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View Full Version : High Altitude Endorsement?


Tpinks
12-07-2015, 12:13 PM
OK, so I have not been able to find anything on this, but do you have to have the High Altitude Signoff to fly a pressurized High Altitude aircraft if it is not being flown at high altitudes?

Case would be, our company operates two Cessna Conquest II's that have a ceiling of 31,000ft, which makes them a "high altitude" aircraft as they are above the 25,000ft threshold of 61.31G. However, we use them for survey, so we can be anywhere from 1000ft AGL to 27,999ft as we are not RVSM equipped. Since I had nothing to fly today, I rode along with one of our conquests on production. We flew no higher than 5,500ft and I hand flew the plane most of the time. (First turboprop flight too btw, AWESOME!)

Essentially, What I am wondering is if there is any precedent of it being treated the same way seaplanes are treated. A "land only" pilot can legally fly any sea/float plane on wheels as long as it is not operated from water... its not that far of a stretch to think the same could apply here as in both cases, the plane has more capabilities than the pilot is licensed/signoff off for.


JohnBurke
12-07-2015, 01:34 PM
61.31 Type rating requirements, additional training, and authorization requirements.

(g) Additional training required for operating pressurized aircraft capable of operating at high altitudes. (1) Except as provided in paragraph (g)(3) of this section, no person may act as pilot in command of a pressurized aircraft (an aircraft that has a service ceiling or maximum operating altitude, whichever is lower, above 25,000 feet MSL), unless that person has received and logged ground training from an authorized instructor and obtained an endorsement in the person's logbook or training record from an authorized instructor who certifies the person has satisfactorily accomplished the ground training. The ground training must include at least the following subjects: ...


Note that the regulation specifies acting as pilot in command, and doesn't differentiate whether the aircraft is actually operated at high altitudes. If the aircraft has a service ceiling or max operatin galtitude above 25,000, then the high altitude endorsement (and training that goes with it) is required. The exception is subparagraph G(3):

(3) The training and endorsement required by paragraphs (g)(1) and (g)(2) of this section are not required if that person can document satisfactory accomplishment of any of the following in a pressurized aircraft, or in a flight simulator or flight training device that is representative of a pressurized aircraft:

(i) Serving as pilot in command before April 15, 1991;

(ii) Completing a pilot proficiency check for a pilot certificate or rating before April 15, 1991;

(iii) Completing an official pilot-in-command check conducted by the military services of the United States; or

(iv) Completing a pilot-in-command proficiency check under part 121, 125, or 135 of this chapter conducted by the Administrator or by an approved pilot check airman.

rickair7777
12-08-2015, 08:46 PM
JP is correct. You cannot be PIC. But you could be SIC, if required by type or operating regs (other requirements might need to be met).

You could also log dual received, and then get a high-altitude endorsement...probably the way to go if you're going to be doing it often.


Tpinks
12-10-2015, 08:18 PM
JP is correct. You cannot be PIC. But you could be SIC, if required by type or operating regs (other requirements might need to be met).

You could also log dual received, and then get a high-altitude endorsement...probably the way to go if you're going to be doing it often.All he did was recite a reg I already knew. He didn't answer my question...

The 441 is single pilot and we are pt 91, so no SIC. It was a one off flight, and eventually I will go to flight safety for it. I'm not worried about logging it, but rather just thought about that question in general.

This reg, in its current form, really is stupid considering my T310R, as configured, can fly just as high, yet requires no sign off since it is not pressurized.

JohnBurke
12-10-2015, 09:33 PM
All he did was recite a reg I already knew. He didn't answer my question...

The 441 is single pilot and we are pt 91, so no SIC. It was a one off flight, and eventually I will go to flight safety for it. I'm not worried about logging it, but rather just thought about that question in general.

This reg, in its current form, really is stupid considering my T310R, as configured, can fly just as high, yet requires no sign off since it is not pressurized.

If you knew the regulation, why did you ask?

It really doesn't matter if you make one flight or 100. The regulation states, VERY CLEARLY, that if you will act as pilot in command of a pressurized aircraft capable of operating above 25,000', you need the endorsement (unless one of the provisions of subparagraph 61.31(g)(3) applies to you).

This is the case regardless of whether your cockpit is single pilot or flown as a crew. If you intend to act as PIC, you need the endorsement.

If you never intend to fly the aircraft above 5,000' but will be acting as PIC, you still need the endorsement.

Your question was answered. It's been answered again.

JamesNoBrakes
12-11-2015, 11:39 AM
This reg, in its current form, really is stupid considering my T310R, as configured, can fly just as high, yet requires no sign off since it is not pressurized.

That's the entire reason the regulation exists. It's not for "flying high", it's for flying pressurized aircraft.

Tpinks
12-11-2015, 11:59 AM
If you knew the regulation, why did you ask?

This is the case regardless of whether your cockpit is single pilot or flown as a crew. If you intend to act as PIC, you need the endorsement.

If you never intend to fly the aircraft above 5,000' but will be acting as PIC, you still need the endorsement.

Your question was answered. It's been answered again.

I did not ask for a clarification of the reg nor did I ask u to copy and paste it. I specifically asked if there has been any precedent of it being treated similarly to how a land pilot can pilot a sea plane from an airfield without being a licensed sea pilot.

There is one set of FAR's yet as history and experience has shown, there are 80 different interpretations of those FAR's. There is a reason why people go FSDO shopping.

I was not the PIC for the flight, all I was there for was to get out of the office. My question comes from me and the PIC talking about the sign off in general.

Being pressurized does not make a difference in the sense that I can fly a pressurized plane that has a ceiling less than 25,000 without the sign off. Because of that fact, that means they intend for the reg to be based off of altitude being flown rather than the specifics of the plane.
Yet, then they allow non-pressurized aircraft to fly at any altitude without a sign off...

Therefore, what is the difference between flying a " low altitude" pressurized plane and flying a "high altitude" pressurized aircraft below 25,000ft that would require the additional training?

2StgTurbine
12-11-2015, 12:09 PM
Therefore, what is the difference between flying a " low altitude" pressurized plane and flying a "high altitude" pressurized aircraft below 25,000ft that would require the additional training?

That is like saying, can I fly a 225 horsepower plane without a high performance endorsement if I don't use more than 200 hp?

Call it crazy, but the FAA wants you to be trained infall aspects of the aircraft you are flying. Some rules feel more like jumping through hoops sometimes, but it is better than nothing. Despite all the regulations we have, there are still plenty of cowboy pilots and scumbag operators.

Tpinks
12-11-2015, 12:16 PM
That's the entire reason the regulation exists. It's not for "flying high", it's for flying pressurized aircraft.

No, otherwise you would need a sign off for a pressurized aircraft that is only capable of flying up to 25,000ft, like the P210 for example.

JohnBurke
12-11-2015, 01:08 PM
Why did you bother to ask the question? The answer has very clearly been given you.

No answer is adequate for you. You argue with every response.

Don't like the regulation? Lobby to get it changed.

I did not ask for a clarification of the reg nor did I ask u to copy and paste it. I specifically asked if there has been any precedent of it being treated similarly to how a land pilot can pilot a sea plane from an airfield without being a licensed sea pilot.


Again, NO, THERE IS NO "PRECEDENT."

I don't care if you asked for the regulation to be quoted. You got it. Deal with it. It was quoted so that it could be spelled out for you, with underlining, italics, and bolding, along with additional explanation and comment. You asked for responses. If you wanted to specific wording, perhaps you should have simply told us what it was that you wanted us to say, so we could parrot your words back to you.

Again, as you really don't seem to get it:

If you intend to act as PIC of a pressurized aircraft capable of flight above 25,000', then you need the high altitude endorsement, unless you are subject to 61.31(g)(3). It would appear that you are not subject to 61.31(g)(3), which means that whether you intend to fly at 2,500' or 25,000', and whether you intend to fly once or a thousand times as PIC, YOU NEED THE ENDORSEMENT.

"Precedent," as you call it, is irrelevant. The FAA Chief Legal Counsel provides interpretation of the regulation, which are defensible, and those letters of interpretation are one of three primary sources from which you may draw to determine the regulation. The other two are the regulation itself, and the Federal Register preambles. As you're so clearly in touch with the regulation, of course, you knew this. Right?

Additional insight may be had through studies of enforcement actions, appeals, and ALJ and board renderings. You knew that too, right?

There is no provision by the FAA, be it in any of the above named sources, that allows for bypassing the high altitude endorsement if you only intend to fly the aircraft once, or if you will be flying it, but not above 25,000. The simply fact of the matter is that if you intend to fly a pressurized aircraft capable of flight above 25,000' or certified for it, then you must have the endorsement if you intend to act as pilot in command (regardless of how often you fly the airplane, or how high you actually fly it). Is this not clear to you yet?


There is one set of FAR's yet as history and experience has shown, there are 80 different interpretations of those FAR's. There is a reason why people go FSDO shopping.


The FSDO is not authorized to provide a legal interpretation of the regulation for you. The FSDO level is not authorized to interpret regulation. Interpretations of the regulation may be obtained where the FAA Administrator has authorized or delegated that authority, and that comes from the FAA Chief and Regional legal counsels.

There aren ot 80 different interpretations of the regulation. Are you not familiar with the FAA Chief Legal Counsel interpretations? Have you not researched the information in the Federal Register preambles?

If you choose to go "FSDO shopping" nothing you receive will be defensible or worth more than an opinion; even if in writing it carries no authority, and you will never be able to defend yourself against enforcement action by saying "but the FSDO told me..."

The Code of Federal Regulations is quite clear with respect to Title 14 and the commonly used parts that you call the "FAR's" (a title actually reserved for the Federal Acquisition Regulations, incidentally, which do not cover aviation). In particular, the regulation regarding the requirement for a high altitude endorsement is unequivocal and obvious.


Being pressurized does not make a difference in the sense that I can fly a pressurized plane that has a ceiling less than 25,000 without the sign off. Because of that fact, that means they intend for the reg to be based off of altitude being flown rather than the specifics of the plane.
Yet, then they allow non-pressurized aircraft to fly at any altitude without a sign off...



Now you're presuming to know the meaning for the implementation and wording of the regulation? You get this based off guesswork, or you actually went to the Federal Register preamble, which gives the explanation of the reason for the regulation, it's background, research, comments for and against, etc? You're guessing, aren't you?


Therefore, what is the difference between flying a " low altitude" pressurized plane and flying a "high altitude" pressurized aircraft below 25,000ft that would require the additional training?

That would be 14 CFR 61.31(g). Would you like it quoted for you? that's the difference. The regulation requires it. End of story.

JamesNoBrakes
12-11-2015, 06:36 PM
Therefore, what is the difference between flying a " low altitude" pressurized plane and flying a "high altitude" pressurized aircraft below 25,000ft that would require the additional training?

The difference is the government doesn't have a control mechanism to take over your pressurized plane when you fly over 25,000'. They aren't going to let you fly a pressurized plane capable of flight above 25,000' on "scout's honor" that you'll keep it lower.

An Eclipse jet just crashed in South Africa in what looks like a possible decompression/hypoxia event. The regulations aren't there to stop people from flying a pressurized aircraft over 25,000', they are there to make it solely the responsibility of that person who chooses to operate in violation of the regulation and to shift the blame to them if something goes wrong, so that when all the parties line up to sue, they can sue the correct party, not the manufacturer, not the government, etc.

You could always petition FAA Headquarters for an exemption. There are instructions on the FAA.gov website for this. When you get to the website, from the upper bar select "Regulations and Policies" and from the next menu, "Rulemaking".

AC560
01-03-2016, 09:22 AM
JP is correct. You cannot be PIC. But you could be SIC, if required by type or operating regs (other requirements might need to be met).

You could also log dual received, and then get a high-altitude endorsement...probably the way to go if you're going to be doing it often.

For logging of PIC you need to be the sole manipulator and rated in category, class, and type. The endorsement is only required to act as PIC, so assuming OP has AMEL certificate and was sole manipulator then he/she could log PIC and dual received. I write this solely from a FAR perspective.

rickair7777
01-03-2016, 09:45 AM
For logging of PIC you need to be the sole manipulator and rated in category, class, and type. The endorsement is only required to act as PIC, so assuming OP has AMEL certificate and was sole manipulator then he/she could log PIC and dual received. I write this solely from a FAR perspective.


Technically correct. But this opens up the whole discussion about logging sole man vs. actual PIC, and what airlines think of that.

My recommendation is to log sole man PIC in a separate column of your logbook and only use it where it's considered acceptable (certain FAA experience requirements, certain employers). But for God's sake don't put it on a major airline app.



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