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LSA aircraft for FAA IFR training!

Hi

I have a customer that wants me to help him to get his FAA Instrument rating in Europe. Since I’m an FAA CFII I have told him I will help him with it. Now the problem is that he owns an LSA aircraft (L3 evolution, Czech registered) and he wants me to train him in his aircraft and he want to do the FAA check ride in his L3 evolution.

- I have no knowledge of LSA airplanes and my question is can he do his IFR training and check ride in his LSA aircraft if the airplane meets the FAR 91.205?
- Can I at least train certain hours in his aircraft and then the rest in an IFR equipped airplane?

The training is going to be in Europe

Many thanks

Last Edited by ABCD at 23 May 19:04
ESGT/ESGP, Sweden

You cannot file an IFR flight plan in Europe if the plane has “VFR only” on its Type Certificate, like the L3.
The FAA instrument rating can be done entirely under VFR conditions except for the 250 NM-cross country (14 CFR 61.65 (d)(ii)), which needs to be performed under IFR and an ATC clearance.
So at least part of the training might be feasible on the L3, provided that it is suitably equipped.

Friedrichshafen EDNY

This is really interesting.

The FAA accepts training done outside the US towards any license or rating, in any (appropriate class etc) aircraft type, with any instructor with appropriate qualifications (does not need to be an FAA CFI or CFII). It is an incredibly generous policy!

It would appear that – outside US airspace for sure – the whole of a US PPL could be done in an LSA and for the IR you would rent another plane for that one flight. I remember doing mine from Phoenix to Nogales in a PA28-161 at 11000ft, with the engine leaned by the CFII for maximum CHT (no; that’s not a misprint!)

@ncyankee might know more detail. In particular whether US schools do this. There is probably no cost advantage in an LSA in the US… other than a lower fuel burn (per hour) of a Rotax.

Administrator
Shoreham EGKA, United Kingdom

ABCD wrote:

he wants to do the FAA check ride in his L3 evolution

Can you really do any FAA checkride in Europe? Or was he going to fly the L3 to the US?

tmo
EPKP - Kraków, Poland

You can, just about, at a price, and subject to a list of requirements as long as your arm, but the subject is surrounded by politics and controversy, and it would be better to not advertise the services of the one guy who does piston GA checkrides because he threatened various people with litigation.

The written exams can’t be done anymore and that is a big block on the FAA route, because it puts in an unknown variable into how much time you need to allocate for the US trip.

Administrator
Shoreham EGKA, United Kingdom

In that case, if I have to go to the US to do the written anyway, might as well take it in the AM, and do the check ride in the PM… ;-)

And we could now commence the TSA / INS (visa) discussion, but let’s not.

tmo
EPKP - Kraków, Poland

tschnell wrote:

You cannot file an IFR flight plan in Europe if the plane has “VFR only” on its Type Certificate, like the L3.

Are LSA like the VL-3 type certificated? Is the restriction in the relevant place worded as “VFR day only” or “VMC only”? In the latter case what prevents flight under the IFR in VMC in Europe? This is permitted in US as addressed in the interpretation given 8 Oct 2010 to Richard Theriault by Rebecca B MacPherson, Assistant Chief Counsel for Regulations: “… an aircraft does not need to be IFR certified to operate on an IFR flight plan, provided the aircraft remains in Visual Meteorological Conditions…”

The interpretation has been incorporated in FAA Order 8900.1 vol 5 ch 2 sec 9 para 5-439:

A. IFR Training in Visual Meteorological Conditions (VMC). Instrument flight training may be conducted during VMC in any aircraft that meets the equipment requirements of §§ 91.109 and 91.205, and, for an airplane operated in controlled airspace under the IFR system, §§ 91.411 and 91.413. An aircraft may be operated on an IFR flight plan under IFR in VMC, provided the PIC is properly certificated to operate the aircraft under IFR. However, if the aircraft is not approved for IFR operations under its TC, or if the appropriate instruments and equipment are not installed or are not operative, operations in instrument meteorological conditions (IMC) are prohibited. The PIC of such an aircraft must cancel the IFR flight plan in use and avoid flight into IMC.

That of course applies in US but is a similar arrangement not possible in Europe?

ABCD wrote:

can he do his IFR training and check ride in his LSA aircraft if the airplane meets the FAR 91.205?

The instrument and equipment requirements in 14 CFR 91.205 only apply directly to aircraft with standard category US airworthiness certificates. According to 14 CFR 61.45(b)(1) “… an aircraft used for a practical test must have … the equipment for each area of operation required for the practical test.” See also 61.45(d)(1) “an applicant for a practical test that involves maneuvering an aircraft solely by reference to instruments must furnish… equipment on board the aircraft that permits the applicant to pass the areas of operation that apply to the rating sought.” Note that it is permissible to attempt suitable portions of the instrument practical test, eg partial panel, separately in an aircraft that does not fully satisfy 91.205(d): see FAA Order 8900.1 vol 5 ch 2 sec 9 para 5-436. At the discretion of the examiner a non–US-registered aircraft may be used on the condition that it is “properly certificated by the country of registry.” 61.45(a)(2)(ii). I expect this would be satisfied by any aircraft fulfilling the conditions in 14 CFR 21.190(d).

Note also the aircraft requirements for logging flight time in 14 CFR 61.51(j): “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— […] 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.

tmo wrote:

we could now commence the TSA / INS (visa) discussion, but let’s not.

If there is any uncertainty it should be cleared up at this stage given the serious consequences of noncompliance. The TSA requirements are covered as a core topic in FAA-approved flight instructor refresher courses, see eg Sporty’s free online FIRC (link).

London, United Kingdom

Absolutely WOW! I did wonder whether Qalupalik would find a way to do the equivalent of cold fusion

I doubt TSA is needed for FAA written exams, which is all that you have to do in the US. I also doubt it is needed for a checkride in the US. The “18 hours” bit is totally absent in these cases. Has this been defined?

Should there be a perceived need for TSA for non US airspace flying, one can get around that by training ostensibly towards a Euro license/rating. The US will then accept the logbook entries. __Those flights don’t need to be done via an ATO (they would need to be done via an ATO if they were to be used towards a Euro license/rating). __ What the DPE (the one in the US, not the one based in Europe) will care about most is whether you had the few required hours within 60 days of the checkride and these must be done with a real FAA CFI or CFII and that is normally the guy who will sign you off as ready for the checkride. Most people doing the checkride in the US also do these few hours out there, for obvious reasons.

Administrator
Shoreham EGKA, United Kingdom

Yes, Qualupalik’s answer is as great as we have come to expect. Thank you!

As far as TSA, the www.flightschoolcandidates.gov web site is not working for me, but according to AOPA:

> An alien is NOT required to participate in the AFSP and undergo a security threat assessment if:
> He/she is seeking recurrent training, such as a flight review, instrument proficiency check, or flight training listed under 14 CFR 61.31; or
> He/she is seeking ground training; or

I believe that implies that an “ab initio” check ride for a rating DOES REQUIRE approval from the TSA. 14 CFR 61.31 are “Type rating requirements, additional training, and authorization requirements.”

I also believe that the way to avoid the requirement for a M visa is to a) not seek a commercial license and b) have less than 18 hours of “training” (which probably includes the check ride) – you can, of course, fly “for fun” with an instructor till you run out of money. Or the world runs out of AVGAS.

That said, I’m seriously considering to get the EASA IR first, and then a FAA one based on that. The biggest problem, for me, by far, are the theoretical exams.

tmo
EPKP - Kraków, Poland

Yes; there is

  • the M1 visa (which is obviously not needed if you don’t visit the US)
  • the TSA (which some say is needed for any training towards FAA-anything anywhere in the world which is obviously absurd)
Administrator
Shoreham EGKA, United Kingdom
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