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Unread 11-17-20, 04:16 PM
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I'm not saying this makes sense - it's a poorly written regulation - but it's clear. The "problem" is the FAR's definition of "pressurized aircraft" - it's any aircraft that can fly over 25,000 ft. So according to 61.31(g) a T337 is a pressurized aircraft, and a P337 is not. There are many recently developed aircraft that you and I would call pressurized that have maximum operating altitudes of 25,000 ft, even though the engine and airframe can go higher. 61.31(g) does not apply to them.

The regulations make much more sense if you replace the word "pressurized" with "high altitude" all through 61.31(g) - but they're written with the word "pressurized."

The FAR is pretty straightforward and clear in the way it defines "pressurized aircraft":

61.31(g)(1): "no person may act as pilot in command of a pressurized aircraft (an aircraft that has a service ceiling or maximum operating altitude, whichever is lower, above 25,000 feet MSL), unless that person has received and logged ground training from an authorized instructor and obtained an endorsement in the person's logbook"

A T337 has a service ceiling over 25,000 ft.
Therefore it is a "pressurized aircraft" according to the FARs. (Hey, I didn't say they made sense.)
Therefore all of 61.31(g) applies.
61.31(g) *never* talks about how high you are actually flying. It only talks about whether or not you're acting PIC.

BTW, the AC doesn't say that you can skip the training if you're operating below 25,000 ft. If the aircraft can go that high, you need the training.
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