Here are our official comments on FAA-2008-0938.
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"FAA is moving in the right direction with the proposed changes to pilot certification.
Chickasha Wings received its initial provisional Part 141 Certificate in May 2009. The certificate is Private Pilot only and we plan to add Instrument and Commercial ratings as our school develops.
Internet-based training: How many operators would take advantage of this proposed provision: Since we are new, we recently remodeled a dedicated training room to meet these requirements. With this proposed change, we will likely renew our TCO to include a part 141-approved web-based training program. Since we will be upgrading our TCO for other purposes, the cost to add internet based ground instruction should be none.
Replace the complex experience requirement with advanced instrument training: We plan to take advantage of this proposal. The complex requirement has been a major barrier to many pilots obtaining the commercial rating. We have five airplanes, two Cessna 150s, a Cessna 172, an Ercoupe for Sport Pilots, and a Piper twin. (Only one C150 is currently on our 141 certificate). We recently completed a students first Commercial in our twin in order to comply with the complex requirement. He had to take two check rides about a week apart, Private ME add-on, the Commercial ME. These are nearly the same check ride. We also had to fulfill all the commercial requirements in the twin which I think did not add much value. The change will solve this problem, and we will not be tempted to use our twin for commercial ratings, but for ME add-on rating instead.
Will a complex aircraft be needed for the commercial and/or CFI checkrides? Would complex then become just an endorsement like performance and not required on check rides?
Combined Private/Instrument Check-ride: Will part 61 students want to move to 141 to take advantage of the 70 hour requirement? I think foreign students and some career students may want to change to 141 for the reduced hour requirement. However, this is a lot of material to cover in 70 hours, and if the same rating is available to part 61 students in 80 hours, I would assume most would go that route; less regulation and more flexibility.
Will the 50 hour cross-country requirement for Instrument Rating go away?
Since we are already planning to add in Instrument TCO, we will likely work toward the combine Private/Instrument.
Overall Costs: I think these pilot certification changes are beneficial to Chickasha Wings and our clients. They ease the path to commercial rating and initial CFI and allow internet based ground training."