61.31L, you don't need to be rated to fly an experimental solo

RussR

En-Route
Joined
Jan 12, 2011
Messages
4,085
Location
Oklahoma City, OK
Display Name

Display name:
Russ
This paragraph came up on a Facebook group, where someone was building a twin-engine experimental single-seat aircraft (in a Cessna 337-style engine configuration) and contended that they did not need a multiengine rating.

I consider myself pretty good with the regulations*, but I don't do much with experimental aircraft so hadn't read, or hadn't really considered this paragraph before.

61.31:
(l) Exceptions.

(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;

This seems to say that as long as you are a pilot of some sort, you can fly an experimental aircraft (which includes E-AB as far as I know), without having the normally-appropriate ratings for that aircraft, as long as you're the only one in it. Doesn't say it has to be single-seat.

So, I've never flown a hot-air balloon, but I could legally build one and fly it, solo.
A Private Pilot - Glider could fly a turboprop-converted RV-10, solo.
An airline pilot with no seaplane experience could fly an experimental seaplane, solo.

Am I reading this correctly? I imagine the practical impact of this is virtually zero, as I imagine most experimental aircraft have ratings requirement written right into their operating limitations when signed off by the DAR.

But what other ramifications does this rule have? It seems to be an unusual one. Is there a real application for this rule? Is it historical?

* Despite what some of you may think after the "XC endorsement thread", but I'm sticking to my views on that one...
 
Also, the practical impact is zero because…. Hopefully few people are that stupid so as not to get training!
 
Am I reading this correctly? I imagine the practical impact of this is virtually zero, as I imagine most experimental aircraft have ratings requirement written right into their operating limitations when signed off by the DAR.

But what other ramifications does this rule have? It seems to be an unusual one. Is there a real application for this rule? Is it historical?
My opinion is that it's a holdover from when EAB was a little more hands-off. There may be a few airplanes out there that never got updated OpLims but I expect most now have the 'shall hold an appropriate category/class rating' in them. Mine also allow an instructor's endorsement in lieu of rating, so I suppose if I could find a sucker willing intructor I could fly my multi-engine powered-lift homebuilt. :)

Nauga,
who doesn't really have a multi-engine powered-lift homebuilt.
 
Guaranteed this won’t work— they are grasping at straws. My OPLIMS (issued in 2015) specifically state, and I quote “The pilot in command of this aircraft must hold an appropriate category/class rating. If required, the pilot in command also must hold a type rating in accordance with part 61, or an LOA issued by an FAA Flight Standards Operations Inspector”.

For those who don’t know, OPLIMs are part of the special airworthiness certificate and have to be kept with the AWC on the airplane. A ******** interpretation of a part 61 paragraph won’t trump it.
 
You can permanently solo in TCd aircraft you’re not rated for as well, depending on how the instructor endorsed the solo authorization.

At one point in time, I recall one of the helicopter kit manufacturers leveraging this regulation on their website. I haven’t looked for a long time to see if they still are.
 
Yeap. I have flown solo many times in aircraft I was not rated in.

Gliders, helicopters and multi engine (well, ME was military so different rules).
 
Can you log multi engine time in an experimental twin if you don't have a multi- engine certificate?

mind-blown.gif
 
Last edited:
Can you log multi engine time in an experimental twin if you don't have a multi- engine certificate?

You can log PIC in any aircraft, rated or not, experimental or not, as long as you are the only occupant. 61.51e(1)(ii). Doesn't mean you're legal to be doing it, but if you are doing it, it's "okay" to log it as such.

But 61.31L says that you're legal to do it in the first place if it's an experimental and you're alone. Barring the operating limitations saying "AMEL required" of course.
 
Can you log multi engine time in an experimental twin if you don't have a multi- engine certificate?

Experimental or not, there are provisions that will allow a person to log PIC time in an aircraft for which they aren't rated. The difference in this case is that with an experimental you could do it with no training and no endorsement.
 
I'd like to know which plane is it? A single seat twin? Must be a rocket.
 
That has been my dream ride assuming I fit comfortably.
 
From the ad: "Requires Experimental Turbojet Type Rating."
No such thing... what is required for an experimental jet is a "Letter Of Authorization" which amounts to the same thing.
 
From the ad: "Requires Experimental Turbojet Type Rating."

That doesn’t indicate if it’s “Experimental Exhibition” or just “Experimental”. Big difference in the utility of the aircraft.
 
I never looked into this rule super deeply, because I never intended to use it, but I remember someone (so yeah, take that for what it's worth) saying it's intentional, and meant for people building / inventing things from scratch that may or may not fit in the rules yet. I remember it being explained as one of those old school "freedom" things: if you've at least got a private pilot certificate, you should at least have an idea of what risks you're taking putting a jet engine on your lawn chair, sticking out your arms as wings, and pushing the big red button.

I'm sure there are a million other ways this wouldn't pass muster, but I remember that being the general rationale.
 
And there are more than just the two types of Experimental

  • Research and development — an aircraft whose purpose is to test new design concepts, equipment, or operating techniques
  • Showing compliance with regulations — a prototype aircraft that is built for the purposes of demonstrating the airworthiness of a design
  • Crew training - an aircraft used solely for training that, for some reason, does not have a standard certificate (e.g. the NASA Shuttle Training Aircraft)
  • Exhibition
  • Air racing
  • Market surveys — a sales demonstration aircraft
  • Operating amateur-built aircraft
  • Operating kit-built aircraft
  • Operating light-sport aircraft
  • Unmanned Aircraft Systems
And then there are also Restricted, Limited, Special, Provisional.
 
Back
Top