In response to NPRMFAA–2008–0938regarding “Pilot in Command ProficiencyCheck and Other Changes to the Pilot and Pilot School Certification Rules” SAFE submitted a five-page response. The response is a compilation of comments provided by SAFE members.[link to PDF]
SAFE Responses to NPRM FAA 2008 0938
Previous post: PAT KNIGHT’s Master Instructor Renewal
Next post: FAA Releases New Instrument Practical Test Standards
{ 3 comments… read them below or add one }
Thank you for submitting these comments on behalf of the SAFE Membership. This response is thoughtful and touches on the key issues and concerns for these proposed changes.
A wonderfully crafted response to this NPRM! I am so proud of my organization here. The distinction between mechanically and technologically complex is astute and should be addressed in any further rule making. We will see what happens, John Lynch has this proposal on “greased skids” toward approval.
The focus of this change is entirely contrary to safety. Essentially they are changing the rule to make it “easier and cheaper for flight schools and for students.” The resulting reduction in necessary skills and hence safety is not addressed! Perhaps we will have FOs that never operated folding gear? an increase in gear-up landings on CRJs? The whole industry is in a panic to get more pilots started but the trend of “lowering standards to make more pilots” is counter-productive in the long run. Witness all the “shake and bake” pilot academy graduates screwing up in airliners now. (Please don’t make me fly on an airliner!) Thanks for your great work here!
Excellent response to the points in the NPRM. We need, however, to address the overall question of “What is the meaning of the Commercial certificate?” It should not be a written test and some lazy eights…
The FAA was exceptionally wise to promote the Instrument Rating earlier. It needs to go further now, and make the Instrument Rating a prerequisite to the Commercial. We are no longer living in the thirties. No passenger carrier would hire a pilot without an instrument rating.
We need to get ahead of the current move in the press to require the ATP for all 121 pilots. We need to make the Commercial relevent again. There is no reason to keep young pilots in flight instructor/banner towing/skydiving for 1200 hours. After a summer of flying jumpers, you aren’t going to learn much more.
I don’t know the answer. Perhaps upping the Commercial ticket to 500 hours. The Commercial should include at least a taste of everything the pilot will see flying the line. I like adding the high dive (high altitude endorsement) to the Commercial. Require a spin endorsement of the Commercial candidate. He or she will need it for the CFI anyway. That would address the concerns of the Buffalo families. Add questions about turbines to the written test.
If we don’t get ahead of the swell, the wave is going to crash on us.
Robert
You must log in to post a comment.