In February, the FAA proposed some 50 pages' worth of clarifications, changes, and updates to Part 61 and 141 regulations governing pilot training and certification. AOPA immediately unleashed its professional staff, called in the AOPA Air Safety Foundation, and asked AOPA members to analyze the proposal line by line.
"Some of what the FAA wants to change would cost students and existing pilots more money with no safety or training benefit, some 'clarifications' just made things more unclear, and some actually would be improvements," said Rob Hackman, AOPA senior director of regulatory affairs. "In our 12 pages of comments, we've made sure that the FAA understands the negative and positive impacts of the proposed regulatory changes."
AOPA's most significant concern is over a proposed change to the instrument currency requirements. The FAA wants to add requirements for both precision and nonprecision approaches; holding patterns at "radio stations," intersections, or waypoints; one-hour of cross-country flight; and a missed-approach procedure within the previous six months for a pilot to remain instrument current.
"These requirements don't reflect real-world flying experiences, nor do we see how they would contribute to improved safety and instrument proficiency," said Hackman.
AOPA recommended that most of the regulations governing instrument currency remain unchanged.
The FAA also proposed changes that would allow pilots to use flight training devices (FTDs) and personal computer aviation training devices (PCATDs) to meet instrument currency requirements.
The idea is good, said AOPA, but the agency is proposing onerous hour and task requirements that go well beyond what's needed for maintaining currency. "We believe that these requirements should mirror those currently required when using an aircraft to meet instrument currency requirements," AOPA said.
The agency wants to require a "view-limiting device" for pilots using a PCATD for credit toward training hours required for an instrument rating. AOPA opposed that, since all types of flight trainers already simulate instrument flight.
The FAA also proposed changes that AOPA found positive, including extending the duration of student pilot certificates to coincide with the duration of the medical certificate.
And AOPA recommended an additional change to Part 61. The association once again proposed that the agency replace the medical for a recreational pilot certificate with a "driver's license" requirement to meet the medical standard, just as the agency has done for sport pilots.
Noting that the FAA has said that medical conditions are not a significant cause of accidents in aircraft used for sport and recreational purposes, and that recreational pilots are limited to day VFR only in lower performance (180 horsepower or less) aircraft carrying only one passenger, AOPA said that the FAA should "take the next logical step" and extend the driver's license medical to pilots exercising recreational pilot privileges.
May 10, 2007