Jeff & Wayne,
I give flight instruction in 235/320/360 Lancairs. I would be very happy
to help you but I must point out a few legal technicalities:
FAR 91.109(a): “No person may operate a civil aircraft
(except a manned free balloon) that is being used for flight instruction
unless that aircraft has fully functioning dual controls.”
The FAA considers rudders and (because we have no nose wheel steering)
brakes to be a part of “dual controls”. I have read recent comments that
persons have given dual in Lancairs without right side rudders. I believe that
those persons are taking on considerable liability and risk of certificate
action by doing so. I am not in a position to take that risk.
The FAA has been extremely clear that dual instruction is not permitted
in an aircraft that is still in phase I testing. The Operating Limitations
that are issued with your airworthiness certificate, the FARs and many FAA
rulings also make it crystal clear that experimental aircraft may NOT be used
for compensation or hire. Therefore, an instructor can not give flight
instruction in an aircraft supplied by the instructor. A possible exception
might be if the instructor made no charge for his services and accepted
no compensation whatever for the use of his aircraft. Even this possible
exception is not totally clear from a legal standpoint.
Consequently, the information that you received from HPAT is not only
correct, but is the only possible course of action that they can legally
propose.
I hear your complaints that you feel “abandoned” and “screwed”.
Although I understand, I do not agree. RV kits come with dual rudders and
brakes. With a Lancair it’s our choice...your choice. The regulation requiring
dual controls for flight instruction is not new. I feel that you need to take
some responsibility for the decision not to install them. I would imagine that
you realized from early in construction that you’d need instruction in your
plane.
I hear your lamentation that LOBO should figure out how to solve the
problem of training. LOBO has been and is now hard at work to that end. One
answer is a LODA (Letter of Deviation Authority). This is a letter issued by
the FAA that would offer specific exemptions to the “compensation or hire”
restrictions for flight training. Nobody...I say again, nobody is pushing the
FAA harder in this area than LOBO. To the best of my knowledge, no LODAs have
been issued by the FAA although several have been applied for. They say that
they are formulating “guidance” for their field offices.
I spent the past 2 days in Washington DC representing LOBO at a meeting
with the FAA. This was a meeting to revise guidance for Flight Instructor
certificate renewal but the main and constant topic was GA safety. Among the
30 or so industry folks in attendance at this meeting were many of the top
people in aviation education (John and Martha, Dr. Gleim, AOPA, Jeppesen among
others) We had presentations from and very frank discussions with several FAA
people. These were not local FAA inspectors but people up to the assistant
administrator level. One presentation was by the head of ASF-800, Mel Cintron.
Mel is in charge of all GA activities at FAA. He presented his list of
the top 10 factors in GA fatal accidents. Care to guess what he listed as
number one? Yep, amateur built aircraft. The people at these levels at
FAA are under tremendous pressure not just from the administrator but from
Congress and the Secretary of Transportation to reduce the accident rate. One
easy and obvious answer for them would be to greatly restrict amateur built
aircraft. I don’t believe that they want to do this (and they said as much)
but the possibility cannot be ignored. LOBO has met with Mel Cintron before
and has and will continue to press for relief from the commercial training
restrictions. Since this could help solve their problem as well as ours I am
cautiously optimistic that we will start seeing LODAs in the near future
(note: FAA “near future” and our “near future” may not be related)
Until such time as we can legally offer different solutions, I urge you
to make the hard decision. Install “fully functioning dual controls” in your
airplane, bite the bullet, reach deep into your wallet and pay a qualified
pilot to test your airplane and fly off the hours (a good one will do real and
meaningful testing and data gathering). The decision that I would beg you not
to make is to fly your airplane without training. As I always tell folks that
I fly with in the 320/360, these airplanes are different...not difficult, but
different. Different enough that to fly it without training would be, at the
very least, inadvisable.
Please contact me if there are any areas that can help you with or
questions that I can answer.
Bill Harrelson
N5ZQ 320 1,850 hrs
N6ZQ IV under construction
Sent: Tuesday, December 07, 2010 7:42 AM
Subject: [LML] Re: lancair 360 training
Wayne
Tassin wrote:
Second, the hpat rep tells me he has to train me in my
airplane which is not complete
and he has to have rudder pedals on the
right side which I did not install.
So what it looks like is I
will need hpat to fly the 25hrs off and retrofit the right side pedals which
look to be all but impossible
and then train me. Please give me your
thoughts or ideas on this situation.
-------------
I would
really appreciate it of LOBO could figure out how to solve the problem of
training
in the 360 series.
If you build any RV, the factory will
help you get training.
If you build a 360 you are basically
screwed.
Lancair has abandoned the
360 and does not provide
training. All they do is point you to HPAT, and they want to
fly the entire
test period (40 hrs for me) before they train you in your own
plane.
Has LOBO abandoned the 360 builder as well?
Apparently,
despite all the 360s out there, some owned by CFIs, there is nobody willing to
train the new 360 pilot.
--
Jeff
Peterson