Support for nixing complex time for commercial restated

March 3, 2011

Removing the requirement to log 10 hours of complex airplane time to earn a commercial pilot certificate would save money and improve safety, AOPA told the FAA March 2.

The association wrote a letter to restate its support of an FAA proposal that would eliminate that requirement in changes to Part 61 of the federal aviation regulations. In the same letter, AOPA restated its concerns regarding a corresponding proposal to add 10 hours of “advanced instrument training” in place of the complex airplane time.

The proposals are part of a package of changes to flight training requirements, of which the FAA is expected to release a final version soon. AOPA weighed in on the proposals when they were first released and, in anticipation of the final rule, is now underscoring its position on the changes to commercial pilot training requirements.

The association strongly supports eliminating the requirement of the 10 hours of aeronautical experience in a complex airplane in FAR 61.129(a)(3)(ii), explained AOPA Manager of Regulatory Affairs Kristine Hartzell. The proposal would reduce the economic burden on flight schools and students and increase safety, she said: Because fewer single-engine airplanes are being produced with retractable landing gear, “flight schools are forced to maintain aging aircraft solely for the purpose of meeting this requisite.”

For private pilots who do not need the commercial certificate but want to pursue it to increase their skills, cost—including the higher cost of training in a complex aircraft—can be a determining factor, she said.

“If the FAA eliminates the 10 hours of complex for the commercial certificate, it would reduce the cost to obtain the certificate and increase safety by attracting more pilots to pursue a higher level of training,” Hartzell wrote.

Hartzell questioned the FAA’s proposal for replacing those 10 hours with advanced instrument training. The proposal “is not only unnecessary, it doesn’t make sense,” she wrote. “The FAA allows for the issuance of a commercial pilot certificate with the limitation of VFR only.” AOPA suggested that the FAA convene a meeting of flight training providers and industry representatives to determine what type of training should replace the 10 hours of complex airplane time.