Does anyone know the FAA rational for requiring the second pilot on board to have access to a complete Fully functioning set of flight controls in order to act as safety observer for the purpose of logging instrument activities with a view limiting device in VMC?
I have a Long EZ, which has a flight control side stick in the rear cockpit, but no rudders or throttle. I have been told I cannot log practice approaches in VMC with a rated pilot in the back seat because it does not have a complete set of flight controls. This is (as far as I can see from FARs), documented in 14 CFR § 91.109, (c), which reads:
To address comments below, please see FAA interpretation of "fully functioning dual controls" and Final FAA Interpretaton.
The first FAA Letter above basically states that brakes are not required, but that pitch, roll, and yaw controls are required. It does not discuss or mention power.
The second reference is the final FAA order, (Bulletin HBGA 00-08) it does specifically discuss the throttles, and then states:
Office of General Counsel clarified its position that the term “dual controls” as used under 14 CFR section 91.109(a) refers solely to the flight controls of an aircraft (e.g., pitch, yaw, and roll controls)
As it would seem that the purpose of the safety observer is observe the sky for other traffic and, in the event of an impending or threatening conflict, either
- Inform the pilot to take off his/her view limiting device and deal with it, or ...
- Take the controls and maneuver the aircraft to avoid the conflict.
I do not understand how rudders or throttle in any way impede the capability of the safety observer to perform that function. It's also curiously inconsistent with the exception made for aircraft with throwover control wheels, (like in Bonanzas). Also, because I fly in Arizona where the flight conditions are (thankfully), IMC only 25-30 days a year, and because of the wide diversity of avionics in so many GA aircraft nowadays, because of this constraint, my only alternative is to perform practice approaches in another aircraft with different avionics and autopilot switchology from what is in my primary aircraft. With modern avionics, basic instrument procedures and instrumentation now represent an ever-increasingly smaller percentage of the knowledge and skills necessary for IFR flight, so satisfying my IFR currency requirements in an aircraft with very different avionics becomes more and more counter-productive instead of actually increasing my proficiency.
Does anyone know the actual FAA rational for this constraint?