Unicom

August 2018 Issue




Are You Experienced?

I found the Learning Experience in June’s issue (“Remember Your Training”) a little alarming. The writer says he had “recently been checked out” in the FBO’s Cherokee, a plane in which he “may have had a total of an hour of dual instruction (the implication is that he had less).

This sounds like malpractice on the part of his FBO and possibly flight instructor. How can a student pilot in primary training with about 20 hours get “checked out” in a different aircraft with that little training? I remember that being approved for solo flight in my FBO’s 172 was a big deal, like it is for most students: you do some landings with the instructor, then he or she gets out and tells you to do it yourself while observing from the ground, something that apparently didn’t occur in this case since the instructor was with him for that sole hour of dual. I’m even wondering how the student’s insurance company would have covered him (or if he was covered at all...).

The point of the letter was to remember one’s training, but in this case, the point should have been whether he should have taken the airplane at all. Twenty-hour students, outside of the military, should probably not be training in more than one aircraft. 

Scott Cole
Via email

Another One

In the “Water, Water Everywhere” Learning Experience (July 2018), the writer shares an experience on a 100-mile solo cross-country while a student pilot. Nowhere in the article does he mention having his preflight planning approved and endorsed by his flight instructor. FAR 61.93 would absolutely require this for the flight. The most important lesson in this article should be for FBOs, instructors and student pilots to follow the rules. They are there for a reason. 

Steve Lehr 
Bellevue, Neb.

Thanks to you both for the comments. Please be aware that we edit Learning Experiences submissions, including for style and length. In this instance, we know that both of these experiences occurred some time ago, when industry standards and the FARs were different. Neither FAR 61.87, addressing student solo flights, nor FAR 61.93, dealing with student solo cross-countries, were as detailed as they are now. That said, the FAA does not require a minimum number of flight hours in an aircraft type before a student pilot may solo it. A one-size-fits-all approach simply doesn’t work, and that discretion (we believe) is properly left to the flight instructor endorsing the student to solo.

Commercial Complex

It’s interesting that the FAA is eliminating the need for a complex airplane for commercial airplane and CFI-A checkrides because “there are far fewer SE complex airplanes....” But the requirement for 10 hours of complex time for the commercial certificate has not changed, which appears to be contradictory at first glance. It is easily explained because changing ACS/PTS requirements are relatively easy through an administrative change. However, changing regulations is much harder, requiring an NPRM (notice of proposed rulemaking).

The language of FAR 61.129(a)(3(iii) is a bit vague if a multi-engine airplane can be used for the 10 complex hours for a commercial SEL. The answer is yes, and FAA Legal provided that clarification on February 13, 2013. Of course, most GA multi-engine airplanes are complex; the only exception that comes to mind that would not qualify is the fixed-gear Cessna 336 SkyMaster.

Luca F. Bencini-Tibo
Weston, Fla.

Your timing is perfect. As this month’s Quick Turns department highlights beginning on page 22, the FAA in late June finalized new rules making substantial revisions to the FARs, including Part 61. One of the major changes involves allowing the use of a simulator to maintain IFR currency without the need for a flight instructor to be present. The new rules also will amend FAR 61.129(a)(3)(ii) (commercial pilot aeronautical experience) to read, in part: “10 hours of training in a complex airplane, a turbine-powered airplane, or a technically advanced airplane (TAA)...or any combination thereof.” The new rules, which go into effect this summer, also expand the definition of a “technically advanced airplane” and tweak the sport pilot rules. See the article beginning on Page 22 for additional details, including the new definition of a TAA.