In February, the
FAA proposed some 50 pages' worth of clarifications, changes, and updates to
Part 61 and 141 regulations governing pilot training and certification. AOPA
immediately unleashed its professional staff, called in the AOPA Air Safety
Foundation, and asked AOPA members to analyze the proposal line by line.
"Some of what
the FAA wants to change would cost students and existing pilots more money with
no safety or training benefit, some 'clarifications' just made things more
unclear, and some actually would be improvements," said Rob Hackman, AOPA
senior director of regulatory affairs. "In our 12 pages of
comments, we've made sure that the FAA understands the negative and
positive impacts of the proposed regulatory changes."
AOPA's most
significant concern is over a proposed change to the instrument currency
requirements. The FAA wants to add requirements for both precision and
nonprecision approaches; holding patterns at "radio stations,"
intersections, or waypoints; one-hour of cross-country flight; and a
missed-approach procedure within the previous six months for a pilot to remain
instrument current.
"These
requirements don't reflect real-world flying experiences, nor do we see how
they would contribute to improved safety and instrument proficiency," said
Hackman.
AOPA recommended
that most of the regulations governing instrument currency remain unchanged.
The FAA also proposed
changes that would allow pilots to use flight training devices (FTDs) and
personal computer aviation training devices (PCATDs) to meet instrument
currency requirements.
The idea is good,
said AOPA, but the agency is proposing onerous hour and task requirements that
go well beyond what's needed for maintaining currency. "We believe that
these requirements should mirror those currently required when using an
aircraft to meet instrument currency requirements," AOPA said.
The agency wants to
require a "view-limiting device" for pilots using a PCATD for credit
toward training hours required for an instrument rating. AOPA opposed that,
since all types of flight trainers already simulate instrument flight.
The FAA also
proposed changes that AOPA found positive, including extending the duration of
student pilot certificates to coincide with the duration of the medical
certificate.
And AOPA
recommended an additional change to Part 61. The association once again
proposed that the agency replace the medical for a recreational pilot
certificate with a "driver's license" requirement to meet the medical
standard, just as the agency has done for sport pilots.
Noting that the FAA
has said that medical conditions are not a significant cause of accidents in
aircraft used for sport and recreational purposes, and that recreational pilots
are limited to day VFR only in lower performance (180 horsepower or less)
aircraft carrying only one passenger, AOPA said that the FAA should "take
the next logical step" and extend the driver's license medical to pilots
exercising recreational pilot privileges.