Are amphibious airplanes considered land or sea planes for pilot certification? Can an ASEL-only pilot fly an amphibious single-engine plane if (s)he only takes off and lands on land? Can an ASEL-only pilot take off from the left seat, then let the ASES-only pilot in the right seat take over and alight on water?
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2 Answers
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For pilot certification purposes there is no "amphibious" class (see 14 CFR 61.5 (b)(2) ). Consequently, again for pilot certification purposes, (the rating held on your pilot certificate), practical tests (flight checks) taken in amphibious airplanes can result in either a "sea" class rating, "land" class rating, or possibly both. This would depend upon the class rating the pilot trained for, applied for, and was tested for, under 14 CFR Part 61. (See 14 CFR 61.45 (a) and (b))
So, for example, in my opinion, if a pilot holds a Private pilot certificate with only an Airplane Single-engine Land rating then he/she could fly an amphibious Single-engine airplane, but could only takeoff and land on "land." In the alternative, if the pilot held a Private pilot certificate with only an Airplane Single-engine Sea rating, he/she could fly an amphibious Single-engine airplane, but could only takeoff and land on "water."
This is an informative FAA legal interpretation (Fitch) which states, in pertinent part:
Title 14 C.F.R. § 61.45(a)(l)(i) states, in relevant part, that" ... an applicant for a certificate or rating issued under this part must furnish (1) An aircraft of U.S. registry for each required test that-(i) Is of the category, class, and type, if applicable, for which the applicant is applying for a certificate or rating ...." Additionally, the aircraft required for a practical test must have "[t)he equipment for each area of operation required for the practical test" and no operating limitations that would prohibit its use in any of the areas of operation required for the practical test. 14 C.F.R. § 61.45( b)(l )(i) -(ii). Under 14 C.F.R. § 6 l.45(b)(2), if an applicant for a certificate or rating uses an aircraft with operating characteristics that preclude the applicant from performing all of the tasks required for the practical test, the applicant's certificate or rating will be issued with an appropriate limitation.
Also note the wording of the last sentence, in the next to last paragraph, of the Fitch legal interpretation linked above. This wording seems to state that an "amphibious" airplane can be both an ASEL and ASES.
However, both practical tests may be administered for ATP: ASEL and ASES using an amphibious airplane, as long as that airplane is certificated and maintained in accordance to regulation as an ASEL and ASES amphibious airplane.
(emphasis is mine)
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$\begingroup$ This answer assumes that a seaplane can magically become a non-seaplane if amphib floats are installed and can be operated by someone who does not have a rating to operate an aircraft certified as a seaplane. I highly doubt any FAA ramp inspector will let this pass. $\endgroup$ May 16 at 19:42
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$\begingroup$ If I followed your logic pilots would need to have ratings to land on snow or ice. A rating on a pilot certificate is for the class of aircraft. An amphibious aircraft is in the seaplane class, not the land class. There is no amphibious class. The type certificate that was issued for the aircraft will show if it is a seaplane or not. An STC may allow you to add amphibious or regular floats, and when they are installed that makes it a seaplane and requires a seaplane rating. If you think otherwise, it would be helpful if you could point to your evidence stating so. $\endgroup$ May 16 at 21:09
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1$\begingroup$ @JuanJimenez what is your reference that An amphibious aircraft is in the seaplane class, not the land class...? Just perusing various definitions of an amphibious airplane indicates that it's an airplane that can land and takeoff on both land and water. $\endgroup$– user22445May 16 at 21:52
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1$\begingroup$ From a certification basis, an amphibian must meet all requirements for a land plane and a seaplane. Properly operated and maintained, it exists as both an ASEL and ASES. If you operate from land, it is ASEL. If you operate from sea, it is ASES. I found the Fitch legal interpretation on the FAA web site. I also found in an FAA Order that to obtain a type rating in an amphib (that requires a TR) you have to demonstrate both land and sea ops or the TR will be "Restricted to Land" or "Restricted to Sea". $\endgroup$– GerryMay 16 at 22:51
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$\begingroup$ @Gerry Could you post the URL to the "Fitch legal interpretation"? $\endgroup$ May 17 at 17:29
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Amphibious aircraft are in the same class as seaplanes. There are no single-engine or multi-engine amphibious ratings, it's either land or sea, and if the aircraft can land in water you need the seaplane rating, regardless of whether it also has landing gear and you only ever operate from land. https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/seaplane_handbook/media/faa-h-8083-23-2.pdf
answered May 15 at 20:29
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6$\begingroup$ Do you have a citation for this? I've had difficulty finding any reliable information. In particular, I'm a bit skeptical that a pilot with only a seaplane rating is allowed to operate an amphibious plane if they are operating only from land. $\endgroup$– ChrisMay 15 at 21:29
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$\begingroup$ faa.gov/regulations_policies/handbooks_manuals/aviation/… You can verify for yourself there is no amphibious rating or endorsement. If you have a seaplane rating and want to fly an amphibious aircraft you only need a proficiency check regardless if you want to fly from water or land. $\endgroup$ May 16 at 19:35
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1$\begingroup$ I'm aware that there is no amphibious rating. That doesn't necessarily imply that a seaplane rating is adequate for operating from land. The handbook you linked mentions amphibious aircraft only briefly and doesn't say anything one way or the other about regulations regarding them. $\endgroup$– ChrisMay 16 at 22:50
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1$\begingroup$ On the other answer you say "This answer assumes that a seaplane can magically become a non-seaplane if amphib floats are installed and can be operated by someone who does not have a rating to operate an aircraft certified as a seaplane. I highly doubt any FAA ramp inspector will let this pass." But by your logic you could make a landplane a non-landplane just by slapping some amphibious floats on it and it can be operated by someone who does not have the rating to operate a landplane. How is that any different? $\endgroup$– ChrisMay 16 at 22:55
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$\begingroup$ @Chris Without an STC, what you would be producing would be an experimental aircraft, and flying it without the experimental a/w certificate would be illegal. You can't just "slap" things like that on type certified aircraft. $\endgroup$ May 17 at 17:28