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  #11  
Old 03-30-2018, 02:36 PM
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DonFromTX DonFromTX is offline
 
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Most interesting, is it a "LODA" you have? Why would this restriction be given to you, any idea of a reason? This seems to be all kinds of silly stuff.

Quote:
Originally Posted by BobTurner View Post
The answer is a flat-out ‘no’ - unless you have access to an RV and an instructor who are truely free, no gas, no strings attached.
I have the waiver from the FAA to give transition training for hire in my RV. But the paperwork says I may not sign off a flight review under this waiver, even if during the course of the transition training we satisfy the flight review requirements! So I think the FAA is serious about this.
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  #12  
Old 03-30-2018, 03:32 PM
BobTurner BobTurner is offline
 
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To answer the above questions:
Yes, the FAA calls the waiver a “LODA” - ‘Letter of Deviation Authority”.
The FAA’s (or at least, the OAK FSDO) stand seems to be no for-hire use is allowed unless there is no way except in an EAB. My LODA specifically forbids me from signing off a high performance endorsement or a Flight Review, even if these things were accomplished incidental to the transition training. It also forbids ‘introductory rides’. It says the pilot must reasonably expect to complete an RV-10, or purchase an already built one, within 6 months. (I’m sure ‘reasonably’ is up for arguement, just as ‘Is buying gas compensation?’).

I wish it were otherwise. I am currently not doing transition training, since the cost of the extra insurance exceeds what I made. If I were able to give introductory rides, or Flight Reviews, there might be enough interest to justify the cost.
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  #13  
Old 03-30-2018, 10:46 PM
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No doubt in my mind if an instructor is giving transition training, he would also log the Biennial flight review in your logbook. It's just a matter of request.
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  #14  
Old 03-30-2018, 10:53 PM
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Quote:
Originally Posted by Infidel View Post
No doubt in my mind if an instructor is giving transition training, he would also log the Biennial flight review in your logbook. It's just a matter of request.
From my limited researched knowledge, it appears that CFI and LODA people are doing lots of unauthorized stuff with flight reviews, apparently this is just another of those examples. It is hard to understand how the LODA could supersede other FAA instructions.
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  #15  
Old 03-30-2018, 11:29 PM
rvbuilder2002 rvbuilder2002 is offline
 
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Quote:
Originally Posted by DonFromTX View Post
From my limited researched knowledge, it appears that CFI and LODA people are doing lots of unauthorized stuff with flight reviews, apparently this is just another of those examples. It is hard to understand how the LODA could supersede other FAA instructions.
It requires an understanding of what a LODA is.
LODA - Letter Of Deviating Autority

It is a written document (letter) from the FAA, authorizing someone to deviate from some portion or specific detail of the FAR's.
In this case, the FAA got behind the idea that if type specific transition training were done, that it would improve safety. The FAA new that they couldn't expect a lot of CFI's to provide their aircraft for free so they needed to have a way around the "no compensation or hire" usage of E-AB aircraft, but instead of totally rewriting the FAR's, they chose to use the LODA process and issue them on a case by case basis.
Since the only reason it was being allowed, was so that people could safely transition into the model aircraft the LODA is issued to, it typically specifies that it is for transition training only. No primary flight training is allowed, and often times it even mentions other training type operations.

BTW, Mike Seager does transition training in aircraft that are Experimental / Market Survey which specifically allows customer training. Because of this there is no LODA, so no exclusions on signing off BFR's, HP endoresments, or tail wheel endorsements (though I think he prefers people to be tail wheel qualified before they come to fly with him).
There is still the limitation of no primary training.
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  #16  
Old 03-31-2018, 05:28 AM
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rmartingt rmartingt is offline
 
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I remember talking about this to an FAA flight standards guy at Oshkosh a few years ago, and he agreed that it seemed silly to him not to allow someone to get endorsements as part of their transition training.

Later, I saw this news release: https://www.eaa.org/en/eaa/eaa-news-...public-comment

I have not been able to find the actual proposed regulation yet; there was another proposed rule from May 2016 dealing with training requirements but it has apparently not yet progressed to "final rule" status.

Anyway, the FAA is at least apparently looking at this. How long it will take them to progress to a change is anyone's guess. The Part 23 changes took years...
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  #17  
Old 03-31-2018, 09:29 AM
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So can we then assume that NO CFI with a LODA can do a "legal" flight review (by him in that plane)?

Quote:
Originally Posted by rvbuilder2002 View Post
It requires an understanding of what a LODA is.
LODA - Letter Of Deviating Autority

It is a written document (letter) from the FAA, authorizing someone to deviate from some portion or specific detail of the FAR's.
In this case, the FAA got behind the idea that if type specific transition training were done, that it would improve safety. The FAA new that they couldn't expect a lot of CFI's to provide their aircraft for free so they needed to have a way around the "no compensation or hire" usage of E-AB aircraft, but instead of totally rewriting the FAR's, they chose to use the LODA process and issue them on a case by case basis.
Since the only reason it was being allowed, was so that people could safely transition into the model aircraft the LODA is issued to, it typically specifies that it is for transition training only. No primary flight training is allowed, and often times it even mentions other training type operations.

BTW, Mike Seager does transition training in aircraft that are Experimental / Market Survey which specifically allows customer training. Because of this there is no LODA, so no exclusions on signing off BFR's, HP endoresments, or tail wheel endorsements (though I think he prefers people to be tail wheel qualified before they come to fly with him).
There is still the limitation of no primary training.
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  #18  
Old 03-31-2018, 10:50 AM
rvbuilder2002 rvbuilder2002 is offline
 
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Quote:
Originally Posted by DonFromTX View Post
So can we then assume that NO CFI with a LODA can do a "legal" flight review (by him in that plane)?
No

It all depends on what the LODA letter they have says.
Each is issued by a different office. Some may not have the limitations that were intended.
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  #19  
Old 03-31-2018, 07:49 PM
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DonFromTX DonFromTX is offline
 
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Is a LODA public information available to anyone? How can we find out if a person/plane has a LODA or not and therefore what restrictions might apply to him?
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  #20  
Old 03-31-2018, 08:05 PM
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RV8JD RV8JD is offline
 
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Quote:
Originally Posted by DonFromTX View Post
Is a LODA public information available to anyone? How can we find out if a person/plane has a LODA or not and therefore what restrictions might apply to him?
Here is one list of holders of Letters of Deviation Authority (LODA), with email addresses and phone numbers:

https://www.eaa.org/en/eaa/aviation-...s-loda-holders
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