Tell FAA to count sport pilot time toward higher certificates

[JEFF TIPTON]

By Dan Namowitz

The FAA has opened for public comments a petition submitted by AOPA and three other associations urging that flight instruction from sport pilot instructors logged by sport pilot applicants be eligible to be counted toward higher pilot certificates.

Members are encouraged to submit comments in support of the petition that, if granted, would give sport pilots greater incentive to pursue further flight training, and recognize the cumulative value of their aeronautical experience in the spirit of the final sport pilot rule enacted in 2004.

In January, AOPA, the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), and the National Association of Flight Instructors (NAFI) petitioned to amend FAR 61.99 and 61.109 to clearly “permit the instruction time received in pursuit of a sport pilot certificate to be credited toward the instruction requirements of additional certificates and ratings.” Pilots wishing to earn recreational or private pilot certificates would still be required to receive training from a certificated flight instructor on all areas defined under the knowledge and flight proficiency requirements of that certificate.

The associations urged the amendments as a fix for the flaw pointed out by FAA legal staff that was preventing student sport pilots from counting their training flight hours received from sport pilot instructors toward higher certificates and thus discouraging them from pursuing additional training. A July 24, 2009, FAA letter of interpretation argued that allowing time logged with an instructor with a sport pilot rating to count toward a private pilot certificate would be “the functional equivalent of permitting that instructor to provide flight training for the issuance of the private pilot certificate.”

In response, the associations pointed out that when the FAA proposed the sport pilot rule in 2002 it signaled its intent to credit flight time earned during training with a sport pilot instructor toward the higher certificate.

The associations have been pressing the FAA to correct this situation since the letter was issued and petitioned for the rule change in January.

Members can submit comments online under Docket FAA-2011-0138.

http://www.aopa.org/advocacy/article...WT.mc_sect=nws

Petition address

http://www.regulations.gov/#!documen...2011-0138-0001

[CLS447]

That would be great !!!!!!

Let's give them an earful !!

[Brent Drake]

I would like to think that the FAA will start getting Gyro testing a little more accurate than it is. Lots of questions that has nothing to do with gyro's.

[scottessex]

Lets hope so.
So the way it stands right now, my dual instruction from Steve McGowan, and my sport pilot check ride from Ron Menzie, don't count toward PPL!? That is a load of BS!
The FAA really screwed up on the whole sport pilot SLA thing.
And on testing. When I took my A&P Exam back in 1989 all the questions were on dope and fabric and radial engines. I work for an Airline, how many radials have I seen at work?
I would not expect anything to move quickly, but yes we need to express our concerns.

[Chuck Roberg]

Scott, your dual training with Steve counts toward your PPL. The problem is training with Sport Pilot CFI's. The FAA says training with a Sport Pilot CFI can not be counted as dual training toward your PPL.

Any pilot in command time logged by yourself will count toward your higher rating. Such as flights to a towered airport, cross-country and solo time.

[scottessex]

Thanks Chuck that is what I had originally thought back then.

[okikuma]

Scott,

In your specific case, you need not to worry.

Steve McGowen is a Rotorcraft Gyroplane & Helicopter CFI. This means that Steve can give dual instruction to all Rotorcraft Gyroplane & Helicopter CFI, Commercial, Private Pilot, Recreational Pilot, & Gyroplane Sport Pilot students, and his dual instruction counts for every one of those ratings. Therefore Scott, the dual instruction you received from Steve McGowen will count for every higher rating above the Sport Pilot.

As it stands right now with the FAA, those individuals who received dual instruction from "Sport Pilot Only Instructors" cannot use that dual instruction time towards a higher than Sport Pilot rating. This is because "Sport Pilot Only Instructors" are able to give instruction specifically to "Sport Pilot Students" only and not for any higher ratings above Sport Pilot.

This is why the AOPA, EAA, GAMA, and the NAFI have petitioned the FAA to amend FAR 61.99 and 61.109 to clearly “permit the instruction time received in pursuit of a sport pilot certificate from a "Sport Pilot Only Instructor" to be credited toward the instruction requirements of additional certificates and ratings."

Wayne

[JEFF TIPTON]

Taken from EAA

Delightfully Surprised by the FAA

By Dan Grunloh, Editor - Light Plane World, EAA 173888
Dan Grunloh

Friends have advised me there is a pretty good chance the FAA will make that small change in the regulations related to sport pilot instruction that has been requested. The simple problem has been obvious for several years, but nothing was done. So finally the EAA and others submitted a joint petition earlier this year. My continued skepticism can be credited to the fact that my aviation roots are in the ultralight community.

I have nothing but praise for the people who work at the FAA. Those I’ve meet have been terrific especially as it relates to ultralights and light planes. It’s because they can see we’re having lots of fun in aviation, and besides, many homebuilders and EAA members are included among their ranks. But imagine a job where one major airplane accident on the East Coast can put you six months to two years behind on your work. Or picture an agency where external political maneuvering and internal differences in philosophy can scrap whole departments or projects. The simple needs of a few thousand sport pilots can be easily buried under a mountain of bureaucracy and the urgency of other events.

The last time I checked the online public comments to the sport pilot instructor petition, there were only about 185 responses by aviation organizations representing hundreds of thousands of members. I think this is definitely not good. It doesn’t matter that almost all the comments are favorable. In my view that isn’t important; almost everyone in the community and perhaps almost everyone at the FAA support the change. I fear the size of the response will have an effect on the sense of urgency within that beleaguered federal agency.

Check the comments here by clicking on the Docket ID number and then checking the box for “Public Submission.” Scan the list of names for your friends or other notable persons in sport aviation. A lot of names are missing that I thought I might see. Hopefully every subpart K sport pilot instructor will respond, and so should many of his students. We need to get going on this and run the numbers up much higher in case this necessary change isn’t immediately (one to two years?) forthcoming. A relatively small number of comments won’t be helpful.

Leaving a public comment on the government website is easy and fun, and the message doesn’t have to be eloquent or sophisticated. The main point is to be counted. Telling your government what to do could be a group activity for your local EAA chapter. Public comments don’t have to come from your home computer. The simple web form can be filled out by anyone, anywhere. A laptop computer with a wireless Internet connection at your monthly chapter meeting could be the source of multiple comments. The activity would help promote a sense of chapter community, and maybe it would help us all to be delightfully surprised by the FAA.

http://www.regulations.gov/#!documen...2011-0138-0001

[bryancobb]

A little history on this, if some folks are not aware. The SPORT PILOT REGS were intended and written to allow Sport CFI's to be REAL FAA instructors and their dual could be used for higher ratings. The way the reg's are worded is not the best, but the SPIRIT AND INTENT was there.

Then some "busy-body" (can't remember the details) who wasn't even a pilot, I think he was a journalist, got this issue in his crosshairs and he couldn't get the answer he wanted so HE ELEVATED IT TO THE FAA LEGAL DEPARTMENT where the lawyers wound up issuing a binding LETTER OF INTERPRETATION of the reg that was nothing like what the writers of the regs's intended.

This NPRM, if enacted, would just nullify the lawyers' letter and probably reword the reg so the original intent can't be misinterpreted.

I am a SPORT (Subpart K) CFI. The concern of the FAA lawyers was that I could give a SPORT student 20 hours of dual and he could then change his mind and go for the Private, and he wouldn't have to do any dual with a PRIVATE+ (Subpart H) CFI, except for the 3 hours of checkride prep.

The lawyers felt that I would NOT be an "Authorized Instructor" (the term in the regulation) in ithis case.

[Steve McGowan]

I have a great big problem with the SP logistics.. either way your FLYING.. Now tell me Im RONG..

Sport pilot ONLY is for those that does NOt want a Medical....That is the only difference and the 1320lbs. limit..

Whether its SP,REC,PPL,Comm or whatever,, You still have to be competent in the machine,,

Would I hear an AMEN to that..

But hey,,, All ya gotta do is another checkride and have a medical..and YES your flyin time will count. ..

[barnstorm2]

Originally Posted by Steve McGowan

Sport pilot ONLY is for those that does NOt want a Medical....That is the only difference and the 1320lbs. limit..

Perhaps some people would like to get a pilots cert and don't want to have to learn and be tested on kinds of flying they don't intend to ever do. Examples might be, night flying, night cross-country, radio navigation, ATC or flying above 10K feet.

Originally Posted by Steve McGowan

Whether its SP,REC,PPL,Comm or whatever,, You still have to be competent in the machine,, .

AMEN.

Originally Posted by Steve McGowan

But hey,,, All ya gotta do is another checkride and have a medical..and YES your flyin time will count. ..

If you or I train them YES (CFIs) but not if a Sport Instructor trained them.

.

[JEFF TIPTON]

To me the sport pilot rating is what the recreational pilot rating should have been in the beginning. There are people that just like to fly low and slow. A student pilot I knew decades ago kept his student license current and his flying consisted of going out to check the Crappie beds before he went fishing.

To me it should not matter who did the the instruction. The CFI study material is pretty much the same regardless of the rating up to the point of navigation and communication skills. The maneuvers taught are pretty much the same.

The key point is when the student is ready for the check ride, can they perform the required maneuvers in a safe manner with the outcome never seriously in doubt.

That is where the prep time comes into play, not just the three hours for the checkride. I will admit that a student going from a CH750 or Evertor and then stepping into something like a Cessna 150 will be an eye opener for them at the student level. It is a handful for many pilots to go from a Mooney to something the likes of a Sport Cruiser.

If the student can in only a few hours with a CFI perform to the Private Pilot level, why penalize them. Let them take the checkride.

I do not think they can in a few fours, but let them have the option as the rule was originally intended!

[bryancobb]

The stance that this commitee (of which I was a participant) took in the proposal is...
The Sport Pilot PTS and the Sport Pilot CFI PTS are
IDENTICAL to their Private counterparts in every single aspect of the maneuvers that need to be performed for the Sport License.
The writers of the Sport Regulations ALWAYS intended for those fist 10 to 20 hours of dual toward the rating, to count toward higher licenses.
When the FAA Legal department issued the letter of interpretation (a verrry rare event) it disallowed what was always the intent of the reg.

I am an experienced pilot whose blood pressure got a little high as I got older. I sold my helicopter and let my medical lapse and started teaching guys in their Kitfoxes, etc.
Now with this Legal Interpretation, no-one wants me as their instructor, because the money they pay me for dual hours is crap, if they ever decide to get a private ticket.
If I give them 15-20 hours of dual and they get their Sport ticket, and then 3 years and 500 sport hours later, they decide to get a private, they have to start back at ZERO dual hours, and pay a Subpart H CFI to re-teach them what they demonstrated on a checkride 3 years prior.

[Steve McGowan]

What you did is exactly what the Sport Pilot certificate was designed for.. However if you have a problem and do not address it,, then your still in violation with the FAA if you have a problem arrise..

The Sport Pilot Certificate gives people the incorrect mind set about flying.. It's the same training except for nite flite and over 25 miles from your home area..

That being said,, I as a Full CFI can instruct SP students and up to the CFI catagory in Helicopters and Gyroplanes.. You already know this,, However a Sport Pilot CFI can only instruct in a Light Sport Aircraft less than 1320 lbs. etc. etc.

Time frame is the same.. 20 hrs.. But that still is NOT the Golden Rule which is PROFICIENCY Level to the Standards of Safety..

You and others already know this and Im probably beating a dead horse by saying the same thing over and over..

[JEFF TIPTON]

Steve I would not say you are beating a dead horse. Very few students are ready for the check ride in the minimum FAA times. If they are not flying on a regular basis they can easily double the minimum requirements.

When it is all said and done they must perform the maneuvers within the PTS guidelines or they will not receive there certificate.