-side type airplanes,
there is very little variation in the visual reference lines for different persons, if those persons are seated with their eyes at approximately the same level. Therefore, in the correct performance of eights-on-pylons, as in other maneuvers requiring a lateral reference, the pilot should use a visual
reference line that, from eye level, parallels the lateral axis of the airplane.
The altitude that is appropriate for eights-on-pylons is called the “pivotal altitude” and is determined by the airplane’s groundspeed. In previous ground-track maneuvers, the airplane flies a prescribed path over the ground and the pilot attempts to maintain the track by correcting for the wind. With eights-on-pylons, the pilot maintains lateral orientation
to a specific spot on the ground. This develops the pilot’s ability to maneuver the airplane accurately while dividing attention between the flightpath and the selected pylons on the ground.
An explanation of the pivotal altitude is also essential. First, a good rule of thumb for estimating the pivotal altitude is to square the groundspeed, then divide by 15 (if the groundspeed is in miles per hour) or divide by 11.3 (if the groundspeed is in knots), and then add the mean sea level (MSL) altitude of the ground reference. The pivotal altitude is the altitude at which, for a given groundspeed, the projection of the visual reference line to the pylon appears to pivot. The pivotal altitude does not vary with the angle of bank unless the bank is steep enough to affect the groundspeed.
Distance from the pylon affects the angle of bank. At any altitude above that pivotal altitude, the projected reference line appears to move rearward in a circular path in relation to the pylon. Conversely, when the airplane is below the pivotal altitude, the projected reference line appears to move forward in a circular path. To demonstrate this, the pilot will fly at maneuvering speed and at an altitude below the pivotal altitude, and then placed in a medium-banked turn. The projected visual reference line appears to move forward along the ground (pylon moves back) as the airplane turns. The pilot then executes a climb to an altitude well above the
pivotal altitude. When the airplane is again at maneuvering speed, it is placed in a medium-banked turn. At the higher altitude, the projected visual reference line appears to move backward across the ground (pylon moves forward).
After demonstrating the maneuver at a high altitude, the pilot should reduce power and begin a descent at maneuvering speed in a continuing medium bank turn around the pylon. The apparent backward movement of the projected visual reference line with respect to the pylon will slow down as altitude is lost and will eventually stop for an instant. If the pilot continues the descent below the pivotal altitude, the projected visual reference line with respect to the pylon will begin to move forward.
The altitude at which the visual reference line ceases to move across the ground is the pivotal altitude. If the airplane descends below the pivotal altitude, the pilot should increase power to maintain airspeed while regaining altitude to the point at which the projected reference line moves neither backward nor forward but actually pivots on the pylon. In this
way, the pilot can determine the pivotal altitude of the airplane.
The pivotal altitude is critical and changes with variations in groundspeed. Since the headings throughout turns continuously vary from downwind to upwind, the groundspeed constantly changes. This results in the proper pivotal altitude varying slightly throughout the turn. The pilot should adjust
for this by climbing or descending, as necessary, to hold the visual reference line on the pylons. This change in altitude is dependent on the groundspeed.
Selecting proper pylon is an important factor of successfully performing eights-on-pylons. They should be sufficiently prominent so the pilot can view them when completing the turn around one pylon and heading for the next. They should also be adequately spaced to provide time for planning the turns but not spaced so far apart that they cause unnecessary
straight-and-level flight between the pylons. The selected pylons should also be at the same elevation, since differences of over few feet necessitate climbing or descending between each turn. The pilot should select two pylons along a line that lies perpendicular to the direction of the wind. The distance between the pylons should allow for the straight-and-level
flight segment to last from 3 to 5 seconds.
The pilot should estimate the pivotal altitude during preflight planning. Weather reports and consultation with other pilots flying in the area may provide both the wind direction and velocity. If the references are previously known (many flight instructors already have these ground-based reference selected), the sectional chart will provide the MSL of the
references, the Pilot’s Operating Handbook (POH) provides the range of maneuvering airspeeds (based on weight), and the wind direction and velocity can be estimated to calculate the appropriate pivotal altitudes. The pilot should calculate the pivotal altitude for each position: upwind, downwind, and crosswind.
The pilot should begin the eight-on-pylons maneuver by flying diagonally crosswind between the pylons to a point downwind from the first pylon so that the first turn can be made into the wind. As the airplane approaches a position where the pylon appears to be just ahead of the wingtip, the pilot should begin the turn by lowering the upwind wing to the point where the visual reference line aligns with the pylon. The reference line should appear to pivot on the pylon. As the airplane heads upwind, the groundspeed decreases, which lowers the pivotal altitude. As a result, the pilot must descend to hold the visual reference line on the pylon. As
the turn progresses on the upwind side of the pylon, the wind becomes more of a crosswind. Since this maneuver does not require the turn to be completed at a constant radius, the pilot does not need to apply drift correction to complete the turn.
If the visual reference line appears to move ahead of the pylon, the pilot should increase altitude. If the visual reference line appears to move behind the pylon, the pilot should decrease altitude. Deflecting the rudder to yaw the airplane and force the wing and reference line forward or backward to the pylon places the airplane in uncoordinated flight, at low altitude, with steep bank angles and must not be attempted.
As the airplane turns toward a downwind heading, the pilot should rollout from the turn to allow the airplane to proceed diagonally to a point tangent on the downwind side of the second pylon. The pilot should complete the rollout with the proper wind correction angle to correct for wind drift,
so that the airplane arrives at a point downwind from the second pylon that is equal in distance from the pylon as the corresponding point was from the first pylon at the beginning of the maneuver.
At this point, the pilot should begin a turn in the opposite direction by lowering the upwind wing to the point where the visual reference line aligns with the pylon. The pilot should then continue the turn the same way the corresponding turn was performed around the first pylon but in the opposite direction.
With prompt correction, and a very fine control pressures, it is possible to hold the visual reference line directly on the pylon even in strong winds. The pilot may make corrections for temporary variations, such as those caused by gusts or inattention by reducing the bank angle slightly to fly
relatively straight to bring forward a lagging visual reference line or by increasing the bank angle temporarily to turn back a visual reference line that has moved ahead. With practice, these corrections may become slight enough to be barely noticeable. It is important to understand that variations in pylon position are according to the apparent movement of the
visual reference line. Attempting to correct pivotal altitude by the use of the altimeter is ineffective.
Eights-on-pylons are performed at bank angles ranging from shallow to steep. The pilot should understand that the bank chosen does not alter the pivotal altitude. As proficiency is gained, the instructor should increase the complexity of the maneuver by directing the student to enter
at a distance from the pylon that results in a specific bank angle at the steepest point in the pylon turn.
The most common error in attempting to hold a pylon is incorrect use of the rudder. When the projection of the visual reference line moves forward with respect to the pylon, many pilots tend to apply inside rudder pressure to yaw the wing backward. When the reference line moves behind the pylon, they tend to apply outside rudder pressure to yaw the wing
forward. The pilot should use the rudder only for coordination.
Other common errors in the performance of eights-on pylons are:
• Failure to adequately clear the area above, below,
and on either side of the airplane for safety hazards,
initially and throughout the maneuver.
• Poor selection of ground references.
• Failure to establish a constant, level altitude prior to
entering the maneuver.
• Failure to maintain adequate altitude control during
the maneuver.
• Failure to properly assess wind direction.
• Failure to properly execute constant radius turns.
• Failure to manipulate the flight controls in a smooth
and continuous manner.
• Failure to establish the appropriate wind correction
angles.
• Failure to apply coordinated aileron and rudder
pressure, resulting in slips or skids.
• Failure to maintain orientation as the maneuver
progresses.
Commercial Pilot Plan of Action
I. Preflight Preparation
A. Pilot Qualifications
B. Airworthiness Requirements
C. Weather Information
D. Cross-Country Flight Planning
E. National Airspace System
F. Performance and Limitations
G. Operation of Systems
H. Human Factors0
II. Preflight Procedures
A. Preflight Assessment
B. Flight Deck Management
C. Engine Starting
D. Taxiing (ASEL, AMEL)
E. Before Takeoff Check
III. Airport and Seaplane Base Operations
A. Communications, Light Signals, and Runway Lighting Systems
B. Traffic Patterns
IV. Takeoffs, Landings, and Go-Arounds
A. Normal Takeoff and Climb
B. Normal Approach and Landing
C. Soft-Field Takeoff and Climb (ASEL)
D. Soft-Field Approach and Landing (ASEL)
E. Short-Field Takeoff and Maximum Performance Climb (ASEL, AMEL)
F. Short-Field Approach and Landing (ASEL, AMEL)
G. Power-Off 180° Accuracy Approach and Landing (ASEL, ASES)
H. Go-Around/Rejected Landing
V. Performance and Ground Reference Maneuvers
A. Steep Turns
B. Steep Spiral (ASEL, ASES)
C. Chandelles (ASEL, ASES)
D. Lazy Eights (ASEL, ASES)
E. Eights on Pylons (ASEL, ASES)
VI. Navigation
A. Pilotage and Dead Reckoning
B. Navigation Systems and Radar Services
C. Diversion
D. Lost Procedures
VII. Slow Flight and Stalls
A. Maneuvering During Slow Flight
B. Power-Off Stalls
C. Power-On Stalls
D. Accelerated Stalls
E. Spin Awareness
VIII. High Altitude Operations
A. Supplemental Oxygen
B. Pressurization
IX. Emergency Operations
A. Emergency Descent
B. Emergency Approach and Landing (Simulated) (ASEL, ASES)
C. Systems and Equipment Malfunctions
D. Emergency Equipment and Survival Gear
X. Postflight Procedures
A. After Landing, Parking and Securing (ASEL, AMEL)
Private Pilot Plan Of Action Template
I. Preflight Preparation
A. Pilot Qualifications
B. Airworthiness Requirements
C. Weather Information
D. Cross-Country Flight Planning
E. National Airspace System
F. Performance and Limitations
G. Operation of Systems
H. Human Factors
II. Preflight Procedures
A. Preflight Assessment
B. Flight Deck Management
C. Engine Starting
D. Taxiing
E. Before Takeoff Check
III. Airport and Seaplane Base Operations
A. Communications, Light Signals, and Runway Lighting Systems
B. Traffic Patterns
IV. Takeoffs, Landings, and Go-Arounds
A. Normal Takeoff and Climb
B. Normal Approach and Landing
C. Soft-Field Takeoff and Climb
D. Soft-Field Approach and Landing
E. Short-Field Takeoff and Maximum Performance Climb
F. Short-Field Approach and Landing
G. Forward Slip to a Landing
H. Go-Around/Rejected Landing
V. Performance and Ground Reference Maneuvers
A. Steep Turns
B. Ground Reference Maneuvers
VI. Navigation
A. Pilotage and Dead Reckoning
B. Navigation Systems and Radar Services
C. Diversion
D. Lost Procedures
VII. Slow Flight and Stalls
A. Maneuvering During Slow Flight
B. Power-Off Stalls
C. Power-On Stalls
D. Spin Awareness
VIII. Basic Instrument Maneuvers
A. Straight-and-Level Flight
B. Constant Airspeed Climbs
C. Constant Airspeed Descents
D. Turns to Headings
E. Recovery from Unusual Flight Attitudes
F. Radio Communications, Navigation Systems/Facilities, and Radar Services
IX. Emergency Operations
A. Emergency Descent
B. Emergency Approach and Landing
C. Systems and Equipment Malfunctions
D. Emergency Equipment and Survival Gear
X. Night Operations
A. Night Preparation
XI. Postflight Procedures
A. After Landing, Parking and Securing (ASEL, AMEL)
Kraemer Aviation / Flymall.org July 2019 Wheels & Wings Newsletter
July is a busy month; Amelia disappeared, John met Paul, Neil walked on the moon, we loss Lee Iacocca, and more.
Click here to for our July 2019 Wheels & Wings Newsletter.
Harry & Pat hosted their annual July 4th 2019 celebration. A good time was had by all.
Click here for more pictures from the July 4th celebration.
We have a nice Grumman AA-5B for sale on the Flymall. Click here for more details.
We also have a classic Jaguar for sale on the Flymall. Click here for details.
History Trivia: Amelia Earhart disappeared disappeared July 2, 1937. The day John met Paul. If you enjoy reading about dates in The Beatles history, visit our Events Calendar and select the “Beatles” category. You can also search our Market Watch section of the Flymall for Beatles memorabilia, record sales, automobiles, and more. Under “Make” search for key words like Beatles, John Lennon, Paul McCartney, etc.
Achievements & Special Recognition: New Private Pilot! Harry did his first checkride as a DPE and the applicant passed. See “CFI / DPE Notes” in this newsletter for a few pictures from that day.
Aviation/Aviators in the news: The LearAvia Lear Fan 2100 was a turboprop business aircraft designed in the 1970s by Bill Lear (the father of the Lear Jet), with an unusual configuration. The Lear Fan never entered production. Click here for more information.
On July 20 2019 we celebrated the 50th anniversary of Neil Armstrong landing on the moon. Just 66 years from the Wright Brothers first flight. Imagine, only 66 years from Kitty Hawk to walking on the moon.
Have you ever thought what would happen if you lost your engine while flying? No really, lost your engine. It falls off of the airplane!!! Click here for a story Harry found about just that. So pay close attention to the propeller during your next preflight.
Car/Motorcycle Show News: Earlier this month we loss Lee Iacocca, the father of the Mustang. A great man that did a lot for the automotive industry.
The Laytonsville Cruise In is ten years old this year. To celebrate Harry has arranged sponsors for awards on the third Friday of each month through October 2019. Its free to participate. Just show up and register your vehicle. Pictured here is a sample of the awards that are given out.
Harry attended the District Harley Davidson bike show. Harry had his 1912 AC Delivery trike at the show.
Here is the 1912 AC next to a 1916 Indian sidecar rig at the show.
Click here for more pictures from the show. Visit our Events Calendar for information on local car shows and other events. Our Day Tripper section is also full of fun places to visit. Check it out!
Trying to get a vehicle ready for show season? Or are you restoring a vehicle or motorcycle, check out the tech tip section of the Flymall. You can also check out the Test Drive section of the Flymall for aircraft reviews, car & motorcycle reviews, and more.
Harry’s 1975 Lomax meets a 2018 Morgan three wheeler.
Click here for more pictures of the Morgan and Lomax get together.
Barn Finds/Hangar Finds: This month for our Barn Find we’re featuring a Jaguar that we have for sale. Its actually a garage find. A 1994 Jaguar XJS Convertible. Click here for more details.
CFI / DPE Notes: Harry completed his first checkride as a DPE earlier this month. Since then, he has completed numerous checkrides. Here are a few pictures from his first checkride.
Before
The plane
He passed
Click here for Harry’s Practical Test page for more info on his checkrides. Harry’s Practical Test page now has a calendar so applicants and instructors can check Harry’s availability.
Weather in the news: The 4th of July 2019 had some interesting weather. Everyone still had a great time at Pat & Harry’s annual July 4th cookout.
July rains bring floods.
Three Wheel Association (TWA): Here is an interesting 3 wheeler for this month. Very little facts online about this one. Visit the Three Wheel Association page on the Flymall for more info on three wheelers.
Prototypes: This month for our prototypes, the theme is “Take a second look”.
Here is an upside down truck that you can actually drive.
Here is a sideways car
Animals in the headlines: This month we have a dog that can play goalie. Enjoy!
Your one stop shop for everything Wheels & Wings related: Sales, Appraisals, Insurance, Supplies, Tech Tips, Reviews, and more!!!
Sign up for this newsletter at Flymall.org
We close this newsletter with these words of wisdom: Smile a lot. It costs nothing and is beyond price.
Private Pilot Flight Profile
Transponder code & frequency for departure ____________________
Transponder code & frequency for return ____________________
Cockpit Management
Engine Starting
Taxiing
Before Take-off Check
Soft field takeoff (cross wind takeoff if applicable)
Cross country: Pilotage/Dead Reckoning
Trigger Event – divert to alternate via pilotage
Side slip for crosswind landing
Soft field landing
Short field takeoff & landing
Forward slip to landing
Go around
Power off 180
Steep turns
Slow Flight
Power off stall (Entering a power off stall from slow flight is not correct, this is a failure item)
Power on stall
Spin awareness
Ground Reference maneuvers
Instrument maneuvers
Magnetic compass turns
Unusual attitudes
Emergency descent
Emergency operations – systems & equipment failures
Lost procedures
Radio navigation to home base via VOR
Post flight procedures
Hazardous Attitudes Text Version
Anti-authority: “Don’t tell me.” This attitude is found in people who do not like anyone telling them what to do. In a sense, they are saying, “No one can tell me what to do.” They may be resentful of having someone tell them what to do or may regard rules, regulations, and procedures as silly or unnecessary. However, it is always your prerogative to question authority if you feel it is in error. Antidote – Follow the rules. They are usually right.
Impulsivity: “Do it quickly.” This is the attitude of people who frequently feel the need to do something, anything, immediately. They do not stop to think about what they are about to do, they do not select the best alternative, and they do the first thing that comes to mind. Antidote – Not so fast. Think first.
Invulnerability: “It won’t happen to me.” Many people falsely believe that accidents happen to others, but never to them. They know accidents can happen, and they know that anyone can be affected. However, they never really feel or believe that they will be personally involved. Pilots who think
this way are more likely to take chances and increase risk. Antidote – It could happen to me.
Macho: “I can do it.” Pilots who are always trying to prove that they are better than anyone else think, “I can do it—I’ll show them.” Pilots with this type of attitude will try to prove themselves by taking risks in order to impress others. While this pattern is thought to be a male characteristic, women are equally susceptible. Antidote – Taking chances is foolish.
Resignation: “What’s the use?” Pilots who think, “What’s the use?” do not see themselves as being able to make a great deal of difference in what happens to them. When things go well, the pilot is apt to think that it is good luck. When things go badly, the pilot may feel that someone is out to get them or attribute it to bad luck. The pilot will leave the action to others, for
better or worse. Sometimes, such pilots will even go along with unreasonable requests just to be a “nice guy.” Antidote – I’m not helpless. I can make a difference.
Hazardous Attitudes
100 Hour Inspection Legal Interpretation
Office of the Chief Counsel
800 Independence Ave., S.W.
Washington, D.C. 20591
Re: Request for Legal Interpretation of 14 CFR § 91.409(b)
Dear Mr. Greenwood:
On October 1, 2014, my office responded to your March 22 request for a legal interpretation of 14 C.F .R. § 91.409(b ), the FAA’s regulation requiring annual or 1 00-hour inspections for aircraft operated for hire, including flight instruction. Your questions concerned operations by Fly By
Knight, Inc. (Fly By Knight), a flight school certificated under 14 C.F.R. parts 61 and 141, that offers both flight instruction and aircraft rental to its customers. We have re-evaluated our response to your final question, which was an expansion of your Scenario 6. Please note that
our responses to Scenarios 1 through 5 remain unchanged. This letter corrects the letter of interpretation dated October 1, 2014, and strikes that letter from the Federal Aviation Administration database.
Section 91.409(b) of subpart E, part 91, states that “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.” For purposes of§ 91.409(b), aircraft used for flight training under part 141 are not treated any differently than aircraft used for flight instruction under part 61. In fact,§ 141.39(a)(3) provides that each aircraft used by a part 141 flight school for flight training and solo flights “must be maintained and inspected in
accordance with the requirements for aircraft operated for hire under part 91, subpart E.”
The 100-hour maintenance inspection requirement of§ 91.409(b) depends on how the aircraft is operated. See Legal Interpretation, Letter to Craig Brown from Donald Byrne, Assistant Chief Counsel for Regulations (February 24, 2000). Therefore, when Fly By Knight uses an aircraft
for both flight instruction and rental, the 1 00-hour maintenance inspection requirement depends on how the aircraft is operated during the flight in question. For instance, if Fly By Knight is going to operate the aircraft to provide flight instruction for hire, then the aircraft must have had
an annual or 100-hour maintenance inspection within the preceding 100 hours oftime in service. If Fly By Knight is going to rent the aircraft to a customer, however, and does not provide the pilot, that aircraft need not have an annual or 1 00-hour maintenance inspection within the
preceding 1 00 hours of time in service. See Legal Interpretation, Letter to Berry Rackers from Joseph Brennan, Associate Regional Counsel (May 3, 1984).
You listed six scenarios that could occur during your operations, and you requested counsel’s opinion as to whether these scenarios represent a violation of§ 91.409(b ).
Scenario 1: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 95 hours of time in service since the last annual inspection. A rental customer reserves the aircraft for a weekend trip and anticipates flying an additional 10 hours. We assume
Fly By Knight does not provide a pilot. Fly By Knight performs a 1 00-hr/annual inspection upon the aircraft’s return.
The fact pattern in scenario 1 does not violate § 91.409(b ). As explained above, the 100-hour maintenance inspection requirement depends on how the aircraft is operated. If the rental customer rents the aircraft and Fly By Knight does not provide the pilot, then the aircraft is not being operated to carry a person (other than a crewmember) for hire, or to provide flight
instruction for hire. Thus, the 1 00-hour maintenance inspection requirement does not apply, and the rental customer may pilot the aircraft the additional 10 hours. Fly By Knight must perform an annual or 100-hour maintenance inspection, however, prior to operating the aircraft to provide
flight instruction for hire.
Scenario 2: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 99.8 hours of time in service since the last inspection. The aircraft is dispatched on a local training flight with a Fly By Knight instructor and a student pilot, and the flight lasts 1.5 hours. Fly By Knight performs a 100-hr/annual inspection upon the aircraft’s return.
The fact pattern in scenario 2 represents a violation of§ 91.409(b) because the flight instructor and the student pilot intend to overfly the 100-hour limitation during a local training flight. The aircraft is being operated to provide flight instruction for hire. As a result, the aircraft must have
received an annual or 1 00-hour maintenance inspection within the preceding 100 hours of time in service. The next annual or 100-hour maintenance inspection is due in 0.2 hours, and the local training flight is expected to take 1.5 hours. Section 91.409(b) states that “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.” This 10-hour grace period applies only to situations where the aircraft must be flown en route to reach a place where the inspection can be performed. In this scenario,
the flight instructor and the student pilot intend to overfly the 100-hour limitation during a local training flight. The 1 0-hour grace period does not apply to local training flights. As a result, the operator violates § 91.409(b) when the 0.2 hours expire.
Scenario 3: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 99.8 hours of time in service since the last inspection. The aircraft is dispatched on a solo cross country training flight with a student pilot. The flight takes 2.5 hours and includes a
full stop landing at the destination airpoti. Fly By Knight performs a 1 00-hr/annual inspection upon the aircraft’s return.
The fact pattern in scenario 3 represents a violation of§ 91.409(b) because the flight student intends to overfly the 100-hour limitation during his solo cross country flight, and he is not flying the aircraft en route to reach a place where the inspection can be done. Section 91.409(b) applies
to aircraft operated to provide flight instruction for hire. Thus, § 91.409(b) applies to aircraft used for flight instruction under part 61, which includes solo training flights. Furthermore, § 141.39 states that each aircraft used by a part 141 flight school for flight training and solo flights “must be maintained and inspected in accordance with the requirements for aircraft
operated for hire under part 91, subpart E.” Therefore, if a flight student conducts a solo cross country training flight, the aircraft must have received an annual or 100-hour maintenance inspection within the preceding 100 hours of time in service.
In this scenario, the next annual or 100-hour maintenance inspection is due in 0.2 hours, and the solo cross country training flight is expected to take 2.5 hours. The 10-hour grace period in § 91.409(b) applies only to situations where the aircraft must be flown en route to reach a place where the inspection can be performed. The student pilot intends to overfly the 100-hour limitation during his solo cross country flight, and he is not flying the aircraft en route to reach a place where the inspection can be done. As a result, the operator violates § 91.409(b ).
Scenario 4: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 99.8 hours of time in service since the last inspection. The aircraft is dispatched on a cross country training flight with a Fly By Knight instructor and a student pilot. The 1st leg to
the destination airpmi takes 1.5 hours. The return flight also takes 1.5 hours. Fly By Knight performs a 100-hr/annual inspection upon the aircraft’s return.
The fact pattern in scenario 4 represents a violation of§ 91.409(b) because the flight instructor and the student pilot intend to overfly the 1 00-hour limitation during their cross country flight, and they are not flying the aircraft en route to reach a place where the inspection can be done.
The aircraft is being operated to provide flight instruction for hire. Therefore, the aircraft must have received an annual or 100-hour maintenance inspection within the preceding 100 hours of
time in service. The next annual or 100-hour maintenance inspection is due in 0.2 hours, and the dual cross country flight is expected to take 3 hours. As stated above, the 10-hour grace period in § 91.409(b) applies only to situations where the aircraft must be flown en route to reach a
place where the inspection can be performed. In this scenario, the flight instructor and the student pilot intend to overfly the 1 00-hour limitation during their cross country training flight, and the aircraft is not being flown en route to reach a place where the inspection can be done. As
in the previous scenario, the operator violates§ 91.409(b).
Scenario 5: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 97 hours of time in service since the last inspection. The aircraft is dispatched on a cross country training flight with a Fly By Knight instructor and a student pilot. The 1st leg to
the destination airport is expected to take 1.5 hours. The return flight is also expected to take 1.5 hours. Due to ATC vectoring/unexpected winds, the flight instead takes 3.1 hours. Fly By Knight performs a 1 00-hr/annual inspection upon the aircraft’s return.
The fact pattern in scenario 5 does not violate§ 91.409(b). The aircraft is being operated to provide flight instruction for hire. As a result, the aircraft must have received an annual or 100-hour maintenance inspection within the preceding 100 hours of time in service. The aircraft had its last inspection within the preceding 97 hours of time in service and the planned flight is expected to take 3 hours. The aircraft remains in compliance with § 91.409(b) even though the flight takes 3.1 hours due to unexpected circumstances. The flight instructor and the student pilot did not intentionally overfly the 1 00-hour limitation, and § 91.409(b) provides that 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.
Scenario 6: Fly By Knight uses an aircraft for both flight instruction and rental. The aircraft has accumulated 100 hours of time in service since the last inspection. Fly By Knight cannot perform an inspection within the next 3 days. The aircraft is marked for rental use only; no flight instruction is performed. Rental customers accumulate 12 hours of flight time over the 3 day period. After this, the aircraft receives an annual inspection.
The fact pattern in scenario 6 does not violate§ 91.409(b). Fly By Knight cannot operate the aircraft to provide flight instruction for hire because the aircraft has not received an annual or 100-hour maintenance inspection within the preceding 100 hours of time in service. Fly By Knight may rent the aircraft to customers, however, as long as Fly By Knight is not providing the pilot and as long as the rental customer is not operating the aircraft for hire. Rental customers may continue to accumulate flight time in this scenario because the 1OO-hour maintenanceinspection requirement does not apply to aircraft being operated for rental purposes. However,
Fly By Knight must perform an annual or 1 00-hour maintenance inspection on the aircraft prior to operating it to provide flight instruction for hire.
You also asked if an annual inspection “reset the clock” for a 100-hour inspection. You provided the following example: An aircraft received an annual inspection and then flew 105 hours, if a 100-hr inspection was performed then the next inspection due would be in a further 95
hours however, if instead an annual inspection was performed, then the next required inspection would be in a further 100 hours, i.e., gaining 5 hours over performing a 100-hr inspection.” Your scenario is only partially correct.
Section 91.409(b) states that “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.” However, “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.”
You may perform an annual inspection rather than a 100-hour maintenance inspection when the aircraft reaches the 100-hour limitation under § 91.409(b ). 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. In your example, the aircraft received an annual inspection and then flew 105 hours. This aircraft would be overdue for an annual or 1 00-hour maintenance inspection, assuming it is being operated for hire or operated to
provide flight instruction for hire. For purposes of this hypothetical, we will assume you exceeded the 1 00-hour limitation by 5 hours while en route to reach a place where the inspection could be done. You must subtract the 5 excess hours from the next 100 hours of time in service. Therefore, the next annual or 1 00-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.
Finally, you asked how to bring the aircraft described in scenario 6 back into compliance when considering the 10-hour limitation detailed in§ 91.409(b). As explained above, the fact pattern described in scenario 6 does not violate § 91.409(b). The rental customer may overfly the 100-
hour limitation because the 100-hour maintenance inspection requirement does not apply to rental aircraft, provided that Fly By Knight does not provide the pilot to the rental customer and provided that the rental customer does not operate the aircraft for hire. Furthermore, the rental
customer may accumulate flight time in excess of 110 hours because the 1 0-hour grace period applies only when the aircraft is being operated for hire or operated to provide flight instruction for hire, and only when it is being operated en route to reach a place where the inspection can be
done. If the aircraft accumulates more than 110 hours of time in service while operating for hire or for flight instruction (only 10 of which are permissible to reach the place of inspection) the operator would be in violation of § 91.409(b ). The only way to bring the aircraft in your
scenario 6 back into compliance for purposes of providing flight instruction is to perform the 1 00-hour or annual inspection before operating it for those purposes. Therefore, the operation in scenario 6 does not violate § 91.409(b) when a rental customer accumulates flight time in excess
of 110 hours. However, Fly By Knight must perform an annual or 1 00-hour maintenance inspection prior to using the aircraft to provide flight instruction for hire.
We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Katie Patrick and Edmund Averman, Attorneys in the Regulations Division of the Office of
the Chief Counsel, and coordinated with the Aircraft Maintenance Division of the Flight Standards Service.
Sincerely,
Lorelei Peter
Acting Assistant Chief Counsel for Regulations, AGC-200
The 5K Orchard Run
The 8th annual 5k trail race/walk will be held at
Butler’s Orchard
(22222 Davis Mill Road, Germantown, MD 20876) on
Saturday, November 23 at 10:30am
(followed by a FREE family fun run).
The 5k Orchard Run supports passionate dreamers from the UpCounty area who imagine the world to be a place of love, justice, compassion, and provision.
This year, we have chosen four local groups to make their corner of the world, locally or globally, as it should be:
Jobs Partnership – Teaching inmates at the Montgomery County Correctional Facility resume, interview, and jobs skills.
Little Free Pantry – An anonymous 24/7 emergency food pantry with locations in Damascus and Clarksburg.
PURE Youth – A local chapter of middle school students raising money to support the education of peers in India.
Campus Life – A middle and high school club dedicated to helping young people build positive relationships.
Get Involved!
Become A Sponsor
Is your business interested in becoming a sponsor? Your monetary donations, gifts in kind, or presence at the race can make this the best race yet. Contact Nicole Bungato at 301-787-6320 / nicolebungato@gmail.com for more information.
Register to Race
Go to 5korchardrun.com to register to race. Select which group you would like to race for and all profits from your registration fee will go towards their group.
