Complex Aircraft
I've written before about the problems surrounding how the FAA defines a complex aircraft, which is the type of aircraft that must be used to train flight instructors and commercial pilots. Here's what the Notice of Proposed Rulemaking had to say:
The current definition of a ‘‘complex airplane’’ in § 61.31(e) requires that the airplane have a retractable landing gear, flaps, and a controllable pitch propeller.
One way around this problem has been to use a twin-engine aircraft (virtually all of these meet the current definition of "complex aircraft") to train instructors and commercial pilots, then use a fixed-gear aircraft to add the single-engine rating to the candidate's multi-engine instructor or commercial certificate. Using a twin for the initial training is much more expensive for the applicant since two engines burn a lot of fuel and multi-engine aircraft are expensive to operate. Unfortunately, the new definition of "complex aircraft" doesn't do much to address the situation. Continuing to quote the Notice of Proposed Rulemaking (emphasis mine):
... a number of training providers have complained to the FAA that they have had to keep older airplanes in their inventory that meet this current § 61.31(e) ‘‘complex airplane’’ definition for providing commercial pilot and flight instructor training of § 61.129(a)(3)(ii) or § 61.129(b)(3)(ii) and the additional training requirements of § 61.31(e). To remove this unnecessary burden, we are proposing to consider an airplane equipped with a FADEC system as being equivalent to one having a controllable pitch propeller.
Now if you think that the FAA is addressing the problem that there really is only one single-engine complex training aircraft (the Piper Arrow) and only one multi-engine training aircraft (the Piper Seminole) currently being manufactured, think again. Near as I can tell, the change to the definition of complex aircraft only affects one aircraft - the twin-engine Diamond DA42. The DA42 meets all the requirements of the current definition of complex aircraft, except for the fact that the propeller is not directly controllable by the pilot - it's controlled by FADEC (Full Authority Direct Engine Control). So the new definition simply allows the DA42 to be consider a complex aircraft. Unencumbered by facts, here's what the NPR says about the costs associated with this change:
Small businesses that would be affected by the revised definition of ‘‘complex airplane’’ would be schools and training providers. Many pilot schools would not have to keep an inventory of two kinds of airplanes to meet the commercial pilot and flight instructor certification requirements. This would engender cost savings, which the FAA estimates at $1,000 per
airplane annually.
With all due respect, what are they smoking? Unless Cessna or Piper has plans to manufacture a new single-engine, retractable gear trainer that has FADEC, the new definition of complex aircraft does nothing to change the fact that many flight schools will still to have to keep old Cessna 172RGs, Piper Arrows, Mooneys or other aged aircraft in order to train single-engine flight instructors and commercial pilots. And of the flight schools that train initial instructor and commercial candidates in twins, I can't imagine that many of them can afford to drop half a million-plus dollars to buy a Diamond DA42. While this change is good news for Diamond Aircraft, it doesn't seem to address the problems faced by smaller flight schools.
Combined Private & Instrument
Under the current rules, holding a private pilot certificate is a prerequisite for applying for an instrument rating. Under the proposed rules, pilots would be allowed to apply for their private certificate and their instrument rating concurrently. Here's the rationale:
Historically, accident statistics show that all weather-related accidents account for approximately 4.0 percent of total accidents. For single engine airplanes with a fixed landing gear, the airplane used predominantly by both student and private pilots, by far the largest weather-related accident cause is continuing to fly under VFR into IMC. This occurs when a pilot encounters changing weather conditions and does not land prior to encountering IMC. The proposed rule change would permit private pilot applicants to combine their private pilot and instrument training, which would improve their skills to operate in IMC and should reduce weather-related accidents. Thus, the FAA is proposing to revise § 61.65(a)(1) to allow applicants for an instrument rating to concurrently apply for a private pilot certificate.
Combining private pilot training and instrument training makes sense for large part 141 schools like Embry Riddle or Middle Tennessee State University, which interestingly enough already had an exemption to do this. This rule change simply benefits other part 141 schools who wish to seek approval to do the same thing.
It's not clear to me if or how this would affect pilots who train under part 61 since one prerequisite for the instrument rating is 50 hours of pilot-in-command cross country experience. Since the only time a student pilot can log PIC time is when they are solo, they'd have to log a lot of solo PIC cross country time and receive an endorsement from an authorized instructor for each and every solo cross-country flight. Maybe I'm missing something, but I don't think this is what the FAA intended and it doesn't seem to increase flight safety. In fact, it might do just the opposite.
Complex Aircraft Experience for Commercial Candidates
The current rules require commercial pilot candidates have 10 hours of aeronautical experience in a complex aircraft, but the proposal is to replace that requirement with 10 hours of "advanced instrument training" in an aircraft, flight simulator, or approved flight training device. Here's the proposed definition of advanced instrument training:
The NPR also contains this:
Proficiency Checks for Single-Engine Turbojets
Even though the economy has tanked, there is the belief that soon there will be a fair number of singe-engine jet aircraft that will most likely be piloted by the owners. Sensing that these aircraft could become the next breed of so-called "Doctor killers," the FAA is proposing that the folks who pilot these aircraft should demonstrate proficiency on a regular basis. I'm sure the insurance companies will also require regular recurrent training, too, but this seems like a sound idea.
... must include instrument approaches consisting of both precision and nonprecision approaches, holding at navigational radio stations, intersections, waypoints, and crosscountry flying that involved performing takeoff, area departure, enroute, area arrival, approach, and missed approach phases of flight.First, there isn't much about this training that would seem to warrant the adjective "advanced." All of the items listed involve basic tasks and areas of operation included in the instrument rating practical test standards. What this change will allow is for commercial candidates to save some dough by logging these 10 hours in a simulator or flight training device, but it's not clear to me that this will result in better pilot training. It will also help candidates who are training for the commercial certificate and their instrument rating concurrently. Wait, I thought that in the future some pilots were going to get their instrument rating when they got their private pilot certificate? At least the FAA's proposal continues the tradition of keeping the rules and regulations confusing.
The NPR also contains this:
The FAA proposes to revise theCall me crazy, but the Commercial Pilot Airplane and Flight Instructor Airplane practical test standards still require the use of a complex aircraft for the practical test, so these schools will still have to keep the old aircraft around for folks to take their check rides. Unless the FAA has plans to change the commercial PTS, too ...
Commercial Pilot Certification—Airplane Single Engine (Land and Sea) rating because fewer single-engine airplanes are being produced with retractable landing gears. Manufacturers of general aviation airplanes now produce technologically advanced airplanes with ‘‘glass cockpits,’’ but which do not have retractable landing gears. Many pilot schools have complained about the necessity to keep 30-year old Cessna 172RGs and Piper Arrows in inventory, which are less technically advanced airplanes, for the sole purpose of providing 10 hours of complex airplane training.
Proficiency Checks for Single-Engine Turbojets
Even though the economy has tanked, there is the belief that soon there will be a fair number of singe-engine jet aircraft that will most likely be piloted by the owners. Sensing that these aircraft could become the next breed of so-called "Doctor killers," the FAA is proposing that the folks who pilot these aircraft should demonstrate proficiency on a regular basis. I'm sure the insurance companies will also require regular recurrent training, too, but this seems like a sound idea.
Sound off!
If you'd like to comment on the Notice of Proposed Rulemaking, try using this link
If you'd like to comment on the Notice of Proposed Rulemaking, try using this link
