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LSA instruction

Posted By:
Bill Leavens
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#1 Posted: 8/10/2009 07:28:21

(From Avweb)

This will put a big hurt on LSA instructors:

FAA: Light Sport Time Can Go Toward Private Cert. (Sometimes)

 

So, can a student pilot apply any flight time he or she logged while training for a sport pilot certificate toward a private pilot certificate? According to a letter from the FAA's Office of the Chief Counsel to aviation journalist Tim Kern, who queried the office, solo sport pilot flight time may only be credited to solo private pilot flight time if the "specific category and class of aircraft are met." Logging instruction time depends on the instructor's credentials. If instruction is received from an instructor who holds only a a sport pilot rating, that instruction may not be credited toward the issuance of a private pilot certificate. However, if the instruction toward a sport pilot certificate is provided by an instructor authorized to provide instruction to both sport pilots and private pilots, that time could "be credited toward the flight training requirements for a corresponding private pilot certificate." There are more details ... .

 

According to the letter, "flight time obtained in a certificated aircraft prior to the issuance of a private pilot certificate, regardless of whether that flight time was obtained prior to, or after, the issuance of a sport pilot certificate may be credited toward the flight time requirements for the issuance of the private pilot certificate." Kern has posted the full text of the letter here (PDF). It explains in detail that a sport pilot instructor (SPI) is not qualified to give dual for a private certificate and therefore any instruction given by an SPI is not applicable toward the private.


It seems to me that flight experience is flight experience.

It's all about becoming familiar with operating in the ocean

of air above us, manipulating the controls and developing

the skills necessary to return to earth safely.



Bill Leavens
Jerry Rosie
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#2 Posted: 8/10/2009 07:56:58

This ruling seems inconsistant with previous rulings on a similar subject.  At the beginning of the LSA transition, time and instruction in an Ultralight was transferable to LSA certification if the pilot was registered with an Ultralight organization and had a letter from that organization.  It doesn't seem that the same logic was applied here.  While it is true that there are subject areas required in PPL training that are not required in LSA training, one would think that receiving training in these areas from a CFI could be added to the time received from an LSA instructor, not disregarding the LSA time totally.  I have to keep remembering "We are from the FAA, We are here to help you" is an oximorin...
biggrin



Cheers, Jerry NC22375 out of 07N
Adam Smith
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#3 Posted: 8/10/2009 08:38:16

EAA has been working on this and will be putting out a story / statement in the next couple of days. 



Steve Phoenix
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#4 Posted: 8/10/2009 20:17:35

If you're learning aerobatics, you may learn more from Sean Tucker than from me and this would indicate that flight experience comes in different intensities.  You may not because Sean might be a lousy teacher, but the rule is an attempt to sort that out.  Rules do not cover all circumstances, but they are usually a best attempt to capture the majority of circumstances.



Patrick Panzera
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#5 Posted: 8/11/2009 16:03:36

With that in mind, if you were a 10,000+ hour GA pilot, with plenty of commercial time in x-country IMC (including military stick time) and you decided to let your medical lapse and then went on to become a CFI-SP, your time given to a SP student wouldn't count toward his private.

Conversely, a 21 year old kid while attending a '"slam-dunk" school hits his CFI rating at a little over the exact minimum, his time with a primary student is somehow more valuable than yours???

Another slant... say I took all my lessons from a CFI-SP. I went on to become a CFI-SP (with all the endorsements) and trained literally hundreds of sport pilots, gave them their endorsements and trained several to become CFI-SP as well, while racking up untold thousands of hours.

Then one day I decide to get a medical and move up a notch to private pilot. I would then need 20 hours from a CFI (maybe the same 250 hour kid as in the above paragraph) doing s-turns, flying dual x-countries, slow flight, stalls, turns on a point, unusual attitude recovery, all the same stuff I've been teaching for years, I now have to get taught again?

I can understand adding 10 to the original 10 I received during my initial training- save the training received while getting endorsed for airspace. I can't see having to do over the primary stuff I've been teaching. What's the point of receiving dual x-country when I have hundreds of trips logged covering thousands of miles? That is especially ironic when my two additional solo x-countries that I would need to "upgrade" to PP are already logged before completing the required three dual.

Somehow a CFI-SP rating, irrespective of the total amount of experience it's backed by, is somehow inferior to a CFI rating when it comes to primary training??? If that's the case, then ALL sport pilots should be required to get their training from a CFI and the CFI-SP rating should be ashcanned.

Pat

 

 

 



Aaron Hunsucker
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#6 Posted: 8/11/2009 20:14:23

I guess I should ask for my money back from my flight school because they told me that my dual training that I would be giving to my students would count towards the higher ratings and I have been telling my students that.

IF this is true about it not counting it really diminishes my rating of SP-CFI



Adam Smith
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#8 Posted: 8/13/2009 18:41:33

EAA's article is now up, too:

August 13, 2009 — Recently a reporter with an aviation news organization pressed the FAA on the subject of transferring a student’s flight-time credit earned during sport pilot instruction toward pursuit of a private pilot certificate. The FAA’s answer, issued just before the start of AirVenture 2009, rekindled concern within the sport pilot community about an apparent discrepancy between the sport pilot rule language on this matter and the intended outcome.

The FAA reiterated its position that not all training received from a flight instructor with only a sport pilot rating may be credited toward the subsequent pursuit of a private pilot certificate. The FAA cited language in the sport pilot rule specifying that, although a student may apply all solo time and total flight time received from a sport-pilot-rated instructor, the dual time with that instructor does not apply toward training for a private pilot certificate.

EAA and the sport pilot community have argued that these terms contradict the intent of the sport pilot regulations. “The intent was to create a category of personal flight that not only lowers barriers to participation but also serves as a stepping stone to higher certificates and ratings,” said EAA President Tom Poberezny.

Several EAA communications to the FAA have argued this point. In fact, EAA, the Aircraft Owners and Pilots Association (AOPA), and the General Aviation Manufacturers Association (GAMA) on June 9 submitted a joint letter asking the FAA to expedite a solution. Additionally, EAA and AOPA both previously filed responses to the most current FAA Sport Pilot Notice of Proposed Rule Making (NPRM), known as the “rule clean-up,” calling for all training with a sport-pilot-only instructor to apply toward the requirements of private pilot training.

“All sport pilot flight training is a directly applicable subset of the training requirements for a private pilot certificate,” said EAA President and Chairman Tom Poberezny. “Flight instructors with only sport pilot ratings have had to pass the same tests and meet the same standards within that subcategory of flight as private pilot instructors. For example, the instruction for turns around a point from either a sport pilot or private pilot instructor is the same. The dual instruction with the sport pilot instructor should apply.”

Poberezny added that this imbalance between the rule language and the original intent “unnecessarily creates perceptions of a subordinate class of instructors.”

The FAA is due to release a final version of revisions to the sport pilot and light-sport aircraft regulations in November. EAA has advocated and supported most of the anticipated revisions; however, EAA and the general aviation community are calling on the FAA to address this issue. EAA will continue to work toward including a provision that permits dual instruction time received from a sport-pilot-rated instructor to count toward higher certificates and ratings. If the matter is not addressed in the forthcoming final rule, EAA and other organizations are prepared to petition for a rule change.

 

 



Edward Clark
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#9 Posted: 8/13/2009 19:01:33

I hope that EAA will also press the point made above about those of us who credited ultralight training towards our Sport Pilot.  I have been working under the impression that I could apply all that training and subsequent flight time towards my private at some point.

since I am just shy of 500 hours now with 440 of that in a champ, my instruction time was divided with 35.5 from an ultralight instructor and 12.5 in the champ with a CFI.  It would seem totally riduculous for the FAA to say the quality of my instruction was not adequate. 



Patrick Panzera
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#10 Posted: 8/13/2009 19:12:18
Adam Smith wrote:
EAA's article is now up, too:

 

Yeah, I just noticed that.

It showed up in my mail box just after AOPA.

It's good to know that there are so many aviation advocates working on this for us.

Pat

 



Roger Bailey
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#11 Posted: 8/13/2009 21:41:42

It seems to me that a simple solution to the problem of logging flight time would be make the change that ANY flight time would qualify... FLying is flying... Just think all of this could have been avoided if the 'LSA' program had utilized the model noted by Van...lets make any private pilot certification linked to the driver's license. That way, all third class medicals would have reverted to that rule. Or at least those aircraft with fixed gear, under 200hp and 4 place to meet the requirement.  Just think of how many of those used aircraft...the affordable ones...would have spurred general aviation...

Wonder why that didn't happen??? Couldn't be the LSA market.....NAAA.

Drib
biggrin



Ray Boyles
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#12 Posted: 8/15/2009 20:01:50

Right on!   I have had my PP, ASEL, ASES, Instrument ratings for 30 years, have advanced college degrees, and have had many occasions to instruct students in industry.  Then I decided to get my SP-CFI rating several years ago because I thought that I had a lot of real-life and aviation experience and knowledge to offer a student   Great!, I thought.  So I now gave several hundred hours of dual to Sport Pilot candidates.  Now, with the official FAA ruling (which is unlikely to change) I see that my effort was probably all in vain and that I (and other SP-CFIs, should now quit instructing.   Why?  Becuse we HAVE to assume that every Sport Pilot student who comes to us for instruction may one day go for a higher rating and we will have done them an injustice by teaching them things that are of no value for higher ratings in FAA's eyes.   Therefore, the SP-CFI rating has been made useless by the FAA's lack of foresight! 

So, I must chalk up as a loss, all the time I spent instructing, as well as my own time and expense in getting my SP-CFI rating.   Of course, I could spend the extra time and bucks and go for the "real" CFI, by taking my commercial and CFI test by demonstrating  that I can really do lazy eights and chandelles in a "complex" airplane.  (Really, isn't that the only difference between a SP-CFI and a "real" CFI?? )   Shame on the FAA!   I've had it!  We can't fight "city hall".



Ray W. Boyles
Jerry Rosie
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#13 Posted: 8/16/2009 08:11:30

Ray,  I hope you are not serious about giving up instructing because you taught me some very valuable lessons.  After x numbers of hours of dual and at least three different instructors, I was still having trouble with steep turns.  You corrected all that with just a five minute explanation of what I was doing wrong.  You do have a lot to give to the Sport pilot student and many of them will NOT be going on to 'higher callings".  And no matter what the FAA says, the instruction you can give to Sport Pilot candidates is valuable and will save lives even if they may have to repeat some of it to get a higher rating.  Hang in there, please,

 



Cheers, Jerry NC22375 out of 07N
Ray Boyles
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#14 Posted: 8/16/2009 09:07:18

Jerry, thanks for the vote of confidence.  It is former students like yourself who learn and go on to become good pilots that make it all worthwhile for us instructors.  I think all CFIs will agree that seeing our students succeed is the best reward for our efforts.



Ray W. Boyles
Bob Meder
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#15 Posted: 8/18/2009 14:39:45

As a "regular" CFI, Ray, I am going to disagree with you.  Yes, there is a problem under part 61 wherein, for the Private rating, the word "authorized" derails things.  Certainly, the intent was for a Sport Pilot to be able to go on and "fill in" the requirements for the Private.  However, under the private pilot regs, a subpart "J" instructor is not authorized to provide training towards the private.  According to the person I spoke to from AFS630 when I was at AirVenture, FAA legal said that was a show-stopper. 

That's the bad news.  The good news is that none of the solo time disappears.  The requirement for the long cross-country has to be met, so a flight by a subpart "H" instructor needs to be authorized.  Of course, if the sport pilot training was provided by a subpart "H" instructor, then the time counts towards the private rating..

The better news is this - NONE of the training is wasted, no matter who provides it.  Think about it - if I get a well-trained sport pilot that is looking to advance his ratings, then my life, not to mention the student's, will be a lot easier:  "Show me a steep turn - OK, that takes care of that..." 

My understanding is that the FAA is struggling with this.  This went against their own intent.  I have been told that they are trying to address this in the re-write of part 61.   am also certain that htere is no one at the FAA that doesn't value the experience you provide. 



Bob Meder "Anxiety is nature's way of telling you that you already goofed up."
Jerry Rosie
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#16 Posted: 8/19/2009 08:00:58

 The better news is this - NONE of the training is wasted, no matter who provides it. 

That is exactly what i was trying to say in my post to Ray.  The training doesn't go away just because a differently rated instructor needs to sign off on it.  If a sport Pilot Instructor teaches me to do a picture perfect landing every time, I still know how to land an airplane whether or not the FAA recognizes the training.  The interpretation of the rule, however, seems a bit flawed in that all training and flight time in an Ultralight was initially recognized during the transition period.  Doesn't make sense that some similar logic shouldn't be applied to transition from Light Sport to PPL  But, then, I don't work for the government....

 

 



Cheers, Jerry NC22375 out of 07N
Ray Boyles
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#17 Posted: 8/19/2009 10:23:17

Bob and Jerry,

I agree completely with what you are saying, e.g. the training is never wasted on the student.  My complaint is that the 15+ hours of SP-CFI dual that the student paid for is not accepted by the FAA for additional ratings.  If a SP-CFI trained Sport Pilot decides to go for his Private Pilot (or commercial), he/she must get at least 20 hours of dual from a "regular" CFI. before he/she takes the practical test.  This translates into real dollars down the drain as far as the student is concerned.  As a licensed Sport Pilot, he already knows and has demonstrated the Private Pilot maneuvers, but he still must record the 20+ hours of dual (additional dollars) with a "regular" CFI before he can take his PP practical test.   And, as you CFIs know, the examiner WILL check that prerequisite "authorized" dual training was received.   By the way, I wonder if we now must record the type of dual (SP or regular) given to a student??   I guess we need another column in our logbooks.   See how ridiculous this is becoming?   The FAA MUST accept dual given by a SP-CFI or abolish the SP-CFI rating.  Until they decide, I am going to inform my students that any instruction I give them can't be used toward additional ratings.  I will also encourage them to get their training from a regular CFI.  



Ray W. Boyles
Jerry Rosie
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#18 Posted: 8/20/2009 07:37:31

Hi Ray -

I will give you an "A+" for integrety for advising your students that they will have to pay extra if they decide to go on to a PPL, but am glad that you have, apparently, decided to continue instructing.  You have much to offer.  The student can then decide whether or not they want to take training with you.  There are gonna be old fuddy duddies like me, who do not want to risk busting a medical, who will be very happy with a LSA ticket and you can give them much of value.

 



Cheers, Jerry NC22375 out of 07N
Ray Boyles
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#19 Posted: 8/20/2009 08:45:46

Some observations/possibilities that will make the FAA "cringe" :-)   (I love it!)

Since SP-CFIs are authorized to give instruction in LSAs in which they are qualified, then why isn't the following true??

BFRs:  FAA regs say that a pilot may take their BFR in any aircraft for which they are qualified.   Why can't a SP-CFI give an any licensed pilot (SP thru ATP) their BFR in a LSA??

Tailwheel endorsements:   Why can't a SP-CFI give any licensed pilot a tailwheel endorsement in a LSA??

These are probably some of  the areas that the FAA is concerned about, i.e,  giving the SP-CFI  too much leeway and credibility.    



Ray W. Boyles
Bob Meder
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#20 Posted: 8/21/2009 11:57:58
Ray Boyles wrote:

 

Some observations/possibilities that will make the FAA "cringe" :-)   (I love it!)

Since SP-CFIs are authorized to give instruction in LSAs in which they are qualified, then why isn't the following true??

BFRs:  FAA regs say that a pilot may take their BFR in any aircraft for which they are qualified.   Why can't a SP-CFI give an any licensed pilot (SP thru ATP) their BFR in a LSA??

Tailwheel endorsements:   Why can't a SP-CFI give any licensed pilot a tailwheel endorsement in a LSA??

These are probably some of  the areas that the FAA is concerned about, i.e,  giving the SP-CFI  too much leeway and credibility.    

 

Ummm, where does it say that a subpart K instructor can't give a flight review in an LSA to a certificated pilot of any rating? (Just a matter of being a pain, there are no licensed pilots in the U.S. goggles)

Also, I don't think it's a matter of the FAA "cringing".  I've worked with a lot of folks at the FAA at various levels and have had a positive relationship with them.  In this particular case, the folks I've talked to hate that this has come up and and recoginize the issues you're bringing up.  This actually runs into a problem wherein there is a conflict in the legal language that was not caught, specifically the phrase "authorized instructor" under the private pilot requirements.  To keep the application of the regulations consistent, they're forced to abide by their own words.



Bob Meder "Anxiety is nature's way of telling you that you already goofed up."
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