Flying an amphib without a seaplane rating

[ahramin]

I've been asked to do some IFR instruction on an amphib beaver. I don't have a seaplane rating but all flights will be to and from land. Anyone think this is legal? What about a pilot without a seaplane rating flying an amphib only on land?

[Meatservo]

How many hours of instruction are you doing? The reason I ask is, you could do a touch&go on water a few times in seven hours, and the guy could give you your seaplane rating.

[PilotDAR]

If you do all of the flying with the wheels extended, the plane would effectively be a "land aircraft":

Subpart 1 — Interpretation
Interpretation

101.01 (1) In these Regulations,
............
land aircraft means an aircraft that is not capable of normal operations on water; (aéronef terrestre)

(A wheels down amphib Beaver operation on water would not be normal)

And you have a "land" class on your license....

[Redneck_pilot86]

Is this instruction toward an initial IFR? If not, I dont think you would need to be PIC, the beaver pilot would be and I assume he has a float rating.

[digits_]

If you do all of the flying with the wheels extended, the plane would effectively be a "land aircraft":

Subpart 1 — Interpretation
Interpretation

101.01 (1) In these Regulations,
............
land aircraft means an aircraft that is not capable of normal operations on water; (aéronef terrestre)

(A wheels down amphib Beaver operation on water would not be normal)

And you have a "land" class on your license....

Not really, I would say using a gear lever is part of normal operations of an airplane. So an amphib airplane is not a land plane according to the above definition.

On the other hand, you don't need a land rating to fly an amphib airplane according to that definition.

[target]

That is all very nice discussion however every time I read one of these questions my immediate question is, will insurance pay if something is damaged. Transport may wage there finger at you, but if your not covered by insurance you could be out a lot of money and open to being sued.

[ahramin]

30 hours, it's an initial. The owner has a ppl so I don't think touch and goes would help. Looks like it's time to get that sea rating as I'm in agreement that a gear handle is normal operation .

[photofly]

I had the same question put to TC for me, and the answer came back a categorical "no". You must have a seaplane rating to be PIC of an amphib.

On whether you can give instruction without being PIC: When you consider the role and responsibility of the PIC, it's hard to see how someone can fulfil that role while under instruction. Read for instance the new rubric in the flight test guide about why the examiner now must be PIC for flight tests. In short you want that rating because otherwise "it won't look good at the enquiry" - you as the more experienced pilot and instructor will be held to be PIC regardless, and not having the appropriate rating will only make things worse for you.

If you want your friend to file a real instrument flight plan and get experience in IMC you will have to be PIC, anyway.

Also note the CAR (can't remember which one) that says anyone giving instruction must be familiar with the flight characteristics of the aircraft used. Hard to argue that one in an amphib with a straight face if you don't have the float rating.

Finally: you'll need to remind your friend that if he or she wants to take the flight test in the beaver they'll need to find a Pilot Examiner with a float rating too.

[SuperchargedRS]

Seems silly to have access to such a excellent plane and not maximize on it to get BOTH your instrument and float, especially if you have any airports near water, shooting a approach to break out and then landing on water would be a great thing to do with the awesome aircraft you have been given access to.

[350i]

With respect to Photos "categorical No," according to the regulations, or lack there of, an amphibian is a landplane as long as you do not land nor take off on the water. The majority of Transport Canadas' own inspectors fly the companys C206 Amphibian without a float endorsement / rating.

Submit your application to be added to the insurance on the aircraft. If the insurance company will accept you without a float rating, go for it. Have the owner or designated instructor give you a good checkout on the aircraft if need be to satisfy the "familiarity of flight characteristics of the aircraft" prior to instruction if this is of concern. insurance would probably require it anyways.

The examiner DOES NOT require a float endorsement to do the IFR Ride so long as they do not take off nor land on the water.

[photofly]

That's an interesting take; but just to be clear it's not my reading of the regulations that I was reporting. The "categorical no" came directly from the local TC office.

Time for an email to CASO-SACO, I feel.
EDIT: done. I'll post whatever reply I get here.

[ahramin]

Get anywhere with that email photo? I just thought of another interesting point. Let's say I have no licence, buy an amphib beaver, and get my private licence on it. To keep things simple and the insurance company happy we only fly it on wheels while I am learning. So while I am a student, I can fly it as much as I want on land or water, solo or dual. As soon as I pass everything and get my licence signed off, I can no longer fly it until I get my seaplane rating. Is that right?

[ahramin]

How about this, we pull and collar the breaker for the gear and make a log entry that the landing gear retraction system is inop and aircraft is only released for land operations. Legal now? I should add for the AvCanada crowd that we're not actually going to do this, I'm just philosophizing further on flying amphibs from land without a seaplane rating.

[photofly]

Get anywhere with that email photo?

Nothing substantive, yet.

Your email message sent to the Civil Aviation Services Ontario email account (CASO-SACO@tc.gc.ca<mailto:CASO-SACO@tc.gc.ca>) has been received. Your request will be processed by our office in the order in which it was received and in accordance with our published Civil Aviation Service Standards, available at: http://www.tc.gc.ca/eng/civilaviation/o ... ds-549.htm.

. I just thought of another interesting point. Let's say I have no licence, buy an amphib beaver, and get my private licence on it. To keep things simple and the insurance company happy we only fly it on wheels while I am learning. So while I am a student, I can fly it as much as I want on land or water, solo or dual. As soon as I pass everything and get my licence signed off, I can no longer fly it until I get my seaplane rating. Is that right?

Im not sure, but it's fun to speculate.

If TC classifies an amphib as a seaplane, then you'll have to take a seaplane PPL flight test and end up with a PPL seaplane (which you can do, I'm told). The class rating for ASES refers to what category/class of aircraft you can fly, not where you can land it, so if your seaplane also has wheels you can presumably put it down on land.

You couldn't fly a regular wheeled aircraft though, not through lack of skill but because you don't hold the rating for that class.

As I said earlier, I'm entirely not sure, and this is just speculation from me.

More interestingly, would the training in the amphib on land count as "land plane training" required towards the land plane rating? If so, you could apply on the same application form as your PPL as get both land and sea ratings at the same time. That would make the most sense to me.

The parallel question to your original one is can a pilot who holds only a seaplane rating be PIC of an amphib? I'm going to guess the answer is yes.

[ahramin]

The rules certainly seem to have been written on the assumption that no pilot would have sea but not land rating. Or maybe on the assumption that no aircraft could be both a sea and a land plane. I don't think amphibs are mentioned anywhere in the CARs. Maybe they just forgot amphibs existed when they wrote the them.

[PilotDAR]

we pull and collar the breaker for the gear and make a log entry that the landing gear retraction system is inop and aircraft is only released for land operations.

Poor idea. It's an RG, there are times when a land forced landing would be better accomplished wheels up. Don't deny yourself this element of safer operation.

I can't assert the actual law, but I would be very surprised if TC took issue with an amphib being honestly flown as a land plane only, particularly when the flight is honestly for the purpose of training. There is lot of history of Lake Amphibians being flown "land only" while the new pilot built experience. I can't see why a Beaver amphib need be any different. Perhaps BPF could offer a thought.

One of my clients bought a 182 amphib. He earned his license on a 180 floatplane, and had to get a land plane rating so I could train him in the 182 amphib (I suppose I could have given him the rating too, but he got it locally first). With that, a whole 8 hours in a 172, I trained him in the 182 on wheels in the winter. We practiced lots of crosswind landings and forced approaches.

If you're going to fly an amphib floatplane as a wheel plane, consider your eye height - it's way different, and bear in mind that a gliding forced approach has a very different approach angle, and comfortable speed.

I too will be interested to hear a formal interpretation from TC on this...

[photofly]

The rules certainly seem to have been written on the assumption that no pilot would have sea but not land rating.

Consider the very existence of the land plane rating....

He earned his license on a 180 floatplane, and had to get a land plane rating so I could train him in the 182 amphib

On what basis did you and he decide he needed a land plane rating so you could train him in an amphib? Just curious.

[ahramin]

we pull and collar the breaker for the gear and make a log entry that the landing gear retraction system is inop and aircraft is only released for land operations.

Poor idea. It's an RG, there are times when a land forced landing would be better accomplished wheels up. Don't deny yourself this element of safer operation.

Legal now? I should add for the AvCanada crowd that we're not actually going to do this, I'm just philosophizing further on flying amphibs from land without a seaplane rating.

In my experience there are many cases where you can make a safe situation legal by making it unsafe as in the example above. Your experience with TC seems to be quite different from mine, but gives me hope. I do have a call in with TC and if they call back I'll look forward to getting an answer where the above scenario isn't the one that makes the most sense.

He earned his license on a 180 floatplane, and had to get a land plane rating so I could train him in the 182 amphib

On what basis did you and he decide he needed a land plane rating so you could train him in an amphib? Just curious.

While it should be obvious, the CARs seem to side with photo on this one (at least the present day ones). If a pilot with a sea only licence flies an amphib around, I don't know what CAR they would be violating. Also how did he get a landplane rating? Did such a thing exist back then because I can't find a standard for getting a landplane rating in the CARs today.

[SuperchargedRS]

Insurance wise, I don't think a promise to never land on water, or screwing with the amphib systems will help. Also not being able to retract the gear, and not training to swing the gear (positive rate) is VERY stupid, and I don't think any instructor worth a damn would agree to train like that.

Where I live 4-5 months out of the year it's too cold for water ops, I tried a few companies to see if I could get out of paying the crazy amphib rates seeing all of the liquid in the area was now solid and there wasn't even a place to do water landings, long and short, all the insurance companies told me unless I put the plane back in its taildragger configuration I'd have to still pay full amphib rates.

[photofly]

Also how did he get a landplane rating? Did such a thing exist back then because I can't find a standard for getting a landplane rating in the CARs today.

The requirements for the landplane rating are listed in CAR421.38(2), immediately following the requirements for the seaplane rating. They are:

(a) Experience
An applicant for a landplane rating shall complete the following:

(i) a total of 3 hours of landplane training including:
(A) a minimum of 2 hours dual instruction, and
(B) a minimum of 5 takeoffs and five landings as sole occupant of the aeroplane.
(ii) The following exercises shall be included in the landplane training:
(A) taxiing,
(B) landings, including crosswind landings, and
(C) takeoffs.

If you did your initial PPL in an amphib, including wheels landings, I think you could make a strong argument to say that although you weren't necessarily in a landplane at the time (if in fact TC deems an amphib to be a seaplane), you had completed the required landplane training and therefore qualified for the landplane rating at the same time as your PPL seaplane.

[ahramin]

Whoops, thanks photo. Rolled right over that.

Had a further thought this morning. A company I flew for used to change the gross weight of their aircraft on a flight by flight basis to save on landing fees. Basically a logbook entry and a placard and voila, max takeoff weight changed by 20 tons. If you can do that with an aircraft limitation, surely you could change the configuration. "Aircraft approved for land flights only" in logbooks and placard. Now you have a legal landplane without having to do anything unsafe.

[ahramin]

Also not being able to retract the gear, and not training to swing the gear (positive rate) is VERY stupid, and I don't think any instructor worth a damn would agree to train like that.

Legal now? I should add for the AvCanada crowd that we're not actually going to do this, I'm just philosophizing further on flying amphibs from land without a seaplane rating.

Insurance wise, I don't think a promise to never land on water, or screwing with the amphib systems will help. Where I live 4-5 months out of the year it's too cold for water ops, I tried a few companies to see if I could get out of paying the crazy amphib rates seeing all of the liquid in the area was now solid and there wasn't even a place to do water landings, long and short, all the insurance companies told me unless I put the plane back in its taildragger configuration I'd have to still pay full amphib rates.

Maybe you're asking the wrong way. I've negotiated a similar arrangement with an insurance company. The letter was to the effect of pilot x will not land on water without having 100 hours on type. Helped keep the rate down. If I am correct that you can change the configuration to land plane through a logbook entry and placard, then perhaps you could find an insurance company that will insure you as a retract for 4 months of the year provided the configuration is legally changed. Not sure what the savings would be over an amphib though.

[AirFrame]

Insurance with a promise is certainly possible... When I bought my RV I had insurance arranged with the requirement that I get checked out on type before soloing it. I could have done it in my RV (in the end I did it in another before I picked mine up), and they didn't want any proof that i'd done the checkout nor did my rate change before/after getting checked out. Essentially, my promise not to fly it solo before checkout was adequate.

In another situation, a house I bought a number of years ago had a wood-burning stove in the basement, with a not-to-code (but probably safe) chimney on it. The insurance company said they couldn't insure me unless the stove was removed from the house. I countered that I would install a new chimney for it, and in the interim would promise not to use it. They agreed, and in the end I didn't even need to move the stove, all I had to do was remove the section of flue that went from the top of the stove to the ceiling in the basement (about a 4' pipe section) and then take a photo for them.

In each case, nothing would have stopped me from breaking my promise, and either flying or having a fire anyway. But if anything had gone wrong, it would probably have been pretty easy to show that I had done so. The situation is similar with the amphib... If all they do is fly off land, the logs will show that. If they happen to crash on a remote lake where hikers nearby were watching them do water circuits, chances are the insurance company won't buck up for the recovery...

[SuperchargedRS]

The talk I had, it was about what was hanging under my plane, amphibs was one rate, taildragger gear was another rate.

I even mentioned I would promise not to land on water (winter ops where everything was frozen anyway), I mentioned that for land ops a amphib is actually safer for land, off field with the gear up chances are very little damage to the airframe and near zero chance of a flip, way less likley to loose control on the ground compared to tailwheel, or even a trike, accidentally land with the gear up on a runway it's not even that much damage, paint and worse case a new keel strip.

Nope

All the companies I spoke with were only concerned with what was bolted to my plane.

[photofly]

Today I got the answer to my query.

Mr Xxxx witout a float rating you may not operate the amphibious aircraft.

https://www.tc.gc.ca/eng/civilaviation/ ... t1-189.htm


Regards,


Nancy Xxxxx
Agente licence du personnel, Services | Personnel Licensing Agent, Service
Transports Canada | Transport Canada
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