I believe strongly in the value of GA—and the importance of introducing others to all that general aviation has to offer. That’s one reason I have made growing the pilot population a personal mission and a priority for AOPA in 2010. But to attract and retain new pilots, flight training must be both accessible and as affordable as possible. So when the FAA proposed a series of changes to Part 61 of the federal aviation regulations (FARs), we were right there to evaluate the proposals and make recommendations to ensure that any changes don’t hurt students or schools. In fact, we think some of the ideas on the table could simplify flight training—something any student pilot would be happy about.
Working with the FAA on issues such as this falls mainly to AOPA’s regulatory affairs team, a small subset of our government affairs division that focuses entirely on the regulations that affect your flying. Their expertise in the complex world of regulations, along with the relationships they have developed by working closely with the FAA on hundreds of issues, helps ensure that they, and by extension you, are heard when it comes to matters that impact the rules governing our flying.
In the case of Part 61, the FAA is proposing 16 different changes. And in comments we filed with the FAA in December, we’ve proposed a few more that we believe will streamline the flight training process, and thereby hold down costs.
For example, we’re supporting an FAA recommendation that student pilots be allowed to earn the private pilot certificate and instrument rating simultaneously—although we don’t want concurrent training to be a requirement. But for students who already know they want to pursue an instrument rating—such as those on their way to a flying career—working on both sets of requirements at the same time could boost efficiency, cut down on training time, and save money.
We’ve also added a recommendation of our own. We’ve proposed changing the rules so that flight instructor certificates don’t expire and instructors have more time to take a flight instructor refresher clinic. Under our recommendation, CFIs would need to take recurrent training every 24 months in order to exercise the privileges of the flight instructor certificate. Our reasons for suggesting this were, again, based on real-world flying. Many flight instructors who leave teaching never return to it because they would have to get their CFI certificate reinstated—a time-consuming and costly proposition. Our proposal would allow former instructors to get back in the game with appropriate training, making it easier and more affordable for them to return to teaching. That has the potential to increase the number of active flight instructors, increasing access to training.
For students and certificated pilots who want to fly complex aircraft, the FAA has recommended expanding the definition of “complex” to include aircraft equipped with full-authority digital engine control (FADEC) systems. The FAA has also proposed removing the requirement for 10 hours of complex time from the commercial certificate.
AOPA is supporting both those changes, but once again, we’ve added a recommendation of our own—eliminating the need for an instructor’s endorsement for complex aircraft and changing the practical test standards for the commercial and flight instructor certificates so that they don’t require flight in a complex aircraft.
As part of its proposal to remove the complex time mandate from the commercial pilot certificate requirements, the FAA has suggested replacing the 10 hours of training saved with 10 hours of advanced instrument training. But we think this may be a little extreme, especially for those seeking a VFR-only commercial certificate. Instead, we’re asking the FAA to meet with flight training providers to find out what other areas of training might be more valuable as part of the commercial certificate.
Of course, when it comes to the regulatory process, there’s a great deal of deliberation involved—and that’s appropriate because so much is at stake. But it also means it could be a long time before we see any changes. The FAA has received numerous comments on its proposals, and now it must go back to the drawing board, consider each idea, and decide if and how to implement it. It’s a process that could take years. But be assured that we will be vigilant and stay involved, representing your interests here as we do in every arena affecting general aviation. And I’m optimistic that, in the end, the collaborative process will produce regulations that serve us, and future generations of pilots, well.