Earlier this week I was conducting a CFI renewal with a very experienced charter pilot getting back into flight instruction. What came up in the discussion was a consensus opinion that 121/135 regs, though burdensome, can provide great cautionary ideas for Part 91 safety. This was seconded later in the week by an Aviation Safety Mag article. Extra care, extra training, all provide a great buffer from “regulatory minimums.” Unfortunately, many pilots still seem to follow the shocking FAA minimums available in part 91 as “operational guidance.” Who would do a zero-zero take-off or a “look-see” approach? Demonstrating a margin above minimums (and teaching the same) is critical for safe flying.
The ACS is carefully constructed so flight tests look for exactly this procedure in all pilot candidates. Every applicant must know the FAA minimums but also demonstrate their personal margin of safety above and beyond these minimums. If “one statute mile, clear of clouds” is your personal minimum, you better have some good justification to support your risky behavior.
The diagram below was developed by David Bowden when he was with US Air and was disseminated more widely later when he ran the Rochester FSDO, then FAA Eastern Region. This was 30 years ago and this paradigm (combined with extensive CRM and other operational changes) helped create the amazing safety record in the major airlines over the last 20 years. Demonstrating and teaching safety margins must be part of every flight lesson.
The second half of creating greater safety is bringing everyone into compliance with this viewpoint of “safety culture!” As pilots, we are very protective of personal freedoms. Piots almost religiously defend every other pilot’s right to their own personal methods and standards (and some wild flying is increasingly popular on YouTube). But we have an obligation, when it comes to people potentially hurting themselves and others, to help rehabilitate “rogue pilots,” and bring them around the campfire of “safe operations.” I again cite Dr. Bill Rhodes and his “Scary Pilots” pdf here. The two questions he highlights at seminars make this clear: “Who has lost a friend in a flying accident?” followed by “Who was really surprised this happened” makes clear our obligation. Please spread the safety message… fly safe out there (and often)!
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Just a thought… your flight was a commercial flight, because something of value was taken and given. This type of flight use to be Part 91 under instruction because instruction wasn’t a commercial operation. You both hold commercial certificates. However, if you landed at an airport other than the on you started from, it was a 135 commercial operation. Did you operate under a Part 135 certificate?
Just another weird thought about the new definition of commercial flight under the recent court ruling.
Yes, don’t get me started… I fly charter almost every week and very thankful he qualify for a first class medical. Under the new “FAA Reinterpretation” will CFIs require commercial level medicals? Will we be subject to new liability concerns? Please support the AOPA-sponsored bills in Congress.
14 CFR 119.1(e)(3). Part 119, and hence parts 121, 125 and 135, do not apply to training flights. Note this does not say training flights are not commercial flights for hire.
Don’t go crazy about the reinterpretation. The sky is not falling. There is a change you have to deal with. Overstating the effects makes you noise, and you will cause the rest of us to get ignored along with you.
As instructors, we have an obligation to get this right. Just like the often misstated status of a DPE giving an exam (they ARE a passenger, but the passenger-carrying rules do not apply by 14 CFR 61.47(c)).