Original Posted By: "Christian Bobka"
The majority of the time, the NPRM takes the point of view that the sportpilot has no or minimal experience as he is newly attracted to sport orrecreational flying. The NPRM barely mentions that, realistically, themajority of future sport pilots are those that have already entered and thenLEFT aviation because of the weight of bureaucratic hassles and costs. Anexample is a close friend of mine who had open heart surgery years ago andwho now works safely driving an 80 passenger school bus, yet is ineligibleto fly an airplane by himself because of the costs in time and money of theburden of proof necessary to get a medical certificate under the currentrules. I know he would be the first to get a new sport pilot certificate.But the rules are rather draconian, if not insulting, considering hisinactive commercial multiengine instrument CFI credentials. I am currentlyan 8000 hour ATP rated airline pilot who someday aspires to the simpler lifeof flying in retirement under sport pilot rules. Yet, it appears that thehassles of finding an instructor with 150 hours of experience and 5 hours ina Luscombe 8B so he can show me how to fly a Luscombe 8B, which I have notflown yet, even though I have flown 1000 hours in the virtually identicalLuscombe 8A, is just not worth it. The new rule simply ignores priorexperience. Flying is all about learning to demonstrate good judgement.For every checkride I have ever taken or given, demonstrating good judgementis the primary criterion for passing or failing. If a highly qualified pilotfeels he needs training, he will seek it. That is common sense and youcannot legislate common sense. The need for many endorsements for make andmodel for a highly qualified pilot wishing to downgrade his certificates isjust too cumbersome and will cause the new rule to ultimately fail. Irecommend that if a sport pilot has 500 hours or more total time, and 200hours or more in category and class, then the endorsement for make and modelbe waived.In connection with the comments in the preceding paragraph regarding thedeficiency in the NPRM regarding favorable rules recognizing the desire ofexperienced pilots or pilots of higher ratings to "demote" themselves tosport pilots, the NPRM is unclear in what is required of an existingCertified Flight Instructor (CFI) to instruct sport pilots or sport pilotcandidates in sport aircraft. My situation, the same as many others, isthat I am a longtime CFI, having continuously held the rating for thirteenyears. Due to my experience, I am an asset to the world of flying and wouldlike to keep it that way. There may come a time that I may wish to let myFAA medical lapse and revert to the drivers license requirement for proof ofhealth. I could then fly sport aircraft with my ATP ticket in my pocket asa sport pilot. Yet can I still instruct in sport aircraft using my CFIcertificate which I would continue to keep current? The back of my CFIcertificate says "valid only when accompanied by [ATP] pilot certificate no.XXXXX. Expires 30 sep 2003". If I no longer have an FAA medical, my ATPprivileges lapse, and so do the CFI privileges? If this were true of everyaging instructor, it would be a tremendous waste of talent for the flyingworld to bare. It is of tremendous importance for aviation to retain asmuch experience as it can, especially in the ranks of the instructors. I amlooking for clarification in the new rule on this question. I recommendthat the new rule allow for a CFI under the current FARs who chooses to lethis FAA medical certificate lapse, to continue to enjoy his CFI privilegesas exist in the current FARs but limited to aircraft that qualify as sportaircraft under the new rule without having to obtain a CFI - Sport Pilotrating. Furthermore, the CFI can continue to renew his CFI using themethods described in the current FARs.I would also like to know how an instructor would train someone to fly aparticular make and model of a SINGLE SEAT sport pilot aircraft? This hasnever occurred before in the FARs, maybe with the exception of the limitedquantities of Letters of Authorizations for warbird aircraft. Recognizingthe need for a few endorsements related to engine horsepower or aircraftcomplexity, usually, you qualify in a category and class and then you aregood for any of the other aircraft in the same category and class. Irecommend the abandonment of the training requirement for specific make andmodel.________________________________________________________________________________