Can a student pilot move an aircraft on the ramp?

John Richardson

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John Richardson
I tried to answer my own questions from the FARs, but can't find anything conclusive. Can the owner of an aircraft--who holds a student pilot certificate--move said aircraft on the ramp for reasons that don't involve flying? For example: My plane needs fueling before my CFI arrives for a training session. Is it legal for me to roll on over to the fuel pump by myself?
 
I tried to answer my own questions from the FARs, but can't find anything conclusive. Can the owner of an aircraft--who holds a student pilot certificate--move said aircraft on the ramp for reasons that don't involve flying? For example: My plane needs fueling before my CFI arrives for a training session. Is it legal for me to roll on over to the fuel pump by myself?

Yes it is.
 
My CFI disagrees. Can anyone cite a FAR that conclusively clarifies whether allowed/disallowed? (My CFI can't)

14 CFR 1.1
Flight time means:

(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing

So you are not "Flying".

61.89 General limitations. No limitations there.

91.13 Careless or reckless operation.
(a) Aircraft operations for the purpose of air navigation. No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.

(b) Aircraft operations other than for the purpose of air navigation. No person may operate an aircraft, other than for the purpose of air navigation, on any part of the surface of an airport used by aircraft for air commerce (including areas used by those aircraft for receiving or discharging persons or cargo), in a careless or reckless manner so as to endanger the life or property of another.
 
(b) Aircraft operations other than for the purpose of air navigation. No person may operate an aircraft, other than for the purpose of air navigation, on any part of the surface of an airport used by aircraft for air commerce (including areas used by those aircraft for receiving or discharging persons or cargo), in a careless or reckless manner so as to endanger the life or property of another.

Which means for the belt and suspenders approach, get your CFI to give you a taxi lesson (he does that every time you fly, from exiting the runway to the tie down - doesnt he?) and then put a short endorsement in your logbook: "I have given Mr X taxi lessons in this aircraft on the grounds of Kyyy and he is competent to reposition this aircraft on this airport solo, for the purpose of refueling and returning to the tie down. Signed xxx CFI ######". That should keep everyone happy.

-Skip
 
Which means for the belt and suspenders approach, get your CFI to give you a taxi lesson (he does that every time you fly, from exiting the runway to the tie down - doesnt he?) and then put a short endorsement in your logbook: "I have given Mr X taxi lessons in this aircraft on the grounds of Kyyy and he is competent to reposition this aircraft on this airport solo, for the purpose of refueling and returning to the tie down. Signed xxx CFI ######". That should keep everyone happy.

-Skip

I don't even see a reason for the endorsement. And if his CFI is already telling him no, then there is no chance he would even do this.

Remember, there are mechanics with no pilot ratings that taxi aircraft around the airport, and they don't require any endorsements. So why should a student pilot?
 
Sounds like you are the student and owner of the plane so I don't see why not. At the school I'm taking lessons at they have given me the green light to taxi for gas anytime it is needed. Their reasoning was, you're signed of to solo so you can safely move an aircraft around the ramp to get gas. Is your CFI, just trying to help you build hours with the hobbs counter travel to/from the pumps with him in it? I guess that could be a small advantage, but now your paying your CFI to babysit you while you fill the tanks prior to departure. In looking at Skips response that is probably the safest way to handle this.
 
I don't even see a reason for the endorsement. And if his CFI is already telling him no, then there is no chance he would even do this.

Remember, there are mechanics with no pilot ratings that taxi aircraft around the airport, and they don't require any endorsements. So why should a student pilot?

That's why I started with "For the belt and suspenders approach". -Skip
 
Who is going to stop you? This isn't an answer, just a way to look at it differently.
 
Are you allowed to push your plane around in your hangar, or from one tie down to another? Why is taxiing it (not for the purposes of flight) any different?
 
14 CFR 1.1
Flight time means:

(1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing

So you are not "Flying".

61.89 General limitations. No limitations there.

91.13 Careless or reckless operation.
(a) Aircraft operations for the purpose of air navigation. No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.

(b) Aircraft operations other than for the purpose of air navigation. No person may operate an aircraft, other than for the purpose of air navigation, on any part of the surface of an airport used by aircraft for air commerce (including areas used by those aircraft for receiving or discharging persons or cargo), in a careless or reckless manner so as to endanger the life or property of another.
Also from 14 CFR 1.1:

"Crewmember means a person assigned to perform duty in an aircraft during flight time."

and

"Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose (except as provided in §91.13 of this chapter) of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise)."
From 14 CFR 61.3(a):

"Required pilot certificate for operating a civil aircraft of the United States. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:" [list of certificate and license options omitted] [emphasis added]


 
Also from 14 CFR 1.1:

"Crewmember means a person assigned to perform duty in an aircraft during flight time."

and

"Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose (except as provided in §91.13 of this chapter) of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise)."
From 14 CFR 61.3(a):

"Required pilot certificate for operating a civil aircraft of the United States. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:" [list of certificate and license options omitted] [emphasis added]



And your point?
 
My plane needs fueling before my CFI arrives for a training session. Is it legal for me to roll on over to the fuel pump by myself?
That’s a felony with up to 25 years in prison.

I kid. :)
 
My first CFI wouldn't let me taxi to the pumps until I solo'd. His personal decision I'm sure. He also made sure to note anytime we fueled the plane in my log book, ground operations and fuel procedures. Apparently he had one of his students that crashed and killed himself after getting his PPL. Fuel starvation. He was sued on the basis that there was nothing in the pilots log book about being trained on how to fuel the plane. Didn't hold up but I then understood why he always made note of it.
 
Also from 14 CFR 1.1

"Required pilot certificate for operating a civil aircraft of the United States. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:" [list of certificate and license options omitted] [emphasis added]


What regulation requires a flight crewmember to drive an airplane around on the ground?
 
As a mechanic and student pilot I taxi regional jets around on an international airport all the time. Mechanics move them to and from the gate between Mx.
 
Sounds like your CFI doesn’t trust you to move the plane by yourself.
 
Also from 14 CFR 1.1:

"Crewmember means a person assigned to perform duty in an aircraft during flight time."

and

"Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose (except as provided in §91.13 of this chapter) of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise)."
From 14 CFR 61.3(a):

"Required pilot certificate for operating a civil aircraft of the United States. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:" [list of certificate and license options omitted] [emphasis added]
In a 2011 interpretation, I found a quotation from a 1979 interpretation that implies the word "operate" is connected with an intent to take off. I'm not an attorney, but it looks to me like that reinforces the premise that taxiing to the fuel pump does not constitute operation, so that the 14 CFR 61.3 requirement for a pilot certificate does not apply. (I haven't found a copy of the 1979 interpretation.)

May 4, 1979, Letter to Delfina R. Mott from Edward P. Faberman, Acting Assistant Chief Counsel (quoting Amendment 91-43, 32 Fed. Reg. 9640 (1967)).

As the FAA's 1979 letter points out, an aircraft is being operated when its engine is turned on with the intent of using that aircraft to takeoff and engage in air navigation.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Murphy - (2011) Legal Interpretation.pdf


 
Is it legal for me to roll on over to the fuel pump by myself?
Yes, provided the airport management policy allows it. The FAA defers oversight/responsibility of airport ground movement of aircraft and vehicles to the airport management and their policies which falls under Part 139 not Part 91. Some airports have requirements that only individuals with FAA certificates may move aircraft on their respective airport. Some don't. There is an FAA Order that details this. Here's some examples of airport policy:
https://www.mobileairportauthority.com/mra/uploads/maa-rules-&-regulations-(app.-12.11.18)(ld1).pdf
upload_2019-10-23_17-3-31.png
https://www.panynj.gov/airports/pdf/rules_regs_revision_8_04_09.pdf
upload_2019-10-23_17-4-27.png
 
Yes, provided the airport management policy allows it. The FAA defers oversight/responsibility of airport ground movement of aircraft and vehicles to the airport management and their policies which falls under Part 139 not Part 91. Some airports have requirements that only individuals with FAA certificates may move aircraft on their respective airport. Some don't. There is an FAA Order that details this. Here's some examples of airport policy:
https://www.mobileairportauthority.com/mra/uploads/maa-rules-&-regulations-(app.-12.11.18)(ld1).pdf
View attachment 78923
https://www.panynj.gov/airports/pdf/rules_regs_revision_8_04_09.pdf
View attachment 78924
Looks like Part 139 would not apply to the majority of general aviation airports.

§139.1 Applicability.

(a) This part prescribes rules governing the certification and operation of airports in any State of the United States, the District of Columbia, or any territory or possession of the United States serving any—

(1) Scheduled passenger-carrying operations of an air carrier operating aircraft configured for more than 9 passenger seats, as determined by the regulations under which the operation is conducted or the aircraft type certificate issued by a competent civil aviation authority; and

(2) Unscheduled passenger-carrying operations of an air carrier operating aircraft configured for at least 31 passenger seats, as determined by the regulations under which the operation is conducted or the aircraft type certificate issued by a competent civil aviation authority.

(b) This part applies to those portions of a joint-use or shared-use airport that are within the authority of a person serving passenger-carrying operations defined in paragraphs (a)(1) and (a)(2) of this section.

(c) This part does not apply to—

(1) Airports serving scheduled air carrier operations only by reason of being designated as an alternate airport;

(2) Airports operated by the United States;

(3) Airports located in the State of Alaska that only serve scheduled operations of small air carrier aircraft and do not serve scheduled or unscheduled operations of large air carrier aircraft;

(4) Airports located in the State of Alaska during periods of time when not serving operations of large air carrier aircraft; or

(5) Heliports.​
 
Mechanics taxi airplanes all the time without a pilot certificate. They’re not moving the plane for the purpose of flight, and that’s ok with the FAA.

As was mentioned, the insurance company might have rules about moving a plane.
 
Looks like Part 139 would not apply to the majority of general aviation airports.
Depends. If the the airport gets any type of FAA funding there is usually a clause in the funding docs they must adopt portions of the Part 139 requirements which normally require some sort of airport ops manual. Regardless its up to the airport who can ground taxi an aircraft, not the FAA.
 
Tell me about what qualification an A&P gets to start and run a particular aircraft? It's not like they're issued type ratings.
 
You'll be OK. When I did my PPL training, after the first few flights I'd pull the plane out of the hangar, start up and do the run-up on the ramp, before the instructor/owner would join me in the plane. It was a small grass strip in the middle of nowhere and there wasn't much of a run-up pad or a ramp....

Sent from my SM-T580 using Tapatalk
 
New question but related to taxi. Do you have to have a clearance at a controlled airport to taxi the plane to the fuel pumps?
 
Do you go through a movement area?

Since I am making it up as I go along, lets say you have to taxi from a tie down spot and can taxi across a big area of the ramp but it would be safer to skirt along on a taxiway for a 20 or 30 yards to get around a hanger. Answer for both.
 
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