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Old 09-23-2023, 12:14 PM
  #1  
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Default Question regarding complex/taa for CMEL/CSEL

Hey gents,

Got PPL/IFR in 2007/08. I started my CSEL/CMEL under a part 141 training back in 2009. I got about 20-30 hours in a SR20 and about 16 hours in a PA44.

I got my complex endorsement. TAA wasn't a thing back then that I can I remember.

I'm looking to get my CSEL/CMEL now and (besides trying to refresh everything I forgot since I last flew in 2014) I'm trying to understand the minimum requirements for CSEL/CMEL.

I read a few articles, but I can't apply it to my situation.

does my SR20 glass cockpit I did for CSEL training back in 2009 apply towards the hours required towards TAA/Complex?

Does my complex endorsement from PA44 apply towards CSEL as well?

Granted when I go finish CSEL/CMEL and get refresher training, I will probably "re-satisfy" these requirements, but I was just curious.

Lastly, is TAA an endorsement now? or do you just show that you were in a glass cockpit airplane.

Thanks!
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Old 09-23-2023, 01:06 PM
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14 CFR 61.1 defines a technically advanced airplane, and 61.129(j) provides specifics about what constitutes an "electronically advanced avionics system."

https://www.ecfr.gov/current/title-1...A/section-61.1
Technically advanced airplane (TAA) means an airplane equipped with an electronically advanced avionics system.
https://www.ecfr.gov/current/title-1...section-61.129
​​​​​​​(j) Technically advanced airplane. Unless otherwise authorized by the Administrator, a technically advanced airplane must be equipped with an electronically advanced avionics system that includes the following installed components:

(1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;

(2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving map using Global Positioning System (GPS) navigation with the aircraft position displayed;

(3) A two axis autopilot integrated with the navigation and heading guidance system; and

(4) The display elements described in paragraphs (j)(1) and (2) of this section must be continuously visible.
You'll need ten hours of training in an airplane meeting those definitions to meet the requirements of 14 CFR 61.129(a)(3)(ii), for the commercial pilot certificate, however, it doesn't all need to be in a "TAA." It can also be in a complex airplane or turbine airplane, or any combination of the three. Note that this need only be training, and does not require solo. Additionally, that training must specifically cover the items listed in 61.127(b)(1); If your former time in the Cirrus meets the requirements above (and below), then it should be applicable. The requirement to provide a complex airplane for the commercial practical test has gone away.

§ 61.129 Aeronautical experience.

(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

...

(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;
There is no requirement for a TAA endorsement, and there is no longer a requirement for a complex endorsement. Additionally, the definition of complex has changed from what it used to be, and you're no longer required to provide a complex airplane for the commercial practical test. You do still need an endorsement to fly a complex airplane (retractable gear, controllable pitch proppeller, and flaps), or a high performance airplane ( an engine of 200 or more horsepower).

The change for technically advanced aircraft was explained in the Federal Register
https://www.federalregister.gov/docu...ools-and-other
​​​​​​​

D. Completion of Commercial Pilot Training and Testing in Technically Advanced Airplanes

Prior to this final rule, a pilot seeking a commercial pilot certificate with an airplane single-engine class rating was required to complete 10 hours of training in either a complex or turbine-powered airplane.[51] In the NPRM, the FAA proposed to add a definition of technically advanced airplane (TAA) to § 61.1 and amend the training requirements to allow a pilot seeking a commercial pilot certificate with an airplane single-engine class rating to complete the 10 hours of training in a TAA instead of a complex or turbine-powered airplane. In addition to these regulatory changes, the FAA proposed to revise the practical test standards for commercial pilot applicants and flight instructor applicants seeking an airplane category single engine class rating to allow the use of a TAA on the practical tests.

The FAA received 35 comments on these proposed changes. Twenty-seven commenters generally supported the proposal. LOBO and 6 individuals did not support the proposal. One individual commenter did not opine, but asked for clarification regarding the definition of TAA. The following sections respond to these comments.

1. Definition of Technically Advanced Airplane

The FAA proposed to define “technically advanced airplane” in § 61.1 based on the common and essential components of advanced avionics systems equipped in an airplane, including a primary flight display (PFD), a multifunction flight display (MFD) and an integrated two axis autopilot. The FAA proposed that a TAA must include a PFD that is an electronic display integrating all of the following flight instruments together: An airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator. Additionally, the FAA proposed that an independent MFD must be installed that provides a GPS with moving map navigation system and an integrated two axis autopilot.[52] The proposed definition of TAA would have applied to permanently-installed equipment.

GAMA suggested the FAA work with industry in refining the definition of TAA to ensure that it is appropriately flexible to accommodate future technologies.

The FAA recognizes that the proposed definition would have been too prescriptive. As explained throughout this section, the FAA has revised the proposed language in response to industry's concerns to make it more flexible and accommodating of new technologies. Furthermore, the FAA recognizes that the definition of TAA would have inappropriately embedded requirements, which may have inhibited future technologies from falling under the definition of a TAA.[53] The FAA is therefore revising the definition of TAA in § 61.1 to contain a more general description of a TAA. TAA is now defined as an airplane equipped with an electronically advanced avionics system. The FAA is relocating the requirements regarding what a TAA must contain to § 61.129 by adding new paragraph (j). The FAA is also adding language to § 61.129(j) to allow the FAA to authorize the use of an airplane that may not otherwise meet the requirements of a TAA. This additional language is intended to provide flexibility by allowing the FAA to accommodate future technologies that do not necessarily meet the confines of the regulatory requirements for a TAA in § 61.129(j).[54]

AOPA stated that the terms “Primary Flight Display (PFD)” and “Multifunction Display (MFD),” which are not defined anywhere, will cause confusion. AOPA further noted that the same argument applies to removing “advanced” from “electronically advanced avionics system.” The addition of “advanced,” without any clarification, will generate questions over whether a particular system qualifies as advanced or not. AOPA commented that if a particular airplane is equipped with the items in proposed paragraphs (i) and (ii), then the airplane should be considered equipped as a TAA with the appropriate electronic avionics system.

The FAA is retaining the terms “Primary Flight Display,” “Multifunction Display,” and “advanced” in the TAA requirements. The FAA disagrees that the terms PFD and MFD will cause confusion. These terms are currently used and described in several FAA publications that are recognized by the aviation industry, including the Airplane Flying Handbook (FAA–H–8083–3B), the Pilot's Handbook of Aeronautical Knowledge (FAA–H–8083–25), the Aviation Instructors Handbook (FAA–H–8083–9A), the Instrument Flying Handbook (FAA–H–8083–15B), and the FAA/Industry Training Standards (FITS). The Pilot's Handbook of Aeronautical Knowledge defines a PFD and MFD in the glossary. PFD is defined as “a display that provides increased situational awareness to the pilot by replacing the traditional six instruments used for instrument flight with an easy-to-scan display that provides the horizon, airspeed, altitude, vertical speed, trend, trim, and rate of turn among other key relevant indications.” MFD is defined as a “small screen (CRT or LCD) in an aircraft that can be used to display information to the pilot in numerous configurable ways. Often an MFD will be used in concert with a primary flight display.”

The FAA believes the terms PFD and MFD add clarity to the TAA requirements by describing and prioritizing the display features and elements for TAA avionics and their respective functions. For example, the term PFD is specific to the use of the primary flight controls to maintain aircraft attitude and positive control. The PFD is used by the pilot to execute appropriate use of the control stick or yoke for pitch and bank, rudder pedals for yaw, and throttle for engine power. The PFD is designed specific to controlling the aircraft attitude and altitude relative to the horizon and the surface of the earth, especially when outside visibility is poor or unavailable. The MFD has a different priority; its function is secondary to the PFD. The MFD is designed for navigational use and position awareness information, even though it may include some PFD features for redundancy. Furthermore, the FAA is requiring certain minimum display elements for both a PFD and MFD, respectively, thereby clarifying what will be considered a PFD or MFD.

As for the term “advanced,” the FAA finds it necessary to describe the avionics system of a TAA as “advanced” to differentiate current new glass cockpit aircraft designs from older aircraft that used six independent mechanical dial/analog style flight instruments.

Twin City suggested the FAA clarify whether the MFD requirement may be satisfied by a split-screen display ( e.g.,Dynon Skyview) or two independent screens ( e.g., Garmin G500) contained within a single physical unit. Twin City also asked whether the moving map display of common GPS/WAAS navigators ( e.g., Garmin GTN650/750, Avidyne IFD 440/540) would meet the MFD requirement.

Section 61.129(j)(2) requires only the minimum elements of a MFD; it does not preclude the use of a split-screen display or two independent screens contained within a single physical unit. Therefore, a manufacturer may use a split-screen display or two independent screens for the PFD and MFD provided the displays contain the minimum elements required for each. Furthermore, in response to Twin City's comment, the FAA is clarifying the MFD requirements by first describing what the display shows ( i.e., a moving map) and then describing how the display is facilitated ( i.e., using GPS navigation). Accordingly, § 61.129(j)(2) now requires the MFD to include, at a minimum, a moving map using GPS navigation. The FAA believes this revision to the proposed language clarifies that a system with a moving map display common to GPS/WAAS navigators would satisfy the MFD requirement. Additionally, the FAA is requiring the aircraft position to be displayed on the moving map. The FAA finds this additional language adds clarity to the MFD requirement and ensures that existing equipment, such as the systems identified by Twin City, would satisfy the MFD requirement for a TAA.

Several commenters noted ambiguity with requiring the MFD to include an “integrated two axis autopilot.” Garmin noted that the G500 and G600 have autopilot mode control and annunciations capabilities for select autopilots on the PFD, not the MFD portion of the display. Therefore, the autopilot function itself is provided in a separate piece of equipment and not included in the MFD. Garmin also noted that equipment, such as Garmin's GTN650 and GTN750, could be considered an independent additional MFD that includes GPS with moving map navigation but the autopilot function and related mode control and annunciations are provided in separate pieces of equipment. Twin City suggested the FAA remove “integrated” from the description of the autopilot, allowing the use of independent/aftermarket autopilot systems.

In response to these comments, the FAA did not intend to exclude systems that provide autopilot functions separate from the MFD. The FAA is therefore separating the “two-axis autopilot” requirement from the MFD requirement. Accordingly, under new § 61.129(j)(3), the two axis autopilot is no longer required to be included as part of the MFD. This change from what was proposed allows the use of independent/aftermarket autopilot systems.

Twin City also asked the FAA to specify whether the integrated autopilot must include GPS roll steering (GPSS). Furthermore, Twin City asked whether the proposed two-axis requirement would have been satisfied by autopilots with altitude hold function only, or if vertical navigation (altitude preselect, glideslope tracking, etc.) is required.

In response to Twin City's comments, the TAA requirements of § 61.129(j) do not require the autopilot to have GPSS. However, § 61.129(j) specifies only the minimum requirements for a TAA. Therefore, an autopilot may have additional features, including GPSS. The “two axis” requirement refers to the lateral and longitudinal axes. The autopilot at a minimum must be able to track a predetermined GPS course or heading selection, and also be able to hold a selected altitude. The autopilot is not, however, required to control vertical navigation other than holding a selected altitude. The FAA is revising the proposed language for clarity and to accommodate future advancements in technology. Rather than requiring the MFD to have an integrated two axis autopilot, the FAA is requiring the TAA to have a two axis autopilot integrated with the navigation and heading guidance system. The FAA believes this revision from what was proposed clarifies the minimum requirements for the two axis autopilot and also allows for flexibility in autopilot design and installation.

AOPA, Garmin, and GAMA recommended that the FAA not require the MFD to be an “independent additional” piece of equipment because this requirement would preclude a single display that features the required information of both a PFD and a MFD from qualifying as a TAA.

The FAA agrees that the proposed definition of TAA would have been unintentionally restrictive and would have excluded some qualifying aircraft unnecessarily with its use of the phrase “independent additional.” The proposed requirement for an MFD to be an independent additional piece of equipment was intended to ensure that the minimum display elements are visible at all times. The FAA is not opposed to an aircraft having one display or piece of hardware that meets the overall definition requirements of § 61.129(j). The FAA is therefore removing the phrase “independent additional” from the proposed language to allow a single piece of equipment or single display to satisfy the requirement for both a PFD and MFD. However, to ensure that both displays are visible at the same time, the FAA is requiring the display elements for both the PFD and MFD (paragraphs (j)(1) and (2)) to be continuously visible.[55]

Garmin noted that the proposed phrase “(MFD) that includes, at a minimum, a Global Positioning System (GPS) with moving map navigation and an integrated two axis autopilot” is problematic. Garmin explained that the MFD portion of the G500 and G600 has a moving map that is driven by GPS but the GPS is a separate piece of equipment and not included in the MFD portion of the display.

In reference to the G500 and G600 equipment identified by Garmin, the FAA understands that the PFD and MFD can be driven or supported by other pieces of equipment to provide for its required functionality. Many of the display features for the PFD and MFD can be driven by separate pieces of equipment that are connected to the display. The TAA requirements in no way restrict the use of peripheral or supporting equipment that enables the display functionality described for the PFD and MFD in the TAA requirements. Therefore, the FAA finds that the G500 and G600 equipment identified by Garmin likely satisfies the requirements for an MFD.

Garmin also commented that the phrase “Global Positioning System (GPS) with moving map navigation” inappropriately mixes “GPS”, “moving map”, and “navigation” functionality. Garmin noted that FAA has separate TSOs for these functions, including for GPS sensors: TSO–C145 (GPS with SBAS), TSO–C161 (GPS with GBAS), and TSO–C196 (GPS only); for moving map: TSO–C165, and for navigation: TSO–C146 (standalone navigation equipment using GPS/SBAS sensor) and TSO–C115d (required navigation performance (RNP) equipment using multi-sensor inputs). Garmin added that it would be better to list these functions separately to allow for avionics architectures that provide these functions in different equipment that still supports the concept of a TAA.

In response to Garmin's concern with the use of the terms GPS, moving map, and navigation, the FAA is only describing the display functionality requirements of the PFD and MFD equipment. The FAA is not adopting any requirements for the underlying architecture or supporting equipment that would provide for the display functions or capabilities.[56] Therefore, while there may be different TSOs for the various functions of GPS, moving map, and navigation resulting in separate pieces of underlying equipment, this equipment can support the MFD requirements so long as the MFD includes a moving map that uses GPS navigation with the aircraft position displayed.

GAMA commented that the FAA should consider whether it is appropriate to evaluate designating certain rotorcraft as technically advanced for certain training and testing related initiatives in the future, noting several benefits.



The FAA appreciates GAMA's comments. However, the FAA finds it unnecessary to designate a rotorcraft as technically advanced at this time because there are no regulatory requirements to obtain training in a technically advanced rotorc
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Old 09-23-2023, 03:13 PM
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Adding to the information provided, some DPEs that I have been around (years ago) wanted to see a specific remark in the logbook by your CFI for that specific lesson about that training being for TAA (or complex) requirements. For example, "CPL training per 61.127 & 61.129a(3)(ii)". So, if this were the case, your previous flights would not satisfy the DPE's requirements (assuming it was not logged in this manner). As you start up your training again, your CFI should know the quirks of the local DPE's but if not, don't be shy in asking.
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Old 09-23-2023, 07:52 PM
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Correction to my previous comments; an endorsement is required for both complex and high performance airplanes. I did note that, but a sentence (which can't be edited now) states otherwise, it should have read that the endorsement is required.
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Old 09-24-2023, 10:50 AM
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Gotcha.

Thanks gents...

I do have 30+ hours in a TAA but I don't think it was required to be shown in 08. All of my CSEL/CMEL will be in a glass cockpit plane so I guess it's not a big deal anyways. Glass cockpit was very new back then. it seems to be the norm now.
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