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Short Version: How does the FAA define the terms "make" and "model" in regulatory documents, particularly in the context of referring to pilot experience in aircraft?


Long Version

In 14 CFR 135—and doubtless elsewhere in 14 CFR—the FAA occasionally uses the terms "make", "model", or some combination of these, such as "make and model".

Specifically, §135 gives requirements for pilot experience to be eligible for certain operations, such as to operate under "eligible on-demand" rules or to act as PIC.

See, for example, 14 CFR 135.4, "Applicability of rules for eligible on-demand operations":

(3) Pilot operating limitations. If the second in command of a fixed-wing aircraft has fewer than 100 hours of flight time as second in command flying in the aircraft make and model and, if a type rating is required, in the type aircraft being flown, and the pilot in command is not an appropriately qualified check pilot, the pilot in command shall make all takeoffs and landings in any of the following situations: [omitted for brevity]

(4) Crew pairing. Either the pilot in command or the second in command must have at least 75 hours of flight time in that aircraft make or model

See also, 14 CFR 135.105, "Exception to second in command requirement: Approval for use of autopilot system":

No certificate holder may use any person, nor may any person serve, as a pilot in command under this section of an aircraft operated in a commuter operation, as defined in part 119 of this chapter unless that person has at least 100 hours pilot in command flight time in the make and model of aircraft to be flown and has met all other applicable requirements of this part.

See also, 14 CFR 135.244

(a) No certificate holder may use any person, nor may any person serve, as a pilot in command of an aircraft operated in a commuter operation, as defined in part 119 of this chapter unless that person has completed, prior to designation as pilot in command, on that make and basic model aircraft and in that crewmember position, the following operating experience in each make and basic model of aircraft to be flown:

In contrast to the foregoing, the FAA often uses the term "type" to refer to the group of aircraft that the pilot must be experienced or trained on. An example of this would be §135.225 (e), where a pilot is required to have logged 100 hours as pilot in command in that type of airplane.


My question is, what does the FAA mean by these terms, and how should we apply them?

I would typically understand the term "make" to refer to the manufacturer: Cessna.

I would typically understand the term "model" to refer to the basic model, without reference to sub-model designations: 172 (but not 172M vs 172R). However, note where the FAA uses the phrase "make and basic model", to make this idea clear, perhaps in contrast to a separate meaning where the word "basic" is omitted.

Type, in reference to pilot certification, seems clearly to refer to all types encompassed by a type rating designation.

To apply this, would a pilot's time in a Cessna Citation 550 Bravo count toward the time required when operating a Cessna Citation 560 Encore? What about in a Cessna Citation 500 or a Cessna Citation 560 Ultra? All of these fall under the same type rating.

Does the FAA offer some guidance on this, or is there a letter of interpretation perhaps?

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The FAA has not defined those terms in §1.1 or elsewhere in the FARs and as such common language definitions are used. Make would be the manufacturer and model is aircraft family group but as J Walters mentioned not the subgroup.

I would personally define make and model aircraft based on whether or not the type certificate data sheet is the same for those airplanes. In looking up Piper aircraft PA28 series airplanes, the TCDS includes aircraft from -140 all the way through -201T.

Looking up the TCDS for Citation 500 and 560 and they have the same TCDS.

An Aircoastal Helicopters legal interpretation defines a "basic make and model" as an aircraft the pilot will actually fly.

Most 135 operators will receive a 293 check in a specifc make and model aircraft and if the additional aircraft has the same type rating will then receive differences to the additional aircraft they are going to fly. The aircraft FSB (flight standardization board) report will list the required differences between make and model aircraft inside each type rating.

The FSB report for the Citation 500 and 560.

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TL;DR: The make of an aircraft is the name of the designer (for example, Boeing) and the model of an aircraft (also called the type) is the designation for the general design of the aircraft (for example, 737). It looks like "basic model" is just an older term for "model".

According to FAA Order 8000.71:

c. Aircraft Make. An aircraft make is the name assigned to the aircraft by the manufacturer when it was produced. In most cases, the aircraft make is the organization common name of the aircraft manufacturer. If the organization that holds rights to an aircraft design permits another organization to build that aircraft then the aircraft make would be the aircraft name assigned by the organization that holds rights to the aircraft design in most cases. If an aircraft manufacturer is an amateur construction, then the aircraft make would be the name of the organization responsible for design in most cases.

and

c. Aircraft Model. An aircraft model is an aircraft manufacturer's designation for an aircraft grouping with similar design or style of structure.

(1) The aircraft model listed in the aircraft TC is the designation used by the aircraft manufacturer to distinguish a particular aircraft or is the designation used by a national military or armed force to distinguish a particular aircraft.

(2) If an aircraft manufacturer is amateur construction, then the aircraft model would be the name designated by the organization responsible for the design in most cases.

Also,

(7) Title 14 of the Code of Federal Regulations (14 CFR) 1.1 defines "type" and provides the basic classification for aircraft as follows:

"(2) As used with respect to the certification of aircraft, means those aircraft which are similar in design. Examples include: DC-7 and DC-7C; 1049G and 1049H; and F-27 and F-27F."

Examples: 777

DC-9

Note: Historical policy and documentation may refer to type as "basic model."

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  • $\begingroup$ The FAA may also consider two different models "similar enough" to require no, or very little, additional training. Back in my charter days, "Twin Cessna" was a single checktide with only minimal ground training for differences between a 310, 414, and 421. $\endgroup$ – acpilot Apr 23 '18 at 23:57
  • $\begingroup$ @ACpilot, but my question is, would an SIC have to log 100 hrs in the 421 specifically, in order to be have the privilege of making landings to destination analysis airports under eligible on-demand rules, or did time in the 310 count toward that? $\endgroup$ – J Walters Apr 24 '18 at 20:03
  • $\begingroup$ @sean So my reading of the FAA oder would lead me to believe that the CE-550 Bravo is a model distinct from the CE-560, model, which includes both the Ultra and Encore. $\endgroup$ – J Walters Apr 24 '18 at 20:05
  • $\begingroup$ For our operation and our particular POI, twin cessna time was all the same. $\endgroup$ – acpilot Apr 26 '18 at 4:29

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