AOPA Action

Flight training with a sport pilot instructor should be allowed to count toward the aeronautical experience requirements of higher certificates, AOPA told the FAA in a petition for a change to the regulations.

The creation of 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. But a 2009 letter of interpretation suggests that flight training given by a sport pilot instructor (CFI-S) could not be credited toward the hour requirements for future certificates and ratings, such as the private or recreational certificates. AOPA’s analysis came to a different conclusion; and the association, the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), and the National Association of Flight Instructors (NAFI) are petitioning the FAA to specify in the regulations that this instruction can be credited toward future certificates.

The groups asked the FAA to amend FAR parts 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.” Anyone wishing to obtain a recreational or private pilot certificate would still be required to receive training from a CFI on all areas defined under the knowledge and flight proficiency requirements of that certificate.

The FAA’s proposal of the sport pilot rule in 2002 signaled its intent that, “Under 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.” But a 2009 letter of interpretation argued that allowing training provided by a 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.”

The groups disagreed in their letter, explaining that aeronautical experience gained in pursuit of a sport pilot certificate can provide a valuable foundation for the additional requirements of the private pilot certificate.

“Experience begins to accrue the very first day that a student pilot sits behind the controls of an aircraft,” they 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.”

Allowing sport pilots to transition more smoothly to higher certificates and ratings would not compromise safety, the groups said. 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.