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View Full Version : Independent instructors US style, AOPA policy doc.


Sandy Reith
14th Apr 2018, 07:42
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.

27/09
14th Apr 2018, 10:09
It's not just the US that does it that way. Here in NZ it's pretty much the same as the US except our Instructors are classified A, B, C which loosely equates to your 1, 2, 3.

Sandy Reith
14th Apr 2018, 10:36
It's not just the US that does it that way. Here in NZ it's pretty much the same as the US except our Instructors are classified A, B, C which loosely equates to your 1, 2, 3.

No doubt your training environment is much easier to work than ours. How do you differ to the US in the medical requirements? From the AOPA paper it would seem that US instructors have a very practical set of rules in this area.

Its really nuts that we cannot have a sensible regulatory regime. Too bad we have not had any government prepared to take on the bureaucracy.

Thank you for your information, its really important for Can’tberra to see how it can be done in a reasonable fashion.

Ozgrade3
14th Apr 2018, 11:03
I don't think CASA would ever allow instructors to work giving lessons in a private C172 out of a farm stip. How can anyone fly a plane without a 3000 page ops manual, 20.11 checks, profioncy checks, sign off, paperwork that could sink a ship. Shoot, before I have a pee I have to look up the current "approved method".

True or False question.

Did CASA once NCN a balloon company because the onions at the BBQ with the customers were not cooked in the manner specified in the ops manual.

Sandy Reith
14th Apr 2018, 11:44
Ozgrade3. Plenty of C172s, 182s etc were sold to rural property owners. Schutts at Moorabbin for example. John Correll when employed by Schutt’s used to fly a newly purchased aircraft to a farm, declare a training area and stay for about three weeks teaching the owner to PPL. John went with his own advanced training school and would speak of those days when GA was growing quickly.

I take my hat off to the modern day instructors and flying schools, towards the end of my own time as instructor and flying school owner the ridiculous paperwork was just starting.
No one would really object if there was good reason and better results but we all know that, if anything, the opposite is true.

Dick Smith
14th Apr 2018, 17:09
Remember the present CASA legislation makes it clear that the most important consideration must be safety and it makes no mention of cost.

Yes CASA claim that they also look at cost. But safety must come first.

That is total industry destruction comes first.

Remember these people have successfully fought for over 20 years to keep this wording.

Tinstaafl
14th Apr 2018, 19:51
Something that isn't mentioned about FAA instructors: The FAA monitors instructor's student pass rates for Part 61 training. If too many candidates recommended by an instructor fail to pass at 1st attempt the instructor can lose his or her instructor certificate, be required to get remedial training, or be required to be retested. This takes the place of an authorised/licenced/certificated/whatever school's pass rate monitoring eg a Part 141 school, or a commercial or higher school in Oz

27/09
14th Apr 2018, 21:44
No doubt your training environment is much easier to work than ours. How do you differ to the US in the medical requirements? From the AOPA paper it would seem that US instructors have a very practical set of rules in this area.

Yes , the FAA has a very practical approach.

I think our medical requirements are more like yours. Unfortunately we have an Aussie as the head of the CAA medical section. There's not even been any move on the PPL medicals as has happened in the US/UK and I think even Oz.

The FAA monitors instructor's student pass rates for Part 61 training. If too many candidates recommended by an instructor fail to pass ......

Once again the FAA have a very effective, cheap, practical and unencumbered way of doing things.

Sandy Reith
14th Apr 2018, 23:41
[QUOTE=Tinstaafl;10118491....The FAA monitors instructor's student pass rates for Part 61 training.

Doubt if DCA/CAA/DoT/CASA (changed its spots in name only, though let of the leash, becoming independent ‘88) ever had a structured monitoring system.

If too many candidates recommended by an instructor fail to pass at 1st attempt the instructor can lose his or her instructor certificate, be required to get remedial training, or be required to be retested. This takes the place of an authorised/licenced/certificated/whatever school's pass rate monitoring eg a Part 141 school, or a commercial or higher school in Oz[/QUOTE]

Often overlooked by our old top down, or pecking order, mentality is the fact that the other half of the training equation is the trainee. A fairly important half.

If we are to increase our freedoms and find better outcomes we should recognise that with the information revolution centralised information through government agencies (of course “Authorities” in Oz) is not now a virtual monopoly.
In other words private reviews and reputation will inform the “market.” I.e. the individuals choosing a school or instructor.