[Peetwo]

wren 460 off the UP -

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Independent instructors US style, AOPA policy doc.

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AOPA Aus has a policy discussion paper written by an AOPA Director Mike Smith.
This could be the single most important area of reform if General Aviation is to recover and actually start to grow sustainably.

Whatever else is true about GA without new pilots constantly coming through there can be no home grown flying industry. In the past there were hundreds of small flying schools scattered all over Australia. Naturally those living in rural areas have very direct benefits from using GA aircraft and hence those flying schools that could be found in every region.

We had to obtain a permission, a cost free licence with virtually no special conditions apart from an approved training area map.

As a “B” grade instructor (for some irrational reason grades A, B and C Ins. Rating became 3, 2 and 1) I was automatically deemed fit for Chief Flying Instructor. After my application a couple of DCA types came from Melbourne told me to be a good boy and my charter licence was amended to include training.

So why is it now that a senior instructor near to me had to put up front $8000 with a flying school application? (2 yrs ago and still nothing)

This is just madness and the latest tranche of flying school regs are going to cause more closures before the transition deadline, August I think.

So what’s necessary, the paper attached shows how simple it can be if we take on the US rules. A very well written paper that if even partly adopted would put GA back in the air and create that turn around that is desperately needed.

Discussion Paper: Independent Flight Instructors


Background

Australia has experienced a decline in active pilot numbers and in new trainees that is impacting the aviation industry at all levels. Traditional flight schools are struggling to meet the requirements of CASR §61 and this has led to an increase in the cost of training and virtually excluded small schools from the market. In regional Australia, where Aero Clubs once flourished, flight training is almost non-existent. In addition to the fees charged by CASA to process applications, applicants endure significant compliance and related costs during the certificate life-cycle.

A global shortage of airline pilots has resulted in airlines in the major markets such as North America and Europe cancelling flights caused by the inability to source adequate numbers of qualified personnel. There is an urgent need to address the global demand for trained pilots that could be met by Australian flight instructors.

ICAO

ICAO Annex 1 outlines the Standards and Recommended Practices for Personnel Licensing, including pilot licenses. Annex 1 provides for training by authorized instructors working as individuals or providing training as part of an approved course.

CASA’s implementation of Annex 1 standards does not allow for instructors to work outside of an approved school. Australia therefore has flight schools individually authorized by CASA under CASR §61 or §141.

FAA

There are three flight instructor certificates available in the USA. These certificates are commonly referred to as: Certified Flight Instructor (CFI), Certified Flight Instructor Instrument (CFII) and Multi Engine Instructor (MEI). All are stand-alone certificates i.e. there is no requirement to hold any one instructor certificate before you can hold any of the others.

Although flight instructors can and do work independently, most work for a flight school that may or may not hold an FAA §141 certificate. As an example, ATP with over 300 aircraft, 300 instructors, 42 locations and delivering about 190,000 hours of training annually do this under §61. It is estimated that 70% of pilots are trained under §61. For those schools wishing to be certificated under §141, the process is relatively straightforward forward with the FAA providing templates for the required manuals and processing the application with no fee attached.

A flight instructor need only hold a class three medical certificate since the FAA views the service a flight instructor is being paid for is their teaching services, not their piloting services. If the student is legally entitled to be the pilot in command, the flight instructor need not hold a medical certificate at all. An example of this is an instructor teaching a commercial student who already holds a private certificate, the student is entitled to be PIC and therefore the instructor does not require a medical. Similarly, for a Flight Review, provided the candidate has a current medical and their Flight Review currency has not lapsed, the flight instructor conducting the review need not have a current medical. There is no requirement for the FAA to be notified that a Flight Review has been conducted.

There is no need to go to a §141 school for any training for a pilot certificate or rating. Even flight instructors can be trained by other flight instructors under §61. The only limitation is that an instructor must have held an instructor certificate for 2 years and have given at least 200 hours of flight instruction before they can recommend an applicant for their first instructor certificate. Even this limitation is currently the subject of a discussion paper that proposes to remove this requirement.

The situation is similar for mechanics who can perform most maintenance without working for the holder of a §145 certificate. Certificated A&P mechanics can perform most of the maintenance required to be performed on flight school aircraft and holders of Inspection Authorizations can certify for annual inspections. These activities do not require FAA certification beyond the individual’s certificates.

PROPOSAL

Adopt the FAA interpretation of ICAO Annex 1 and permit authorized flight instructors to provide flight training for any CASA pilot license without the need to hold or work for the holder of a CASA flight school certificate. During a transitional period, grant existing holders of §61 flight school certificates provisional §141 status.

Implementation

CASA would seek the repeal of those sections of CASR §61 that require an operating certificate for individuals or organizations that provide flight training. CASR § 141 would remain to allow for schools to take advantage of the reduced training hour requirements that ICAO Annex 1 provides for when undertaking training as part of an approved course.

CASA would continue to make regulations that give specificity to ICAO training standards such as the minimum aeronautical experience required for each license as well as the knowledge requirements to be met. Instructors would be required to ensure that all required training is completed before students may progress to solo for example, and prior to being recommended for a flight test.

Other Considerations

Existing flight schools often express concern that the independent instructor system would undermine their business. In contrast to the Australian experience, the FAA process to gain a §141 pilot school certificate is straightforward and in-expensive, CASA should follow a similar, simple and affordable process. In transitioning to the new arrangements, existing CASA certificated flight schools under §61 should be granted provisional §141 status and then have two years to meet the applicable requirements for a pilot school certificate (non- provisional).

Some believe that safety is compromised however, this is not supported by FAA experience.

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MTF...P2