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Сarriage of passenger in airplane without emer exit

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Old 25th Oct 2017, 15:00
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Сarriage of passenger in airplane without emer exit

Hello guys,

here is a question:

Сan I carry passengers in the aircraft (experimental) without an emergency exit under Part 61 FAA/EASA? Specify the specific article of the law please.
I am suspect what i am not allowed to do that, just need a clarification.

Thanks!
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Old 26th Oct 2017, 09:30
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You are in Russia, asking in a British dominated website, about how to comply with American regulations?

G
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Old 26th Oct 2017, 09:50
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Also, why would anyone design an aircraft without one?
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Old 26th Oct 2017, 09:51
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Under FAA Part 61 is about certificate and training requirements.
I’m not sure I understand your question.
A Pa28/C172/random general aviation aircraft doesn’t have “emergency exits” as in case of an emergency you use the “normal” doors.
Are you talking about carrying passengers for hire?
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Old 26th Oct 2017, 10:56
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Originally Posted by Genghis the Engineer
You are in Russia, asking in a British dominated website, about how to comply with American regulations?

G
My citizenship out of topic. I am FAA CPL holder flying on N-reg aircrafts.


Also, why would anyone design an aircraft without one?
You better ask manufactured about it

A Pa28/C172/random general aviation aircraft doesn’t have “emergency exits” as in case of an emergency you use the “normal” doors.
Are you talking about carrying passengers for hire?
It is Epic LT.
But what if a main door will blocked or stuck? It is happened already.
Yes, for hire.
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Old 26th Oct 2017, 13:18
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Im suspecting that this will not be for a Part 135 but rather for a Part 91K operator? Or rather flying under Part 91 with the owner and their invited guests?
In which case the strictor of the two sets of regulations apply, the Russian or the FAA.

Quick search came up with this but I'm not sure it applies: FAR 23.807

If Russian regulations are somewhat similar to EASA I would suspect you CAN NOT use a kit built experimental for Commercial operations regardless of emergency exits.
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Old 26th Oct 2017, 14:14
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Originally Posted by B2N2
Im suspecting that this will not be for a Part 135 but rather for a Part 91K operator? Or rather flying under Part 91 with the owner and their invited guests?
In which case the strictor of the two sets of regulations apply, the Russian or the FAA.

Quick search came up with this but I'm not sure it applies: FAR 23.807

If Russian regulations are somewhat similar to EASA I would suspect you CAN NOT use a kit built experimental for Commercial operations regardless of emergency exits.
Forget about Russia please. Aircraft N reg. flying 95% in Europe.
I am mentioned in first post what i am interesting about FAA/EASA regulation in this certain case.
And you are right-flying with the owner and their guests.
I am found in FAR about emer exists, but nothing regards experimental aircrafts.
Thats why i am ask for help to figure out.
Thanks!
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Old 26th Oct 2017, 14:22
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And take it into account: that is NOT commercial flights. Private flights only. I got SAFA ramp inspection already and everything was good, but i discover what is emer exit (window) is fake exit. I am not going to fly this airplane with no emer exit anymore for sure, because it is simply out of my flying culture and respect to law, but i have to arguments to prove it to the owner.
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Old 26th Oct 2017, 14:50
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Why does your plane need a dedicated 'emergency exit'? Most small planes don't - they just have the standard doors used every time.

On the basis that it's not something done by Mr.Cessna - I don't believe it's something needed by Mr.Epic.
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Old 26th Oct 2017, 15:53
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Grief. Let me get this right.

A Russian, in an American Experimental aeroplane, flying around Europe, on an FAA licence.

Because that aeroplane is sub-ICAO and from outside the ECAC area, that is subject to individual overflight permissions for each country being overflown, and because it's experimental there is no standardised build standard under which EASA can ramp check it.

What a bag of worms! I'm just glad it's not mine to solve. Looks like a fun aeroplane however - although you can't help wonder about the deeper reasons why it was never certified by the FAA.

G
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Old 26th Oct 2017, 16:44
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Emergency exits are only required in Transport Category airplanes (Part 21, part 25). Here's what the FAA says for light aircraft:
Make sure that your passengers know how to open the door(s) in the event of an emergency evacuation.
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Old 26th Oct 2017, 16:54
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Originally Posted by Genghis the Engineer
Grief. Let me get this right.

A Russian, in an American Experimental aeroplane, flying around Europe, on an FAA licence.

Because that aeroplane is sub-ICAO and from outside the ECAC area, that is subject to individual overflight permissions for each country being overflown, and because it's experimental there is no standardised build standard under which EASA can ramp check it.

What a bag of worms! I'm just glad it's not mine to solve. Looks like a fun aeroplane however - although you can't help wonder about the deeper reasons why it was never certified by the FAA.

G
It seems that you have some special attitude to Russian, but I won't discuss nationalist attacks. No one wondering about British or Indian guys flying on american airplanes. Or here is a difference? Strange.

And you are right-it is individual overflight permissions for each country being overflown, and because it's experimental, but it does not mean what ramp inspection can avoid for this reason.

It is not my problem as well-i am just freelancer on that airplane. Usually i am flying Piaggio Avanti 2, and you will be probably disappointed: Russian, with FAA licence flying in Europe on P180 N-reg. Sorry about it.

By the way-Epic E1000 is certified by FAA.

So, are you able to give certain answer on my question? If you not, would you be so kind and stop off-topic please? Thank you!
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Old 26th Oct 2017, 17:01
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Originally Posted by MarcK
Emergency exits are only required in Transport Category airplanes (Part 21, part 25). Here's what the FAA says for light aircraft:
Thank you very much!
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Old 26th Oct 2017, 17:48
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Light aircraft emergency exits? Cessna has two doors. Piper aircraft usually only one!
Good reason to prefer the Cessna....
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Old 26th Oct 2017, 18:42
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Originally Posted by mary meagher
Light aircraft emergency exits? Cessna has two doors. Piper aircraft usually only one!
Good reason to prefer the Cessna....
In many Pipers the window opposite to the single door doubles as emergency exit. It can be removed by pulling a handle which removes the rubber seal that holds it in it's frame.
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Old 26th Oct 2017, 19:48
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Are you SURE you can fly an N-reg experimental around Europe?
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Old 26th Oct 2017, 20:23
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Originally Posted by Thud105
Are you SURE you can fly an N-reg experimental around Europe?
My understanding, having done a bit of sub-ICAO ferrying is that you need individual overflight permits for each sector pretty much.

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Old 26th Oct 2017, 20:24
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Are you talking about carrying passengers for hire?
It is Epic LT.
...
Yes, for hire.
I think you will run afoul of:
§ 91.319 Aircraft having experimental certificates: Operating limitations.
(a) No person may operate an aircraft that has an experimental certificate -

(1) For other than the purpose for which the certificate was issued; or

(2) Carrying persons or property for compensation or hire.

Last edited by MarcK; 26th Oct 2017 at 20:28. Reason: additional info re: for hire
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Old 26th Oct 2017, 20:29
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I don't think that European regulations normally permit "for hire" in sub-ICAO aeroplanes either, certainly not internationally.

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Old 26th Oct 2017, 22:31
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Mr. Cessna, and Mr. Piper (among other certified airplane builders) built aircraft at the time which conformed to:

Sec. 23.807

Emergency exits.

(a) Number and location. Emergency exits must be located to allow escape without crowding in any probable crash attitude. The airplane must have at least the following emergency exits:
(1) For an airplane with a seating capacity of more than five occupants, but less than 16, at least one emergency exit on the opposite side of the cabin from the main door specified in Sec. 23.783.
(2) For an airplane with a seating capacity of more than 15 occupants, the emergency exit specified in subparagraph (1) of this paragraph, and an emergency exit in the top or side of the cabin for each seven occupants, or fraction thereof, above 15. However, no more than four exits are required if their arrangement and size allow quick evacuation of each occupant.
(3) If the pilot compartment is separated from the cabin by a door that is likely to block the pilot's escape in a minor crash, there must be an exit in the pilot's compartment. The number of exits required by subparagraphs (1) and (2) of this paragraph must then be separately determined for the passenger compartment, using the seating capacity of that compartment.
(b) Type and operation. Emergency exits must be movable windows, panels, or external doors, that provide a clear and unobstructed opening large enough to admit a 19-by-26-inch ellipse. In addition, each emergency exit must--
(1) Be readily accessible, requiring no exceptional agility to be used in emergencies;
(2) Have a method of opening that is simple and obvious;
(3) Be arranged and marked for easy location and operation, even in darkness;
(4) Have reasonable provisions against jamming by fuselage deformation; and
(5) In the case of acrobatic category airplanes, allow each occupant to bail out quickly with parachutes at any speed between and VD.
(c) Tests. The proper functioning of each emergency exit must be shown by tests.
Note that the current version of this standard is much more demanding.

So, yes, emergency exits are required for all certified aircraft, rather than just transport category. I don't know the Epic, though if it is not a certified design, it has not demonstrated compliance to the design requirements, so its required characteristics are generally those accepted by the purchaser, who best inform themselves.

The C206 is an example of a "challenged" design WRT exits: The P206 was ok, two front doors like a 182, and a third left side exit at the back, which met the requirements. Once the U206 was introduced, the absence of the right front exit became a problem, as the aft clamshell doors were imperfect as emergency exits, if their use was required with the flaps extended. Workarounds were developed over the years. In Canada, the U206H (certified to a newer standard) was limited to being a five place aircraft, as compliance could not be demonstrated as a six place, again, clamshell door operation. Again, there may be workarounds, but this was a hot topic at the Canadian introduction of the U206H.

§ 91.319 Aircraft having experimental certificates: Operating limitations.
(a) No person may operate an aircraft that has an experimental certificate -

(1) For other than the purpose for which the certificate was issued; or

(2) Carrying persons or property for compensation or hire.
Is because the "Part 91" side of the FAA knows that non certified aircraft have not followed the "Part 23/2/27/29" certification route, and their characteristics are unproven.

Even the FAA recognizes that the full Part 23 certification path is very burdensome, and are working to streamline it for some aircraft. But the notion that an "experimental" aircraft can replace a certified one operationally is a stretch.
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