Hey all,
I am doing the first 30 hrs of my practical training for the CBIR in my own airplane, a Bonanza, which doesn’t have brakes on the co pilot side.
Now the issue has been brought up that this plane doesn’t meet the training requirements. I said, no, it’s ok, because brakes aren’t primary flight controls as referred to by Part FCL.
I can understand that the swing over controls of some of the older Bonanzas won’t work. But brakes ? They’re mentioned nowhere.
I’d be happy for some insights here :)
These are the rules for EIR:
AMC2 FCL.825(h) En route instrument rating (EIR)
TRAINING AIRCRAFT
The aeroplane used for the instrument flight time under instruction provided outside an
ATO by an IRI(A) or FI should be:
(a) fitted with primary flight controls that are instantly accessible by both the student and
the instructor (for example dual flight controls or a centre control stick). Swing-over flight
controls should not be used; and
(b) suitably equipped to simulate instrument meteorological conditions (IMC) and for the
instrument flight training required.
and here are those for IR:
AMC4 to Appendix 6 Modular training courses for the IR
SECTION Aa IR – COMPETENCY-BASED MODULAR FLYING TRAINING COURSE
FLYING TRAINING
(a) The instrument flight instruction outside an ATO provided by an IRI(A) or an FI holding the
privilege to provide training for the IR in accordance with Appendix 6 Section Aa (6)(a)(i)(A) may
consist of instrument flight time under instruction or instrument ground time or a combination
thereof.
TRAINING AIRCRAFT
(b) The aeroplane used for the instrument flight training provided outside an ATO by an IRI(A) or
FI should be:
(1) fitted with primary flight controls that are instantly accessible by both the student and the
instructor (for example dual flight controls or a centre control stick). Swing-over flight controls
should not be used; and
(2) suitably equipped to simulate instrument meteorological conditions (IMC) and for the
instrument flight training required.
(c) The FSTD used for the instrument flight instruction provided outside an ATO by an IRI(A) or FI should
be suitably equipped to simulate instrument meteorological conditions (IMC) and for the instrument flight
training required
Excuse me for bypassing all the despicable acronym soup but how could anyone ever claim wheel brakes are flight controls? How can brakes – sowieso never effective unless not airborne – affect flight? What’s the point?
That’s a funny but good point, since I have been told by an IRE that if I crash the plane after he told me I passed, I still end up with an IR, because the IR test doesn’t include the landing.
In fact another guy, who did my JAA IRT, told me he doesn’t normally tell people they passed until after they successfully landed (he did tell me though) since he had one case of a lady pilot who got so excited she passed that she was unable to land and on the Nth go-around he had to take over and land it.
Wheels and brakes are not even flight controls, let alone primary.
It is hard to prove this to some jobsworth that is dead set on overinterpreting a rule – the German LBA for example insisted that the engine is “Equipment connected to IFR flight” on the basis you need it to fly IFR.
It might be helpful to point out that in ramp inspection forms the flight controls and wheels/tyres/brakes are listed separately
https://www.easa.europa.eu/system/files/dfu/Annexes%20to%20Regulation.pdf
I just found something a bit more definite. FAR Part 23, and the EASA equivalent CS 23, both define
CS 23.673 Primary flight controls: (a) Primary flight controls are those used by the pilot for the immediate control of pitch, roll and yaw.
Brakes are NOT primary flight controls.
Case closed.
Jan_Olieslagers wrote:
Excuse me for bypassing all the despicable acronym soup but how could anyone ever claim wheel brakes are flight controls? How can brakes – sowieso never effective unless not airborne – affect flight? What’s the point?
Try landing a small Continental powered Cub on a tarmac runway in slight cross wind, and you will see that brakes are indeed flight controls. More “ground controls” perhaps, but handle those brakes wrong and the airplane won’t be flying in a long time.
@Cobalt: thank you, it is almost a relief to see there are legal texts that conform to factual life.
@LeSving: allow me to refer you to earlier:
Brakes are NOT primary flight controls. Case closed.
And regarding
landing a small Continental powered Cub on a tarmac runway in slight cross wind
: you search trouble you’ll get trouble. Or as IT’ers say: garbage in garbage out. Nothing to do with definitions, neither legal nor common sense.
It’s customary to offer the instructor/examiner to test his brakes…for a reason. There have been incidents where the position used by the instructor did not have brakes, the student then proceeded to (possibly by mis managing a hot start on a fuel injected engine) collide with a parked vehicle.
I wouldn’t want to be the hapless instructor/examiner having to explain to the loss adjuster I was instructing in an aircraft where I did not have access to the brakes.
LeSving is being generous in describing the vintage drum brakes on a C-65 or 85/95 Cub/Super Cub, as controls – they tend to function by appointment, although fortunately the type is quite benign for a tailwheel.
I did my differences training for VP prop and retractable on a Mooney M20J LM (“Lean Machine”) which didn’t have any brakes on the right hand seat, either. On a 540m tarmac runway no less.
The instructor just told me “Look, I have no brakes, so don’t mess it up”. When queried he also said “If you land in the right spot, braking is not an issue. If you don’t, you will go around. If you are too fast, you won’t land anyway in this thing, let’s go”.
IFR training isn’t ab initio, nor is it training flying taildraggers in crosswind.
RobertL18C wrote:
LeSving is being generous in describing the vintage drum brakes on a C-65 or 85/95 Cub/Super Cub
We have disk brakes on our Cub actually, changed them some 3-4 years ago. To be honest, not much more braking power, but more precise. To the original question, wouldn’t that rather be a question of who is PIC ? Can the PIC sit in a seat that has no brakes?
