Proposed FAR Changes

MidlifeFlyer

MidlifeFlyer

Well-Known Member
I cross-posted this here and in the CFI Corner.

The FAA issued a proposed rule this morning. It deals with a number of training, instrument currency and one logging issues. It can be read at http://1.usa.gov/2203vVS.

If interested, I put together a summary on one of my Facebook pages

One of the interesting proposals from a CFI standpoint is yet another reversal of the FA's position. This proposal includes returning the authority of a CFII without the applicable CFI-Aircraft rating to teach instruments.

An interesting proposal for those heading for careers is permitting a copilot to log SIC time in a Part 135 operations even if the regs do not require an SIC. That is a reversal of the FAA's permission and is, I think designed to reflect the reality of the 135 operating world.
 
The since 91k can do it, why shouldn't 135. They "pay to play" concern is moot. The real concern is pencil-whipped training and ensuring safety really is increased.
 
MidlifeFlyer said:
I cross-posted this here and in the CFI Corner.

The FAA issued a proposed rule this morning. It deals with a number of training, instrument currency and one logging issues. It can be read at http://1.usa.gov/2203vVS.

If interested, I put together a summary on one of my Facebook pages

One of the interesting proposals from a CFI standpoint is yet another reversal of the FA's position. This proposal includes returning the authority of a CFII without the applicable CFI-Aircraft rating to teach instruments.

An interesting proposal for those heading for careers is permitting a copilot to log SIC time in a Part 135 operations even if the regs do not require an SIC. That is a reversal of the FAA's permission and is, I think designed to reflect the reality of the 135 operating world.
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Good summary! In my opinion, the Part 135 SIC rule modification should have happened at the same time that the 1500 hr. ATP mins rule came into effect . . . allowing low-time commercial pilots to gain remunerated SIC first-hand 135 ops experience in the same type of complex/higher-performance airplanes that they will be flying PIC once they meet 135 VFR/IFR mins is a practical way to prepare them for their eventual transition to airliners. Thinking ahead and coming up with new/revised ways for entry-level pilots to get the training/experience needed to meet the new reqs then would have certainly saved the industry from having to scramble crazy mad right now to convince enough youngsters and potential returnees to step up and get the mandated flight time experience in order to fill the current/future demand for ATPs . . . guess common sense is not a beloved concept at some of our gov agencies :rolleyes:
 
Ditto to the above. These changes would've been a boon last year when I was unemployed, in 40k debt, at 211 hours and not getting a single call back.

Also, if they change the rules regarding CFII privledges , then I'm definitely going to get that cert, as I could do it for under 1k.
 
If the comment period ends on August 10th, when would these take effect (I saw the 30,60 and 180 day interval but when does that period start)?

Wondering if I should start working on my CFII .
 
RamRise said:
If the comment period ends on August 10th, when would these take effect
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No one knows and it is very hard to predict. It depends on a lot of things including things related directly to the proposals like how extensive the comments are and what they say to other FAA priorities. And sometimes, the comments raise so many questions that the FAA changes the proposal for additional comment. It can be a long and ugly process.

For example, a Part revision of about the same size was done in 2009. That's the one that, among other things forgot to include the revision about logging device time without a CFI and included the rule that stopped CFIIs with no CFI-Aircraft rating) from teaching instruments. It thinks it went pretty smoothly but, the proposed rule was published in February 2007. The final rule was published in August 2009, more than two years later. And it went into effect in October that year.
 
MidlifeFlyer said:
No one knows and it is very hard to predict. It depends on a lot of things including things related directly to the proposals like how extensive the comments are and what they say to other FAA priorities. And sometimes, the comments raise so many questions that the FAA changes the proposal for additional comment. It can be a long and ugly process.

For example, a Part revision of about the same size was done in 2009. That's the one that, among other things forgot to include the revision about logging device time without a CFI and included the rule that stopped CFIIs with no CFI-Aircraft rating) from teaching instruments. It thinks it went pretty smoothly but, the proposed rule was published in February 2007. The final rule was published in August 2009, more than two years later. And it went into effect in October that year.
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Shucks, this was almost gonna make a difference in my life.
Atleast the guys coming up in the future will have more options to get experience.
 
USMCmech said:
Just to be completely annoying avgeek.....



The Cirrus does have a constant speed prop. It just does not an independent prop control.
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You are, of course, correct.
geek-300x300.jpg
 
Roger Roger said:
Ok, cool, now we get guys without an MEI yanking engines in twins. That's a good idea.
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That was going on for many years before 2009. Well, sort of.

I'm assuming the post-reg limitations would be the same as before 2009:
  • The CFII must have a multi rating on his pilot certificate.
  • The instructional activity may only cover instrument tasks. And yes, that means a single-engine approach, but
  • The "student" must already be multi-rated and so presumably knows how to handle flight on one engine.

I suspect in the real world we are not going to see much in the way of CFIIs without an MEI giving primary instrument instruction in a multi. I'd guess by the time most pilots are working on the AMEL rating, they already have their instrument rating in a single and get multi instrument privileges as a result of their AMEL checkrides. What we probably will see is primary instrument training to private ASEL pilots, with, for the most part, the multi issue limited to IPCs.
 
MidlifeFlyer said:
That was going on for many years before 2009. Well, sort of.

I'm assuming the post-reg limitations would be the same as before 2009:
  • The CFII must have a multi rating on his pilot certificate.
  • The instructional activity may only cover instrument tasks. And yes, that means a single-engine approach, but
  • The "student" must already be multi-rated and so presumably knows how to handle flight on one engine.

I suspect in the real world we are not going to see much in the way of CFIIs without an MEI giving primary instrument instruction in a multi. I'd guess by the time most pilots are working on the AMEL rating, they already have their instrument rating in a single and get multi instrument privileges as a result of their AMEL checkrides. What we probably will see is primary instrument training to private ASEL pilots, with, for the most part, the multi issue limited to IPCs.
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Well, at that point, why bother? I've always held the position that it's not unrealistic to expect that someone giving instruction toward a multiengine rating (including instrument multiengine) have a certificate for instructing in multiengine airplanes.
 
Roger Roger said:
Well, at that point, why bother? I've always held the position that it's not unrealistic to expect that someone giving instruction toward a multiengine rating (including instrument multiengine) have a certificate for instructing in multiengine airplanes.
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People are obviously going to disagree on a few of the proposals. Personally I always thought that the old Part 61 FAQ was a little weird in saying such things as a CFII with no MEI can't give training in one-engine failure during takeoff but can give instruction in single-engine operations under instrument conditions. But I guess no history of problems is no history of problems.

The "why bother"? Who knows. The Chief Counsel's office and Flight Standards battled over this for a long time. In 2009, the Chief Counsel won and Flight Standards amended the rule to "clarify" it was not permitted. Now, they are turning it around to what Flight Standards apparently wanted to begin with. Crystal ball (which has never worked that well) says the public comments submitted will have some real effect on which way it ends up.
 
gotWXdagain said:
Show me the reg that defines the meaning of "Rest" for the purposes of having 10 hours within the previous 24.
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135.273

Rest period means the period free of all responsibility for work or duty should the occasion arise.


It's been clear since the mid 90s. Operators chose to ignore it and multiple letters of interpretation. It's an enforcement issue.
 
Roger Roger said:
Well, at that point, why bother? I've always held the position that it's not unrealistic to expect that someone giving instruction toward a multiengine rating (including instrument multiengine) have a certificate for instructing in multiengine airplanes.
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Yeh I dont meet many CFIs with their MEI, kinda cheapens the certificate. I got the PPL AMEL so that my CMEL addon hours were PIC - surely its a good way to get to 50+ hours.
 
mojo6911 said:
135.273

Rest period means the period free of all responsibility for work or duty should the occasion arise.


It's been clear since the mid 90s. Operators chose to ignore it and multiple letters of interpretation. It's an enforcement issue.
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Shops get around that in two ways:

1- That reg is buried in the flight attendants section.

2- "Our pilots can always call fatigue"
 
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