November 2, 2011
Four major general aviation organizations are calling on the Federal Aviation Administration (FAA) to change the rules and make it easier for Sport Pilots to pursue additional training and higher level pilot certificates. The Aircraft Owners and Pilots Association (AOPA), Experimental Aircraft Association (EAA), General Aviation Manufacturers Association (GAMA), and National Association of Flight Instructors (NAFI) petitioned the FAA to amend the federal aviation regulations (14 CFR Part 61) so that flight hours accrued while earning a Sport Pilot certificate can count toward additional ratings and certificates.
AOPA, EAA, GAMA, and NAFI have collaborated to submit a petition for rulemaking that requests amendment of 14 CFR Part 61 to allow instruction time received in pursuit of a sport pilot certificate to be credited towards the instruction requirements of additional certificates and ratings. The four organizations have submitted this petition in response to questions that each organization has received regarding the applicability of instruction received from sport pilot instructors during training for a sport pilot certificate and the applicability of this time towards further ratings and certificates, such as a private pilot certificate.
A 2009 letter of interpretation from the FAA argued that allowing training provided by a sport pilot instructor (CFI-S) to count toward the aeronautical experience requirement for a private certificate "would be the functional equivalent of permitting that instructor to provide flight training for the issuance of the private pilot certificate with those ratings." It has been suggested that flight training given by a CFI-S could not be credited toward the hour requirements for future certificates and ratings, such as the private or recreational certificates.
AOPA, EAA, GAMA, and NAFI believe that training received from a sport pilot instructor should count toward other certificates and ratings, and so are petitioning the FAA to amend FAR Part 61.99 and 61.109 to clearly "permit the instruction time received in pursuit of a sport pilot certificate to be credited towards the instruction requirements of additional certificates and ratings." Anyone wishing to obtain a recreational or private pilot certificate would still be required to obtain training from a CFI on all areas defined under the knowledge and flight proficiency requirements of that certificate. They would also be required to complete the elements that a sport pilot instructors cannot complete such as the night training and three hours in preparation for the practical exam.
When it was created, the sport pilot certificate was intended in part as a less expensive entrée into the world of general aviation, and for some pilots as a stepping-stone to higher certificates. The FAA’s proposal of the sport pilot rule in 2002 signaled its intent that "[u]nder this proposal, certificated sport pilots could credit ultralight flight time toward higher-level certificates, which would increase the experience level and qualification of sport pilots."
"Experience begins to accrue the very first day that a student pilot sits behind the controls of an aircraft," the groups wrote. "The aeronautical experience obtained in pursuit of a sport pilot certificate should not be discredited, in essence resetting the clock on aeronautical experience as if that sport pilot was an initial student with no previous experience. The experience gained in pursuit of the sport pilot certificate relates directly to the experience needed to obtain a recreational or private pilot certificate and should not be disregarded. It provides a valuable foundation for the additional requirements of the private pilot certificate."
Allowing sport pilots to transition more smoothly to higher certificates and ratings would not compromise safety, the groups said; in fact, it would give sport pilots greater incentive to pursue higher certificates. Safety is enhanced as a pilot receives additional training and pursues higher certificates and ratings, the groups said.
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