Here are excerpts from previous postings on the topic of Ercoupe 
(without rudder pedals) restrictions on pilot certificates.

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This is what my local DPE has to say on this topic:

Answer: The commentor is correct. There is no regulation that
refers to two vs. three-axis controls.

There is also no regulation that specifies that an applicant taking
a practical test must do a "steep turn," and that the satisfactory
parameters are "plus or minus 100 feet, 45 degree bank, plus or
minus 10 knots," etc.

However, even though no regulation specifies what the parameters
are, the FAA says if you don't meet those parameters in the
Practical Test Standards (PTS), you don't get your pilot
certificate.

Likewise, the PTS says that the applicant must do "slips to a
landing."

The Ercoupe can't do slips.

Therefore, an applicant who takes a test in an Ercoupe cannot do all
the specified maneuvers that are required by the PTS, and the FAA
could say that NO test may be taken in the Ercoupe, period. In
fact, this was the FAA's position for a short period of time. Then
reason prevailed, and the FAA changed it's mind and said, "O.K., you
may take your practical test in an Ercoupe, but since you can't do
all the required PTS items, you are limited to flying only the
Ercoupe after completing the test."

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This what I got from Joe Norris from the EAA:

The issue with taking a practical test in an Ercoupe without rudder
pedals is not directly addressed in the regulations themselves. To
find the answer, one must look in the guidance that an FAA inspector
or Designated Pilot Examiner (DPE) would use when performing 
practical
tests and issuing pilot certifiates. This guidance is found in FAA
Order 8710.3E, Change 1, titled "Designated Pilot and Flight Engineer
Examiners' Handbook". In Chapter 5, Section 1, item number 7E,
titled "Aircraft Limitations", the following verbiage appears:


E. Aircraft Limitations. A limitation will be placed on an 
applicant's
pilot certificate if the applicant provides an aircraft that has
operating characteristics that preclude it from performing all the
tasks required during the practical test (per 14 CFR ยง 61.45(b)(2)).
However, this situation and the kind of aircraft to be used must be
specifically identified and approved by the FAA, General Aviation and
Commercial Division, AFS-800, at 800 Independence Avenue SW.,
Washington, DC 20591 (phone: (202) 267-8212) on a case-by-case basis.

(1) For the record, AFS-800 generally disapproves the use of such
aircraft, but it may grant approval on a case-by-case basis.

(2) For example, in the past, AFS-800 has approved the Ercoupe 415
series airplanes for use in a practical test. Persons seeking to use
an Ercoupe 415 series airplane for a practical test would receive the
limitation LIMITED TO ERCOUPE 415 SERIES WITHOUT RUDDER PEDALS.


As you can see from reading the above, the issue isn't specifically
the fact that the aircraft doesn't have rudder pedals. The issue is
that the aircraft cannot perform all the tasks required by the
practical test. The lack of rudder pedals specifically effects the
ability of the aircraft do perform forward slips, which is a required
task on the practical test. The aircraft also cannot perform the
required stalls. Thus, the pilot performs a practical test in the
Ercoupe without rudder pedals will be restricted to flying only
Ercoupes without rudder pedals until such time as he/she performs a
practical test in an aircraft that is capable of performing all the
required maneuvers.

Let me know if you have any further questions.

Joe Norris
EAA Aviation Services
888-322-4636, extension 6806
www.eaa.org

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Frank Nelson


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