Proposed FAR Changes

[midlifeflyer]

The FAA issued a proposed rule this morning. It deals with a number of training, instrument currency and one logging issues. It can be read at http://1.usa.gov/2203vVS.

If interested, I put together a summary on one of my Facebook pages

 

[James331]

Not shabby, so the CFI part would allow a instrumented rated CPL who is a CFI but not a CFII to give instrument instruction?

 

[midlifeflyer]

Not shabby, so the CFI part would allow a instrumented rated CPL who is a CFI but not a CFII to give instrument instruction?

That's what it seems to say. At least so long as the CFII has the applicable aircraft rating on the commercial certificate. This one is mostly interesting because it has gone back and forth a lot. I've always though the argument over it was a major participating factor in the demise of the Part 61 FAQ.

Edit: I misread the post. @flyingron has it right. It is the other way around. The FAA will still requires someone teaching instruments to have passed the CFI-Instrument knowledge and practical tests.

It will allow the CFI-I who does not have an aircraft rating to teach instruments in an aircraft or simulation device so long as he or she has the applicable aircraft rating on the commercial certificate.

 

[James331]

Personally I think it makes a ton of sense.

If you're a CFI and have a SEL IFR ticket, you should be able to teach instrument in a single engine plane as well.

 

[frfly172]

Thanks for the post,some good information.

 

[midlifeflyer]

BTW, for anyone interested in commenting, head over to regulations.gov. The docket for this reg change is located at http://1.usa.gov/221lb3t

 

[flyingron]

Not shabby, so the CFI part would allow a instrumented rated CPL who is a CFI but not a CFII to give instrument instruction?

I think it's the other way around. It lets someone who has a Instrument Rating on his CFI but not the appropriate category/class rating on his CFI to instruct instruments provided he has the category/class on his pilot certificate.

An example would be a CFII who is not a MEI, but has a ME on his commercial certificate, to teach instruments (but not the underlying ME stuff) in a twin. However, I think this is more targeted at instrument instruction in odd things like gliders and powered lift etc...

 

[flyingron]

I'm all for the changes to the ATD stuff (and the CFI thing discussed above is just really refining what you're talking about when you say you are giving instrument instruction versus aircraft instruction).

I'm not sure I guy the complex vs. TAA. While TAA issues (glass panels and the like) bring in their own issues (as mentioned in the NPRM, failure modes), learning these doesn't seem to supplant the things that a complex aircraft forces you to learn. However, it's probably largely a splitting hair issue as a single engine alone commercial certificate doesn't really mean a whole lot to the industry. Almost all ME training is done in complex aircraft (TAA or not) anyhow.

 

[Wheels]

Does operating a complex aircraft really need to be part of a commercial Checkride at all? Maybe require the endorsement as a prerequisite for the Checkride but why does the examiner have to doublecheck the instructor who gave you the endorsement? Should you also have to get a Checkride to verify that you can fly a high performance or tail-wheel after you get an endorsement for it?

 

[midlifeflyer]

I think it's the other way around. It lets someone who has a Instrument Rating on his CFI but not the appropriate category/class rating on his CFI to instruct instruments provided he has the category/class on his pilot certificate.

An example would be a CFII who is not a MEI, but has a ME on his commercial certificate, to teach instruments (but not the underlying ME stuff) in a twin. However, I think this is more targeted at instrument instruction in odd things like gliders and powered lift etc...

You are correct. I misread the question. I added an edit to my earlier reply.

IOW, here's one scenario:

• Commercial pilot certificate with ASEL and AMEL ratings.
• Instructor certificate with only an Instrument Airplane rating (no ASE or AME).

May teach instruments in both ASE and AMEL aircraft
May not give general ASEL or AMEL instruction.

 

[midlifeflyer]

I'm not sure I guy the complex vs. TAA.

I think it's kind of like the insurance-related "performing the duties of PIC with an instructor on board." A reality-based modification, in this case due to the ageing and diminishing of much of the light retract rental fleet traditionally used for the purpose (Cutlasses and Arrows). I kind of expect this part of the proposals to generate the most negative comments.

 

[James331]

I'm all for the changes to the ATD stuff (and the CFI thing discussed above is just really refining what you're talking about when you say you are giving instrument instruction versus aircraft instruction).

I'm not sure I guy the complex vs. TAA. While TAA issues (glass panels and the like) bring in their own issues (as mentioned in the NPRM, failure modes), learning these doesn't seem to supplant the things that a complex aircraft forces you to learn. However, it's probably largely a splitting hair issue as a single engine alone commercial certificate doesn't really mean a whole lot to the industry. Almost all ME training is done in complex aircraft (TAA or not) anyhow.

Agreed.

To be a professional pilot you should really be able to make a CS/RG airplane sing, any monkey can follow a checklist and fly the damn thing, but to do a "keep your speed up approach" and end up crossing the fence right at VREF, using your prop, gear and flaps at the right times and easing them in just right, that takes the skill expected of a aspiring pro pilot.

 

[flyingron]

that takes the skill expected of a aspiring pro pilot.

The FAA argument, which I might agree, is that most "real" pilots end up with MEL ratings which usually are done in real complex aircraft. This only lightens up the guy trying to get a CFI or do some hack SE commercial work (as limited as that can be).

 

[denverpilot]

The FAA argument, which I might agree, is that most "real" pilots end up with MEL ratings which usually are done in real complex aircraft. This only lightens up the guy trying to get a CFI or do some hack SE commercial work (as limited as that can be).

The place I'm using for the Commercial is going straight to the multi -- they have no desire to keep a retract single in their stable. Commercial single is then a backtrack into a 182, which is bog simple for them to maintain and operate.

The proposal seems to be aimed at selling more Cirri. Which I'm not judging. Just sayin'.

 

[flyingron]

Or Columbias... etc... For a while Cessna hadn't built any retract singles in decades. Of course, now they have the G36.

 

[James331]

The FAA argument, which I might agree, is that most "real" pilots end up with MEL ratings which usually are done in real complex aircraft. This only lightens up the guy trying to get a CFI or do some hack SE commercial work (as limited as that can be).

9.9 times out of 10 your first job ain't going to be in a multi.

 

[MauleSkinner]

9.9 times out of 10 your first job ain't going to be in a multi.

Of that 99%, what percentage are in complex airplanes?

Or Columbias... etc... For a while Cessna hadn't built any retract singles in decades. Of course, now they have the G36.

those still say "Beechcraft" on the side, not "Cessna".

 

[James331]

Meh.. like 40% or so I'd say.

My first job was in a Arrow IV, friend of mine went into a 210, if you end up at a DZ (good starter job) you're likely going to be behind a CS prop and a big bore, cowl flap engine, so much of what you learn in a complex minus the gear.

Not many newbie jobs for twins or glass panels.

 

[dmspilot]

I would say allow 10 hours of high-performance time to count for the complex...but not 10 hours TAA. The NPRM admits many pilots are flying TAA aircraft already so what's the point? A TAA isn't more challenging, it's just different.

 

[KSCessnaDriver]

9.9 times out of 10 your first job ain't going to be in a multi.

99% of the time people are going to go sit in the right seat of a 172 "teaching" people to fly.

 

[mondtster]

I think it's the other way around. It lets someone who has a Instrument Rating on his CFI but not the appropriate category/class rating on his CFI to instruct instruments provided he has the category/class on his pilot certificate.

An example would be a CFII who is not a MEI, but has a ME on his commercial certificate, to teach instruments (but not the underlying ME stuff) in a twin. However, I think this is more targeted at instrument instruction in odd things like gliders and powered lift etc...

That's how I read it too. The instrument instructor rating without holding an airplane (or helicopter, or whatever) instructor rating is pretty much worthless the way things are currently written, because it would basically only allow you to teach ground or in a simulator. I've always thought it was a bit ridiculous that I can fly instruments in a multi, act as safety pilot in a multi, and teach instrument flying but I can't currently give someone an IPC in a multi.

I'm not sure I guy the complex vs. TAA. While TAA issues (glass panels and the like) bring in their own issues (as mentioned in the NPRM, failure modes), learning these doesn't seem to supplant the things that a complex aircraft forces you to learn. However, it's probably largely a splitting hair issue as a single engine alone commercial certificate doesn't really mean a whole lot to the industry. Almost all ME training is done in complex aircraft (TAA or not) anyhow.

My ax to grind with dropping the complex requirement has little to do with actually flying the airplane, but more to do with learning more complex aircraft systems and how to manage and troubleshoot them. Granted, even if they did drop the complex requirement on the commercial certificate it is not likely that someone would be getting a job without some training or time in type due to insurance requirements so I suppose it could be done at that time.

Or just get your initial commercial rating in a seaplane. Then you don't need a retractable landing gear anyway.

 

[MauleSkinner]

Meh.. like 40% or so I'd say.

My first job was in a Arrow IV, friend of mine went into a 210, if you end up at a DZ (good starter job) you're likely going to be behind a CS prop and a big bore, cowl flap engine, so much of what you learn in a complex minus the gear.

Not many newbie jobs for twins or glass panels.

From what I've seen, very few pilots' complex training includes anything that will help with a big bore engine and cowl flaps. For that matter, a lot of high performance training is deficient in those areas. (Ever seen someone start an airplane at full throttle for a couple of seconds before reducing to idle because "they were taught not to make rapid power changes"?)

 

[James331]

99% of the time people are going to go sit in the right seat of a 172 "teaching" people to fly.

That's a bit over the top, plenty of glider tow, Dz, overseas charter stuff, pt91, to be had.

From what I've seen, very few pilots' complex training includes anything that will help with a big bore engine and cowl flaps. For that matter, a lot of high performance training is deficient in those areas. (Ever seen someone start an airplane at full throttle for a couple of seconds before reducing to idle because "they were taught not to make rapid power changes"?)

That's just bad CFIing, would not have been a recommend for a CPL ride with me, making cheap CPLs cheapen the profession as a whole.

 

[MauleSkinner]

Plenty of bad CFIing out there...that's one of the ingredients in "a classic warm front comes south out of Canada and makes 60,000 ft thunderstorms."