Easier is NOT Necessarily Better, BUT…

The FAA has made a bold move and dropped the requirement for a complex aircraft for the single-engine commercial and CFI tests. Dr. Donna Wilt, a professor at FIT in aviation and our SAFE representative on the ACS working group, alerted me to this change as it was being written earlier this week. We had heard hints of this when we met Brad Palmer at Sun ‘N Fun a few weeks ago. His team at AFS 800 was very concerned about the safety of our aging fleet of complex planes. To be clear the requirement in 61.129(3)ii for 10 hours of experience still is in place (only an NPRM process can change a regulation, and this has been pending for over a year). With a stroke of the pen however, the complex requirement in testing is gone.

So what does this mean for flight training and safety? For flight students there was a collective sigh of relief for reduced requirements and cheaper acquisition of their certificates. For older pilots there was a lot of justifiable grumbling about “lowering standards” and future safety implications. Obviously there is always a compromise between safety and proficiency in all our training standards but I think the recent Piper Arrow accident in Florida tipped the scales on this decision.

SAFE clearly stated our position on the proposed NPRM  changing comples standards in August 2016; lowering the training requirements is not commensurate with greater safety. But given grave concerns about the Piper Arrow wing spar issues, many flight schools are already operating under an FAA Waiver that eliminates the complex requirement. Why should Part 61 candidates not have this same relief from this regulation for a complex A/C on tests?

Pilots in training will inevitably seek the easiest and cheapest pathway to their certification. But those pilots who truly value safety and proficiency will go  further and seek out tail wheel, glider and other categories to build additional skills and proficiency. (Witness the recommendations from senior aviators at the NTSB LOC Roundtable yesterday.) Our job at SAFE is to inspire, encourage and enable the latter pathway; toward the voluntary pursuit greater proficiency and aviation excellence. We continuously work with the FAA to achieve reasonable solutions. We have all seen pilots that despite regulations, cut every corner and take the “low road” satisfying every requirement. Join and support SAFE to inspire and enable aviation excellence and professionalism. Your thoughts?


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Author: David St. George

Master CFI, 141Chief Instructor, FAA DPE, ATP (ME/SE)

3 thoughts on “Easier is NOT Necessarily Better, BUT…”

  1. David,
    Thanks for the update on the latest reduction in training standards. I understand the issues related to cost and maintaining an ancient fleet of training aircraft. I think you are correct that the recent Florida accident tipped the scales, even though we do not know if this tragedy was caused by aging aircraft issues or by improper maintenance.
    Count me among the grumpy old instructors who think this is a bad idea. As pilots climb the ladder to more and more complex equipment, the transition to complex aircraft is a significant marker. Checklist integration and procedural discipline have never been as important, in a very immediate sense, as they become with retractable landing gear operations. Moving into aircraft where a failure in these disciplines results in an immediate and expensive outcome at the very least, requires more of the pilot/student. It’s a peek into the consequences of “real world” operations and the massive responsibilities they entail.
    So removing the requirement to test these levels of development on FAA practical tests, which as you know reduces or eliminates their emphasis during training, does more damage than merely depriving the student of practice moving the gear lever up and down. Removing this testing requirement removes an entire level of learning, a rung of the ladder, if you will. Where will pilots get this missing level of adaptation, during part 121 IOE with a load of passengers in the back?

    1. Yes, Charlie I am also personally not supporting this reduction in standards. Like you, I often sit in the left seat with increasingly unprepared novitiates climbing aboard to pilot. It is inconceivable they might never had flown a retract and now are qualified to fly customers. I see this train accelerating downhill but not sure where we are headed (or if anyone is providing direction). The impulse to make flight training easier and cheaper is everyone’s desire but it cannot be supported by a decrease in safety.

  2. I heard that this might be coming. I do believe we are entering the age of “politically correct flight training”. I still believe spins should be taught and required pre-solo.

Tell us what *you* think!