Cri-Cri and multi engine rating

[Old Geek]

Suppose a fella was crazy enough to build one of these:

http://cdn-www.airliners.net/aviation-photos/middle/9/4/6/0925649.jpg

Would he need a multi engine rating to fly it?

 

[Jim Logajan]

No, there is an "and" to 61.31 (d)1.

(My copy of the regs show an "or".)

But the section I think everyone is looking for is paragraph L, "Exceptions" at the end of 61.31. I capitalized the L but in the regs it is lower case, and l looks a lot like 1 (the number.)

Anyway, note that the "Exceptions" paragraph says that 61.31 (and therefore the prohibition of flying without an appropriate category and class rating) doesn't apply to non-type-certificated aircraft. Experimental aircraft are not type certificated. Ergo no category or class is required to fly an experimental. However, the operating limitations issued for each experimental aircraft is the place that any category and class limitations will be found, as shown beginning on page 4-75 of FAA Order 8130.2G. Note that it states that operating limitations must be designed to fit the specific situation. It is possible for the builder to get a set of operating limitations written that allows them to operate without having the category and class. This is something all those ornithopter experimentalist no doubt need, as no existing category covers such aircraft.

 

[Jim Logajan]

You don't. See 61.31(l):
But you still might be smart to get some appropriate training before going up solo in an Experimental for which you do not have the appropriate rating.

But the standard template for operating limitations does require category and class. I do know a couple of gentlemen who built an experimental airship and got issued operating limitations allowing them to fly it even though neither one had an airship rating. The still weren't allowed to carry passengers, though. I think they petitioned to have that restriction removed.

 

[Jim Logajan]

The section to which Jim refers applies (item 17 on the list) only to turbojet/turbofan-powered aircraft, those with MGW of 12,500 or more, or "when deemed necessary." It is not normally included and I do not think it has ever been applied in a case like the one under discussion.

You may be correct, since I interrupted the composition of my post to go eat dinner and on returning decided to quickly wrap it up - then found after I finally finished that you had posted much earlier. (I knew from research I did on this subject several years ago what the answer was, but had to go relocate the regulation and the FAA order. I stopped scanning 61.31 as soon as I thought I found what I had seen years ago.)

However, section 61.31 covers more topics than pilot "type ratings," and 61.31(l)(1) references "aircraft not type-certificated," not "pilot not type-rated." Powered parachutes and weight-shift-control aircraft, which are mentioned in that paragraph, are unlikely to exceed 12,500 lbs. So I think that paragraph is not concerned with large aircraft type ratings; maybe it is indeed intended to cover aircraft like ornithopters.

But your reference to 61.31(l)(2)(iii)(B ) is more appropriate, regardless.

My own interest in this regulatory subject occurred when I was interested in building an experimental airship several years ago (who knows, maybe I still will.) It costs a fair amount of money to get an airship rating, so it was at first a nice revelation to see that exception. I found it hard to believe, though, that people wouldn't abuse the exception. I eventually found that the generic operating limitations issued on most experimentals closed the exception.

This may have some minor value to those who are interested in flying unconventional experimental aircraft like the Cri-Cri:

Back when I was more heavily researching airship design I became acquainted with Dan Nachbar who had designed and was building a Personal Blimp (the video really shows the beauty of genuine low-and-slow sight seeing with a relatively quiet airship.) According to this story and this story, he and his partner did eventually get the exemption they sought to carry passengers in their experimental airship without an airship rating.

 

[Jim Logajan]

I'm more confused than when I first asked the question....

What part is confusing? The regs as written would allow you to fly a Cri Cri without a multi-engine rating so long as the Operating Limitations that were issued for that particular aircraft didn't include any limitations on pilot category and class. Operating limitations for experimentals are issued on a per airplane basis, so it isn't possible to provide more specific guidance.

 

[Jim Logajan]

Build your airship, I'll teach you to fly it. I think the biggest obstacle is finding someone to give you the checkride.

Thanks - if I do build one it will likely be a couple years before I would be able to take you up on that offer.