Modest Proposal -- Delete 14CFR61.51(e)(3)

[Ed Guthrie]

In another thread, Arnold suggested that the only means to increased flight safety is via regulatory means. In part I agree, and I think there is a quick, simple, single pen stroke fix to a large part of the problem. I believe we should lobby to delete 14CFR61.51(e)(3). In a single stroke of the regulatory pen all time building CFIs would disappear from the flight training world. The low time pilot/CFI looking to build time as his/her ticket to the majors would be forced to find another venue. The only folks providing flight instruction would be those who wanted to flight instruct.

After 61.51(e)(3) disappeared, the CFI population would rapidly diminish. Supply and demand would force a strong increase in CFI pay. Experienced pilots/CFIs who wished to teach for the sake of teaching would pull a decent salary and could afford to stay in the industry. The flight training system for the first time in history would economically incentive good teacher/pilots to remain within the CFI profession. IOW, Arnold would resume flight instructing. Furthermore, with salaries high, flight schools would have the economic tools necessary to shop for good CFIs instead of being forced to accept available CFIs. IOW, flight schools would engage in a bidding war for Arnold's flight instruction services.

As average CFI experience level increased, GA flight safety would increase, too.

And the world would be as it should.

The only downside I see to this proposal is that flight training costs would necessarily increase. But in reality the increase would be relatively modest. Assume CFI take home pay increases from $20/hour to $50/hour. At the minimum hours required by FAR, a private certificate would cost $600 more, an instrument rating would cost $450 more, and a PVT helicopter add-on to a PVT-ASEL certificate would cost $570 more. In a world where it seems as if every pilot is toting around a $1000 handheld GPS the increased discretionary cost is obviously within means of most pilots.

I suggest we all immediately request that the AOPA and EAA lobby the FAA on our behalf asking that 14CFR61.51(e)(3) be removed immediately as it is an obvious impedance to flight safety.

Much as I post this with tongue somewhat in cheek, I do think 61.51(e)(3) is part of the overall problem.

 

[poadeleted3]

Sounds to me like you are more motivated by economic snobbery, trying to force out of business those who cannot simply buy their way into a cockpit.

 

[Henning]

Sounds to me like you are more motivated by economic snobbery, trying to force out of business those who cannot simply buy their way into a cockpit.

I'm guessing you're refering to the time builders heading to the airlines, and I'm not sure that your assumption is necessarily correct. Not every nation/airline works the way we do in the US. Lufthansa is an example. I think they still run a cadet program which the Airline pays for. They start in at very low and sometimes no hours. You apply and you take some tests. If you are at the top of the test group, they train you (used to be in AZ) up and get you time, all the while you have to do well at your training or wash out. That way, by the time you get the pilots on the line, they have hundreds of hours of real flight training to company spec, and you have weeded out those who don't cut it, and the people who belong in the cockpit end up there and get paid for their time training. As long as people are out there willing to pay for their company training though, it won't happen.

 

[Brian Austin]

Lufthansa is an example. I think they still run a cadet program which the Airline pays for. They start in at very low and sometimes no hours. You apply and you take some tests. If you are at the top of the test group, they train you (used to be in AZ) up and get you time, all the while you have to do well at your training or wash out.

Last I saw when I was there, it's still located at Goodyear (KGYR), just outside of Phoenix. They have a bunch of primary and advanced trainers there.

 

[fgcason]

Sounds to me like you are more motivated by economic snobbery, trying to force out of business those who cannot simply buy their way into a cockpit.

I don't know about that. It makes it rougher if you're trying to buy your way into a larger cockpit but not necessarily a smaller one. His idea is suggesting moving the power struggle away from airlines to GA.

If you want to fly for a living and willing to teach, for $1000+- more his idea suddenly potentially made flight instruction a respectable occupation instead of a lowly stepping stone for disinterested instructors. Get your CFI at 250 hrs give or take and can teach 1 on 1 you're where you can live off the income nearly right now. It's either that or rack up 1000+ hours however you can along with forking out for specialty advanced ratings over the next few years to hopefully be minimally qualified to show up at an interview for a job that you may or may not get.

I bet the "I've got 35 hours and my instructor just took a $15K/yr commuter job what do I do now" frustration comments would drop to near zero.

If you market yourself to keep busy, $50/hr you could quit hurting financially real quick. I don't make anywhere near that much per hour. How about you?

Not sure if the idea would work in the long run but it sort of has potential...

 

[poadeleted3]

snip
If you market yourself to keep busy, $50/hr you could quit hurting financially real quick. I don't make anywhere near that much per hour. How about you?

Not sure if the idea would work in the long run but it sort of has potential...

No, I don't make that much, and I would not pay an instructor that much. Neither would lots of other people. Frankly, the job isn't worth that much, and it takes a heck of a self involved ego to think it is.

 

[Brian Austin]

If you market yourself to keep busy, $50/hr you could quit hurting financially real quick. I don't make anywhere near that much per hour. How about you?

A $50/hr CFI that's doing it on contract work has to have his/her own insurance and pay taxes as a self-employed contractor, most likely. You're not walking away a rich man in that hourly rate. Take home would probably be in the $18-25/hr area. And keep in mind that it's FLYING hours you're generally billing out at (with a little pre- and post-flight stuff). You're not flying 40 hours a week as a CFI in most markets...although supply/demand would change considerably if the existing model went away.

 

[poadeleted3]

A $50/hr CFI that's doing it on contract work has to have his/her own insurance and pay taxes as a self-employed contractor, most likely. You're not walking away a rich man in that hourly rate. Take home would probably be in the $18-25/hr area. And keep in mind that it's FLYING hours you're generally billing out at (with a little pre- and post-flight stuff). You're not flying 40 hours a week as a CFI in most markets...although supply/demand would change considerably if the existing model went away.

A $50 hr CFI, once you added the FBO's costs onto it, would run $75 hr. That's more than I spent for a plane, and is a simply ridiculous sum. Frankly, the $20 an hr I paid is what the job is worth, and is still more than I earn. It's ridiculous in the extreme to think the job is worth $50 hr or more.

 

[Brian Austin]

A $50 hr CFI, once you added the FBO's costs onto it, would run $75 hr. That's more than I spent for a plane, and is a simply ridiculous sum. Frankly, the $20 an hr I paid is what the job is worth, and is still more than I earn. It's ridiculous in the extreme to think the job is worth $50 hr or more.

I wasn't even considering a FBO's involvement in the transaction. Depending on how the FBO employs the CFI (contract, perm, temp, 1099, W-2) changes the payscale for both the customer and CFI.

If the CFI you hired is a direct contract, he/she is actually walking away with about $10-12/hr if all the taxes and insurance is being taken care correctly. Personally, I would find more profitable things to do if that was the payscale I could expect.

 

[Henning]

No, I don't make that much, and I would not pay an instructor that much. Neither would lots of other people. Frankly, the job isn't worth that much, and it takes a heck of a self involved ego to think it is.

Heck, I don't do mechanic work that cheap. Why do minimalize your value?

 

[gismo]

A $50 hr CFI, once you added the FBO's costs onto it, would run $75 hr. That's more than I spent for a plane, and is a simply ridiculous sum. Frankly, the $20 an hr I paid is what the job is worth, and is still more than I earn. It's ridiculous in the extreme to think the job is worth $50 hr or more.

Joe, market (supply vs demand) is what sets the pay scale, not CFI egos. I do think that Ed is correct in that without the logbook filling part of instructing there would be a lot fewer CFI's, but there's a good chance the demand for $50/hr (75 including FBO cuts) would be significantly less than the current student start rate. And that could easily cap the market cost at something very little higher than the current rates.

 

[poadeleted3]

Joe, market (supply vs demand) is what sets the pay scale, not CFI egos. I do think that Ed is correct in that without the logbook filling part of instructing there would be a lot fewer CFI's, but there's a good chance the demand for $50/hr (75 including FBO cuts) would be significantly less than the current student start rate. And that could easily cap the market cost at something very little higher than the current rates.

I agree. I paid $20 hr for the instructor, plus another $15 to the FBO. I don't think there are a lot of people willing to pay a whole bunch more than that for basic instruction.

 

[Arnold]

In another thread, Arnold suggested that the only means to increased flight safety is via regulatory means. In part I agree, and I think there is a quick, simple, single pen stroke fix to a large part of the problem. I believe we should lobby to delete 14CFR61.51(e)(3). In a single stroke of the regulatory pen all time building CFIs would disappear from the flight training world. The low time pilot/CFI looking to build time as his/her ticket to the majors would be forced to find another venue. The only folks providing flight instruction would be those who wanted to flight instruct..

I was thinking making the minimum requirements to instruct more closely resemble PIC IFR part 135. But your solution has a certain elegance to it.

 

[woodstock]

I'm paying 45 an hour for my CFI, not sure how much actually goes to him though - he's with the school obviously. he's doing it b/c he loves to do it though, he's a captain at an airline so he isn't going anywhere.

 

[Henning]

I'm paying 45 an hour for my CFI, not sure how much actually goes to him though - he's with the school obviously. he's doing it b/c he loves to do it though, he's a captain at an airline so he isn't going anywhere.

How the heck does he get to pull off being a Capt and CFI? Is he on furlow?

 

[woodstock]

How the heck does he get to pull off being a Capt and CFI? Is he on furlow?

nope - he only has a few students and is actually based where he lives - here. he gets a few days off a week and that is when we fly.

 

[Ed Guthrie]

nope - he only has a few students and is actually based where he lives - here. he gets a few days off a week and that is when we fly.

Henning was referring to the fact that an airline pilot has a cap on the commercial flying hours s/he may accumulate each month. Usually they don't hit the cap, but the airlines try to maximize their money, which means they try to schedule each pilot so as to approach but just not quite exceed the monthly cap. Flight instruction would be commercial flying in addition to the airline flying hours, so, if the airline pushes the pilot's flying duty right up to the limit, flight instruction would quite possibly push the pilot's commercial flying time over the limit.

IOW, airlines do not take kindly to captains who call in on the 25th of the month and say, "Sorry, can't fly my routes any more this month. I did 12 hours of flight instruction earlier this month. Those 12 hours, plus the hours I've flown for the company so far this month put me at my flight time limit. I'll see you on the 1st."

 

[Henning]

nope - he only has a few students and is actually based where he lives - here. he gets a few days off a week and that is when we fly.

Yeah, that's all well and fine, but flight instruction is "Commercial Flying Time", and therefor adds to his cumulative weekly/monthly& annual maximum flying time. Airlines don't take kindly to someone timing out unless it's in their airplane, and some even have specific clauses in their contracts prohibiting outside commercial flying. Perhaps he is on a reduced schedule at the airline.

 

[Greg Bockelman]

Yeah, that's all well and fine, but flight instruction is "Commercial Flying Time", and therefor adds to his cumulative weekly/monthly& annual maximum flying time. Airlines don't take kindly to someone timing out unless it's in their airplane, and some even have specific clauses in their contracts prohibiting outside commercial flying. Perhaps he is on a reduced schedule at the airline.

Well, for what its worth, 121 regs cap at 1,000 hours a year, 100 hours a month, and something like 30 hours in 7 consecutive days. I very seldom get too close to those limits, and would generally not have any problems with a couple of three students.

As far as outside commercial operations, what the company is really looking for is flying that is more or less in direct competition with their operation. I have never had any problems with flight instructing with any of the companies I have worked for.

 

[kath]

I agree. I paid $20 hr for the instructor, plus another $15 to the FBO. I don't think there are a lot of people willing to pay a whole bunch more than that for basic instruction.

I pay $45 right now. I'd be willing to pay more for a quality instructor. This is someone who is going to carry my life in his or her hands for a while! Why pay so much for the aircraft and then skimp on the most important part of it?
--Kath

 

[woodstock]

Well, for what its worth, 121 regs cap at 1,000 hours a year, 100 hours a month, and something like 30 hours in 7 consecutive days. I very seldom get too close to those limits, and would generally not have any problems with a couple of three students.

As far as outside commercial operations, what the company is really looking for is flying that is more or less in direct competition with their operation. I have never had any problems with flight instructing with any of the companies I have worked for.

so far the most he and I have flown would be about 4 hours in one month. I don't know if Kaye is going up with him anymore, I think she got her next rating already?

 

[Greg Bockelman]

Ed,

I am confused. How would the elimination of 61.51(e)(3) create the benefits you propose? That part is all about the logging of PIC, right? I don't get it. As an instructor of primary students, the instructor would have to be the legal PIC because the student is not rated. So you would propose that the instructor could not log PIC in that case?

How would you propose the instructor log the time?

 

[poadeleted20]

In evaluating Ed's post, one might remember that the original "Modest Propsal" was that the Irish eat their own young. I suspect implementation of Ed's "modest proposal" would likely be about as feasible as implementation of Jonathan Swift's.

http://art-bin.com/art/omodest.html

From a non-satirical perspective, I still argue against the proposal. First, in nearly all situations, the instructor is in fact acting as the pilot in command in a training situation, and should be able to log the time as such just as an airline captain can log PIC time while in the head. Second, having instructed full time at a time when I had very little PIC experience, I can attest to the fact that there is nothing like instructing to build your skills -- even better than flying yourself, as you have a broader perspective and are more sensitive to all the factors involved. Frankly, talking someone through something is much harder than doing it yourself, and really builds your fundamental skills. There is no question in my mind that instructing builds skills, experience, and command ability in a multi-pilot environment much better than boring holes in the sky by yourself.

For those reasons (and not those related to satirical arguments), I respectfully disagree with Ed. If I were to make any changes to improve the quality of instructors in our world, it would be to put aeronautical experience requirements above those of just a Commercial Pilot certificate in 14 CFR 61.183 (maybe 500 hours PIC time or 1000 hours total time), not to change 14 CFR 61.51(e)(3).

 

[Greg Bockelman]

Thank you, Ron. Put much better than I could do. I agree 100%.

 

[Ed Guthrie]

Ed,

I am confused. How would the elimination of 61.51(e)(3) create the benefits you propose? That part is all about the logging of PIC, right? I don't get it. As an instructor of primary students, the instructor would have to be the legal PIC because the student is not rated. So you would propose that the instructor could not log PIC in that case?

IMO, as a result of the time logging opportunity the flight training aspect of this industry is pushed out of kilter, so to speak. I suggest that it is the contrary motivational force (accumulating flight time versus teaching excellence) that creates issues within aspects of flight training quality and ultimately flight safety. IOW, accumulating flight time is not an incentive/metric associated with quality teaching, so why allow it to become a motivational force within the flight training process?

Regarding logging flight time, with the exception of multiple pilot crews, acting as PIC does not confer logging PIC. Furthermore, the FAA has held that flight instruction is not a pilot flight crew activity, it is a teaching activity (see the FAA position regarding CFIs and medicals). I merely suggest aligning flight time logging with the FAA position regarding CFIs and medicals. I would propose that a CFI be allowed to log only that time allowed under the other sub-clauses of 61.51(e), i.e. that time the CFI manipulates the controls.

How would you propose the instructor log the time?

With respect to flight time, I don't propose the instructor log it at all. I suggest CFIs be allowed to log something such as "flight instruction given", but only as a means to maintain a continuous record (student & CFI).

 

[Ed Guthrie]

For those reasons (and not those related to satirical arguments), I respectfully disagree with Ed. If I were to make any changes to improve the quality of instructors in our world, it would be to put aeronautical experience requirements above those of just a Commercial Pilot certificate in 14 CFR 61.183 (maybe 500 hours PIC time or 1000 hours total time), not to change 14 CFR 61.51(e)(3).

I respect the conundrums Ron notes, for exactly the reasons Ron suggests. I think what Ron proposes could accomplish the appropriate goal, provided it effectively removed the "passing through" incentive 61.51(e)(3) creates. IOW, the flight experience threshold for a CFI certificate would need to be set at or above the minimum hiring level of the commuters.

 

[Len Lanetti]

How the heck does he get to pull off being a Capt and CFI? Is he on furlow?

Henning,

If he is a sharp bidder with some seniority he can have weekends off. But you know that.

Len

 

[Len Lanetti]

Yeah, that's all well and fine, but flight instruction is "Commercial Flying Time",

Is it? Don't need a 2nd class medical to do it.

Len

 

[poadeleted20]

Quote:
Originally Posted by Henning
Yeah, that's all well and fine, but flight instruction is "Commercial Flying Time",

Is it? Don't need a 2nd class medical to do it.

Like the breath mint, you're both right. For some commercial flying duty time purposes, paid flight instruction is considered "commercial flying time." For medical certification purposes, flight instruction is not an activity requiring a medical certificate; only the pilot responsibilities associated with instructing (e.g., acting as PIC with a non-rated pilot or acting as a safety pilot for a hooded pilot) require the medical certificate.

 

[CFIse]

I'm missing something. Why do you think CFI's are trying to build PIC time?

All the "time builders" are trying to do is meet the Part 135 IFR requirements to act as PIC - there's no mention of a PIC time requirement, it's all just pilot time.

So people with a Commercial and a CFI are still going to be building time to 1200 hours - just not logging it as PIC.

So leaving aside other issues - it's not going to achieve the effect you seem to want.

 

[poadeleted20]

I'm missing something. Why do you think CFI's are trying to build PIC time?

Because, while 135.243 specifies no minimum PIC time, many if not most 135 (and 121 and corporate) operators (or their insurers) do.

 

[jdwatson]

Obviously, hours logged can't be the be all end all qualification. If it were, I could fly 300 hrs/year between the same two airports just to build the time. I've been trying vary my destinations just to get the experience of different ATC organization, different local procedures & customs, and there's nothing like visiting a new place.

Just to keep things alive, I'm trying to visit each public, paved airport in my home state of NC. I get three ARTCCs, all classes of airspace, mountains (sort of), ocean, winds and our friends in the Military. We have 110 public airports, many of them paved. I think the ones inside the KCLT airspace will be a challenge.

 

[CFIse]

Because, while 135.243 specifies no minimum PIC time, many if not most 135 (and 121 and corporate) operators (or their insurers) do.

Yeeeees, but they still want the same people, with the same experience, so they'll just drop the PIC requirement and perhaps replace it by a "dual given". They're not idiots.

The only reason to stop CFI's logging PIC is so that they can't qualify for things under the regulations. Everybody else will just change their requirements.

If they'll take somebody with 1200 hours and 900 dual given also logged as PIC they'll happily take somebody with all the same time and experience but not logged as PIC.

No - Ed's got to come up with a different plan if he wants to make $100/hr as an instructor, because this one ain't going to cut it.

 

[Dave Krall CFII]

Hours logged are only a fractional part of any pilot's true worth and ultimate useful PIC qualifications as has been stated repeatedly by so many pilots with experience here and elsewhere.

Aviation always has been and should by natural selection remain only a broadminded, thinking person's game.

If a candidate for any level of aviation activety can't figure out how to find the # of $ signs neccessary to get where they want to be in terms of PIC in a certain aircraft, it's more highly probable they will also be unable to both ascertain how the curves in the $ signs generate lift nor how to safely control that lift on a consistant basis.

No change in Regs will permanently change that reality, nor where, nor how, a good PIC logged their flight training, and much less how they paid for it.

 

[jdwatson]

Whoa, this almost sounds like common sense. There's nothing like that in my industry. Common sense got sold with all the dot.coms and shredded by Eron.

 

[Ed Guthrie]

Yeeeees, but they still want the same people, with the same experience, so they'll just drop the PIC requirement and perhaps replace it by a "dual given".

That is perhaps the major flaw in my proposal.

No - Ed's got to come up with a different plan if he wants to make $100/hr as an instructor, because this one ain't going to cut it.

I don't make a living providing flight instruction, and I certainly have no aspirations to make $100/hr in the trade. As I stated elsewhere, my reason for the proposal is that I see an opportunity to improve what is a clearly less than perfect system. I believe that time building is an incentive which is poorly aligned with any goal related to providing excellent flight instruction. I feel the industry would be best served by experienced flight instructors who teach because they absolutely want to provide flight instruction and who provide excellent flight instruction. iMO, the opportunity to build flight time towards a subsequent, unrelated job should not be a motive for folks to enter flight instruction. As motivational tools go, that one is misaligned at best.

If you agree with the goal (flight instruction could be improved) but see holes in the plan (BTW, you noted a major, gaping hole in my proposal) I'd love to hear alternatives. The big disappointment is that the hole you noted in my proposal also appears in Ron's proposal. IOW, I believe you are correct, the airlines will simply change the rules, and the (poor) incentive will remain.

 

[poadeleted3]

Can't lay all the ills in the flight instruction business at the feet of time builders. Hands down, the worst flight instructor I ever had is still teaching, four years later the chief instructor of a flight school he helped start. This is a guy who had me climbing and descending through cloud layers without any kind of clearance (it's ok, it's a big sky), showed me how to use WD-40 to lubricate sticking flaps (don't need a mechanic, to expensive, a couple spritzes will fix it right up) and darn near killed my wife and on one flight.

 

[CFIse]

If you agree with the goal (flight instruction could be improved) but see holes in the plan (BTW, you noted a major, gaping hole in my proposal) I'd love to hear alternatives. The big disappointment is that the hole you noted in my proposal also appears in Ron's proposal. IOW, I believe you are correct, the airlines will simply change the rules, and the (poor) incentive will remain.

I agree with your goal.

However - to achieve it FIRST we need an alternative way for people to build time, because paying for the first 250 hours is expensive, if people had to pay for the first 1200 who knows who could afford to make that happen. Which ultimately leads to a pilot shortage. Short term that might be a good thing, but long term it's not pretty.

 

[Ed Guthrie]

I agree with your goal.

However - to achieve it FIRST we need an alternative way for people to build time, because paying for the first 250 hours is expensive, if people had to pay for the first 1200 who knows who could afford to make that happen. Which ultimately leads to a pilot shortage. Short term that might be a good thing, but long term it's not pretty.

In my envisioned perfect world, people would flight instruct because they want to flight instruct. In my envisioned perfect world, if the airlines want their pilots to have extensive flight experience the airlines pay for their pilot's extensive flight experience. Meanwhile, flight instruction focuses on flight instruction.

Hey, I'm allowed to dream.

 

[Auburn_CFI]

I do not see where you answered the question of PIC during primary training. This proposal is perhaps one of the most ridiculous things I have ever read in the years I have been around aviation. I read about 6 different aviation publications per month and have been reading most of them for several years, I have never seen a single article that says that we have a problem with the performance of CFI's nationwide. You are suggesting that we do in fact have some sort of major problem, and I was wondering where you are getting this information. I know many CFI's who are building time, every one of them takes Flight Instruction seriously and does their job well. I invite you to visit my workplace anytime to view our operation and let you judge for yourself the quality of training we offer. Flight Instructing has for many years been a very honorable way to gain knowledge and experience while building time and offering a service to others.