FAR 61.31 Is tailwheel endorsment required for "experimenta"l solo flight?

[qsmx440]

Saw this regulation posted on another group in relation to a Cri Cri twin. The poster stated that this indicated that a twin experimental was exempted from the multi engine rating requirment when flown solo by a SEL rated PPL. This got me to wondering if it would apply to experimental tailwheel also?:

§ 61.31 Type rating requirements, additional training, and authorization
requirements.

(c) Aircraft category, class, and type ratings: Limitations on the carriage of
persons, or operating for compensation or hire. Unless a person holds a
category, class, and type rating (if a class and type rating is required) that
applies to the aircraft, that person may not act as pilot in command of an
aircraft that is carrying another person...

(l) Exceptions. (1) This section does not require a category and class rating
for aircraft not type-certificated as airplanes, rotorcraft, gliders,
lighter-than-air aircraft, powered-lifts, powered parachutes, or
weight-shift-control aircraft.

(2) The rating limitations of this section do not apply to—

(iii) The holder of a pilot certificate when operating an aircraft under the
authority of—

(B) An experimental certificate, unless the operation involves carrying a
passenger...

Not debating the wisdom but just wondering about the rules?? Was the poster wrong in his opinion about solo experimental?

[mvivion]

Category = Airplane/Rotorcraft/Lighter than Air, etc

Class = Single Engine Land/Multi Engine Land, etc

Type Rating = Lear 35, B-767, etc--required of all turbo jet powered aircraft, aircraft with GTOW over 12,500 and others specified by the Administrator.

What the regulations say is that the TYPE RATING requirements don't apply to experimental aircraft, unless you're carrying a passenger.

A tailwheel endorsement is NOT a Type Rating, though, just an endorsement.

MTV

[qsmx440]

Thanks mtv. I tried to read the FAR and for some reason couldn't connect the dots looking at it. I figured I was reading it wrong. Like I said wasn't planning on avoiding the endorsement just wondering if the rules required it. I guess a student pilot must receive his TW endorsement (for solo ops?) along with solo so to speak.

[jnorris]

A note on the tailwheel endorsement: The operating limitations of the aircraft in question may indeed require this endorsement even though the regulations themselves may not. Most operating limitations issued to experimental aircraft over the past 10 years or so (and possibly longer) contain the following item:


The pilot in command of this aircraft must hold a pilot certificate or an authorized instructor's logbook endorsement. The pilot in command must meet the requirements of § 61.31(e), (f), (g), (h), (i), and (j) as appropriate.


You can't just look at the regulations, but must also look at the operating limitations that are issued to the aircraft itself as a part of its airworthiness crtificate. If a limitation similar to this one is included the pilot would need to have the tailwheel endorsement (or high performance, or complex) as approprate to the aircraft.

Another issue is insurance. My guess is, regardless of whether the regulations or operating limitations require it, an insurance underwriter will require the pilot to meet all category, class, and endorsement requirements in order to fly a particular aircraft.

[qsmx440]

Joe that "operating requirments" on the AW for an experimental was brought up on the original thread also. I was just following up the trivia of the thing. Are you saying then that there may be older experimentals running around that the DAR didn't put that restriction on that could be flown solo without a TW endorsement? For that matter could there be some experimental twins in the same boat (Cri Cri)? I know insurance and common sense/survival etc would dictate you get the training but just wondering about the wording of the FAR.

[bob turner]

I am not sure, but I think I soloed a student without a tailwheel endorsement. She now holds a private pilot license without a tailwheel endorsement, but has never flown anything other than a Cub. Am I going to jail?

[irishfield]

LOL Bob.. if she got her ticket in a cub.. she probably needs a tricycle endorsement! You guys (read the FAA) make it so difficult down there...

[RAC cubs]

You won't be in as much as her ,THE PIC is always held responsible my FSDO would go wild.

[kase]

I would say if you signed her student pilot certificate to solo in a J3 thats all the endorsement she needs.

[Amy]

I would say if you signed her student pilot certificate to solo in a J3 thats all the endorsement she needs.

That's what I got . . . tailwheel endorsement went in the logbook before the checkride as I recall. I am having a memory-challenged moment but I believe if your student logged any PIC time in a tailwheel aircraft before 1991 (this is the part I can't remember) she is grandfathered (or grandmothered) in. My thought is always that, even if you had that PIC time before that date, it can't hurt to have someone sign it off in your logbook, in case you ever get asked.

[Amy]

I would say if you signed her student pilot certificate to solo in a J3 thats all the endorsement she needs.

That's what I got . . . tailwheel endorsement went in the logbook before the checkride as I recall. I am having a memory-challenged moment but I believe if your student logged any PIC time in a tailwheel aircraft before 1991 (this is the part I can't remember) she is grandfathered (or grandmothered) in. My thought is always that, even if you had that PIC time before that date, it can't hurt to have someone sign it off in your logbook, in case you ever get asked.

[cubdriver2]

I did all my training in a pa11, my writen was going to expire in less then a week and we couldn't find an examiner who was happy in a tailwheel airplane so I jumped into my friends C172 for a couple hours so that I could take the checkride in it and I owned a pa15 at that time also, I passed the checkride and the examiner say to me, I know that you've been signed off to fly your Vagabond but now that you passed the checkride in the Skyhawk you need a TW signoff before you can fly your plane.

Glenn

[mvivion]

You need a tailwheel endorsement for operating a tailwheel airplane. An endorsement for a solo flight in a tailwheel airplane MIGHT keep the FAA happy, depending on who the "FAA" is. Every FAA type I've ever met wants a specific endorsement, referencing the tailwheel configuration.

Remember, there have been J-3's out there with a nosewheel Oh, the shame of it all.

Easy to take care of though, just go back to an appropriate date and sign a tailwheel endorsement, on a date when you actually flew with them, that is. And, here's the "not required before" paragraph:
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.

MTV

[Steve Pierce]

I never got a tailwheel endorsement. Learned in a tailwheel and it has never been an issue and my pilot's logbook has been scrutinized by both the FAA and their lawyers.

[behindpropellers]

I never got a tailwheel endorsement. Learned in a tailwheel and it has never been an issue and my pilot's logbook has been scrutinized by both the FAA and their lawyers.

I'm sure if you told them what to look for they could find something wrong

[jnorris]

Are you saying then that there may be older experimentals running around that the DAR didn't put that restriction on that could be flown solo without a TW endorsement?

In a word, yes. Operating limitations issued many years ago don't look anything like the ones that are issued today. There was a time when the operating limitations required the PIC of the aircraft to hold "an appropriate category/class rating". Others only require a "pilot certificate" with no mention of category/class. There may be other variations as well. But only the limitations issued in about the last 10 years or so specifically mention the 61.31 endorsements. This is mostly because those endorsements didn't exist when the older operating limitations were issued.

All this being said, there remains the fact that most if not all "modern" FAA inspectors will expect to see the applicable endorsements if a pilot is flying an airplane that would appear to require them. Do you really want to have to stand there are "discuss" this with an inspector and have to prove your case, or would it just be easier to have the endorsements and go on about your business? You pays your money and you takes your chance!!

I never got a tailwheel endorsement. Learned in a tailwheel and it has never been an issue and my pilot's logbook has been scrutinized by both the FAA and their lawyers.

How long ago did you get your certificate Steve? I don't have a tailwheel endorsement either. The endorsement is only required for those pilots who did not have PIC time logged in a tailwheel aircraft before April 15th, 1991. If you took your training and had tailwheel PIC time logged before that date, you're golden.

When I solo a student in a tailwheel aircraft, they get the usual solo endorsements AND the tailwheel endorsement. The solo endorsements in and of themselves do not meet the requirements of 61.31.

[qsmx440]

Thanks Joe and a good discussion on this. It was really a trivia question on my part that came up when I read the "twin engine loophole" on another post. Read the FAR and looked like the loophole extended to TW endorsement. Nope I don't ever argue with government men "on the spot" and I will get my TW endorsment of course when/if I see the light at the end of tunnel on my build. Always thought people really looked stupid when they would go off or argue about some small violation I would issue them and it never made any difference. It's "yes sir" and "no sir" from me to any law enforcement I run afoul of. Any problems and I would "tell it to the judge".

[AntiCub]

I got my pilot certificate in a tail dragger, my instructor signed off my tailwheel endorsement at the same time he signed off my solo endorsment.

[Steve Pierce]

How long ago did you get your certificate Steve? I don't have a tailwheel endorsement either. The endorsement is only required for those pilots who did not have PIC time logged in a tailwheel aircraft before April 15th, 1991. If you took your training and had tailwheel PIC time logged before that date, you're golden.

When I solo a student in a tailwheel aircraft, they get the usual solo endorsements AND the tailwheel endorsement. The solo endorsements in and of themselves do not meet the requirements of 61.31.

I wasn't grandfathered in but all my training and check ride was done in a tailwheel airplane and no one ever made an endorsement entry.

[jnorris]

I wasn't grandfathered in but all my training and check ride was done in a tailwheel airplane and no one ever made an endorsement entry.

That's really interesting. The examiner missed the boat on that one for sure. If you don't meet the "grandfather clause" in the regulation you definitely do need the endorsement regardless of what training or solo endorsements you have. You might want to talk to your instructor and get that resolved.

[kase]

Had a student that I trained and soloed in a C182. She took her checkride in the aircraft and aced her checkride. Only aircraft she ever flew.

I signed her student pilot certificate and gave her a high perfermance endorsement also the day she soloed.

The examiner said the HP endoresment was unnecessary and the endoresment on her student cert was all that was required.

[Steve Pierce]

Interesting. Sat through a deposition where a lawyer from the justice department picked apart anything and everything she could about me as a person, pilot and mechanic and never said anything about this. I will investigate.

[SJ]

I've done a number of primaries in taildraggers and have not given the TW endorsement to those folks that I can recall, since they learned in that type. Adding the endorsement in those cases would only take another couple minutes - since obviously they meet the criteria already.

sj

[dalec]

I was grandfathered, but during my last BFR in my cub, the instructor put a tailwheel endorsement in my logbook. His comment was something along the lines of "I realize you don't have to have this, but this way no one will ever be able to question your "right" to fly a taildragger". At that time I thought it was starnge, now I appreciate the wisdom of his caution.

[strangeak]

I have an entry in my logbook that says checkout in supercub from prior to the cut off date, but at the time was a student pilot. I had no additional tailwheel time at all until far after the cut off date. No one since ever put an entry stating tailwheel check out, but I asked the last few instructors that signed off my BFR's about it, and was told i was pilot in command prior to the cut off. Always seemed kid of a gray area to me.

[qsmx440]

I started this thread just to satisfy my trivia instincts but it looks like it may have gone "legal" looking at the last few posts. I bet the FAA would see some of these highly experienced pilots with less than legal logbook entries as just minor but in a serious accident with large payouts to innocents this could maybe be a problem that lawyers or insurance companies could capitalize on. Sounds like an endorsement at the next flight review might be a good idea. If SJ sees this, maybe this thread needs a better title (and fix the spelling) and get rid of the "experimental" and maybe even move it to a better forum than experimental. Might be a gray area for a lot of people?

[Steve Pierce]

I'm gonna get ornery like TJ and say screw it. I figure I was signed off to solo, take a check ride, took a SODA and my flight test, 709 ride etc. all in a tailwheel airplane. I bet I don't have 20 hours in a nose wheel airplane and most of that was in a LongEZ. I'll let them sort it out and prove I'm not legal to fly a "conventional" geared airplane.

[T.J.]

Way to go Steve!
If necessary, hire yourself a good lawyer. It may cost a few bucks, but to me, it is worth the satisfaction of teaching some guvment employees that I can read better than they can.