No more complex for Commercial?

[TMetzinger]

this just in...

On August 31, 2009, FAA published a notice of proposed rulemaking (NPRM) in the Federal Register. The NPRM recommends several changes to pilot, flight instructor, and pilot school certification rules under the Code of Federal Regulations (parts 61, 91, and 141). The proposed changes reflect advances in aircraft design and avionics, pilot training, and international agreements. Among the 16 proposed rule changes is requiring a § 61.58 pilot-in-command (PIC) proficiency check for single-piloted, turbojet-powered airplanes; the ability of applicants to apply for and be issued a private pilot certificate and instrument rating concurrently; and a proposal for replacing the 10 hours of complex airplane training at the commercial pilot certification level with 10 hours of advanced instrument training.
The NPRM represents the potential for several safety benefits. According to John D. Lynch, of the FAA Certification and General Aviation Operations Branch, replacing the required 10 hours of complex airplane training with 10 hours of advanced instrument training “allows students to use their time more efficiently and gives them experience with more useful instrument flight training.” Lynch adds that flight schools would save by not having to keep an inventory of two kinds of airplanes (i.e., complex and non-complex airplanes) to meet the commercial pilot and flight instructor certification requirements.
To see the proposed changes, as well as to send any comments, go to www.regulations.gov and search for FAA-2008-0938. Comments must be received on or by November 30, 2009.

Since nobody's really making new retractable piston singles, this strikes me as a good idea.

 

[Ted]

Commercial is about showing you have better mastery of the aircraft, and are a good enough pilot to get paid to fly. To me, the complex is part of this. I'd rather see it kept in there.

 

[gprellwitz]

Since nobody's really making new retractable piston singles, this strikes me as a good idea.

Don't tell Andrew with his Matrix!

Commercial is about showing you have better mastery of the aircraft, and are a good enough pilot to get paid to fly. To me, the complex is part of this. I'd rather see it kept in there.

I'm fine with the removal. Being able to use all the functionality in a TAA aircraft also shows mastery of the aircraft, and is more in keeping with what is being produced today. Think Corvalis, Cirrus SR-22, etc.

 

[TMetzinger]

Commercial is about showing you have better mastery of the aircraft, and are a good enough pilot to get paid to fly. To me, the complex is part of this. I'd rather see it kept in there.

The complex endorsement should cover mastery of the retractable gear system - I don't think it should be a checkride/certificate item.

 

[Ted]

The complex endorsement should cover mastery of the retractable gear system - I don't think it should be a checkride/certificate item.

Point taken, but I don't think that a complex endorsement shows mastery, just competency. We know that all certs are more licences to learn, so a commercial applicant won't necessarily be perfect, but there's a good sum more going on with a complex aircraft in various critical phases of flight than in a fixed gear single, especially something like a Cirrus where the prop and throttle are handled by a single lever.

I suppose I'm being a crochety old man here, removing the requirement wouldn't necessarily bother me, but I'd be fine with it staying.

 

[Greg Bockelman]

Point taken, but I don't think that a complex endorsement shows mastery, just competency. We know that all certs are more licences to learn, so a commercial applicant won't necessarily be perfect, but there's a good sum more going on with a complex aircraft in various critical phases of flight than in a fixed gear single, especially something like a Cirrus where the prop and throttle are handled by a single lever.

I suppose I'm being a crochety old man here, removing the requirement wouldn't necessarily bother me, but I'd be fine with it staying.

Well, Ted, to stir the pot a bit, to take your position one step further, you would have to ADD all of the other things that are listed in 61.31 to the Commercial checkride. After all, that is where the requirement for a complex endorsement is contained. Why would the Commercial Certificate single out complex and ignore the rest?

 

[EdFred]

I don't like this or the FADEC changes.

 

[gismo]

I don't like this or the FADEC changes.

Why? A complex endorsement is still required for anyone flying a retractable airplane and IMO a "properly" taught complex transition does way more for a pilot's competency WRT retracts than the current requirement to demonstrate landing a complex airplane.

I do see some value in requiring knowledge about retractable landing gear and traditional engine controls with a C/S prop, but with today's lack of suitable complex trainers I agree with the FAA as far as these changes go for the practical test. Perhaps they should just have a portion of the commercial oral dedicated to complex aircraft issues.

A similar issue is looming WRT glass panels vs steam gauges for an IR checkride. It may be that what's really needed is a three version IR (steam, glass, both) checkride or better yet some kind of endorsement for this. The alternative is to require a "mini type rating" for each aircraft which would be terribly cumbersome but the notion that an instrument rated pilot who's never flown anything but a Cirrus SR-22G3 jumping into a steam gauge Bonanza and attempting to fly on the gauges is a bit scary. You might think that the typical insurer mandated transition training would take care of this but IME such training rarely includes any instrument training.

 

[TMetzinger]

Having now read the entire proposal, I think it's sound. Removing the complex airplane from the commercial certificate doesn't compromise safety, you still need the endorsement to act as PIC, and the insurance companies will still require significant complex time before insuring someone to act as PIC.

There are some ambiguities in the throwover control yoke stuff as written, but Lance Fisher has tackled this in his comments.

Requiring a 61.58 proficiency check to act as PIC in a jet is a good idea, and again, any insurer is going to insist on it anyway.

Exempting online course providers from having a physical classroom is common sense.

 

[SkyHog]

Is this step 1 to requiring a TAA endorsement later on?

If so, I'm against it.

 

[poadeleted20]

I do see some value in requiring knowledge about retractable landing gear and traditional engine controls with a C/S prop, but with today's lack of suitable complex trainers I agree with the FAA as far as these changes go for the practical test. Perhaps they should just have a portion of the commercial oral dedicated to complex aircraft issues.

With the exception of high altitude issues (Area X), testing of systems knowledge on the Commercial is limited to the systems on the aircraft provided for the practical test and has been for man years. I don't think that's going to change. If you provide a TAA plane, you're going to have to know all the avionics. If you provide a complex plane, you're going to have to know the gear and prop systems. If you provide a FADEC plane, you're going to have to know how the FADEC works as well as its capabilities and limitations. Talking about systems beyond those installed gets into too much trouble with the differences between say, the gear on a Piper Arrow and that on a Cessna Cutlass, especially if you're taking the test in a Cirrus.

 

[poadeleted20]

Is this step 1 to requiring a TAA endorsement later on?

Last I heard from AFS-800 on this, they were not going to get into endorsements for steam vs glass, no less TAA. They said as long as they don't see accidents due to this issue, they're not going to regulate it, and so far, they said, the insurance industry is forcing folks to get appropriate training for glass cockpits.

 

[SkyHog]

Last I heard from AFS-800 on this, they were not going to get into endorsements for steam vs glass, no less TAA. They said as long as they don't see accidents due to this issue, they're not going to regulate it, and so far, they said, the insurance industry is forcing folks to get appropriate training for glass cockpits.

That makes me happy. I'm ok with Insurance companies requiring it, since that's their right, of course. I just get antsy when the FAA starts passing rules.....law of unintended consequences being what it is.

Thanks Ron.

 

[jdwatson]

When will they define "advanced instrument training" ? Seems that what's advanced for some will be routine for others and vice versa. On my commercial check-ride it seemed that we had the gear going up and down all the time. Landings, stalls, ground reference maneuvers... It would have been a whole lot easier in a fixed gear plane.

Of course, the commercial rating in itself is pretty anemic in what you can do with it without additional training, certificates or ratings.

 

[TMetzinger]

I'm going to suggest they leave the instrument subjects up to the instructor to tailor to the needs of the candidate. I started my commercial training while finishing up the instrument rating and I was very sharp on instruments - I didn't need any training on "controlling the airplane by instrument reference". What I COULD have used was some more instrument X/C working in the system.

 

[TMetzinger]

Hmm, I didn't see this anywhere in th NPRM, but I assume that means that the CFI-A won't require a complex airplane either. I'll make a comment to that effect.

 

[mantakos]

This is probably a stupid question, but does this also assume an elimination of the requirement to demonstrate some subset of the commercial PTS maneuvers in a complex?

In other words, will you be able to get a commercial rating without ever touching a complex aircraft?
-harry

 

[TMetzinger]

This is probably a stupid question, but does this also assume an elimination of the requirement to demonstrate some subset of the commercial PTS maneuvers in a complex?

In other words, will you be able to get a commercial rating without ever touching a complex aircraft?
-harry

As I read it, YES. Now of course you won't be able to act as PIC of a complex airplane without the endorsement.

 

[gprellwitz]

This is probably a stupid question, but does this also assume an elimination of the requirement to demonstrate some subset of the commercial PTS maneuvers in a complex?

In other words, will you be able to get a commercial rating without ever touching a complex aircraft?
-harry

Not a silly question at all. I think that Ron had the same one, and investigated it. They do plan to bring the PTS in line with this once it's finalized. I'll let him fill in the details.

 

[poadeleted20]

When will they define "advanced instrument training" ?

It's in the proposed reg:

(ii) 10 hours of advanced instrument
training in a single engine airplane, or
in a flight simulator, flight training
device, or an aviation training device
that replicates a single engine airplane,
and the training must include
instrument approaches consisting of
both precision and non-precision
approaches, holding at navigational
radio stations, intersections, waypoints,
and cross-country flying that involves
performing takeoff, area departure,
enroute, area arrival, approach, and​

missed approach phases of flight;

Sounds a lot like IR training, doesn't it?

 

[poadeleted20]

Hmm, I didn't see this anywhere in th NPRM, but I assume that means that the CFI-A won't require a complex airplane either. I'll make a comment to that effect.

You can make that comment, but it's not relevent there's nothing in the regs requiring complex for CFI-A. That is in the CFI-A PTS because of a policy, not a regulation, and I've already been told by AFS-800 that if complex goes out of the CP-A reg, it will go out of the CFI-A PTS, too. However, that's not part of the rulemaking process -- first they go final on the rule, then they rewrite the PTS as required to fit the new rule.

 

[poadeleted20]

In other words, will you be able to get a commercial rating without ever touching a complex aircraft?

Per AFS-800, yes, you will be able to get a commercial certificate with airplane rating without any complex training or experience. So, for all of you Partenavia P68 owners, you can now get your initial Commercial with AMEL rating in your own airplane. Champion Lancer pilots are still hosed, though, since they can't feather a prop.

 

[tonycondon]

Per AFS-800, yes, you will be able to get a commercial certificate with airplane rating without any complex training or experience. So, for all of you Partenavia P68 owners, you can now get your initial Commercial with AMEL rating in your own airplane. Champion Lancer pilots are still hosed, though, since they can't feather a prop.

nah. the Partenavia guy might be able to get their initial Commercial Multi rating, someday, if the rules go through as proposed.

 

[Greg Bockelman]

Champion Lancer pilots are still hosed, though, since they can't feather a prop.

All 4 of them?

 

[gismo]

Talking about systems beyond those installed gets into too much trouble with the differences between say, the gear on a Piper Arrow and that on a Cessna Cutlass, especially if you're taking the test in a Cirrus.

I don't agree. You can learn plenty about one or two retract systems from books and the FAA could even publish something themselves covering the basics. I personally don't see much point in knowing the nominal/min/max system hydraulic pressure if it's marked on a gauge or if there's no gauge at all nor do I see any point in knowing how much fluid the system holds, yet all of these seem to be a significant part of what's covered on some checkrides.

What should be known IMO is how the emergency extension is used and when to use it, plus some idea of what to do if the landing gear won't extend fully, when and how to check for proper operation of the gear, and a little about the variety of extension systems (manual, electric, hydraulic, electric/hydraulic). Why couldn't the oral given to a commercial applicant flying a Cirrus include a discussion along those lines? Same for constant speed prop operation, basic design info of a few common types plus a bit on proper use.

 

[gismo]

When will they define "advanced instrument training" ? Seems that what's advanced for some will be routine for others and vice versa. On my commercial check-ride it seemed that we had the gear going up and down all the time. Landings, stalls, ground reference maneuvers... It would have been a whole lot easier in a fixed gear plane.

AFaIK with today's regs and PTS you can do all the maneuvers in a fixed gear single, then perform a takeoff and landing or two in a complex airplane and be good to go. Of course the slippery FAA language allows the examiner to require the applicant to perform any PTS task in either or both planes but most examiners are kinder than that.

Of course, the commercial rating in itself is pretty anemic in what you can do with it without additional training, certificates or ratings.

Yeah, you'd think there would be tasks like taking pictures while circling low and picking up banners on the fly.

 

[poadeleted20]

I don't agree. You can learn plenty about one or two retract systems from books and the FAA could even publish something themselves covering the basics.

But on the practical test, it's about practical knowledge -- how does the gear system work, how do you preflight it, what do you check, what are the indications of malfunction, what do you do about any particular malfunction, etc. Given the wide range of gear system designs out there, how do you cover that on the practical test for a plane with no gear retraction system? And where does it stop? How about hydraulic systems, bleed-air systems, turbine engines, flight control systems, flight management systems, etc? The FAA's answer is that when it comes to systems knowledge on the practical test, you are quizzed on the aircraft in which you show up. Anything else is "impractical."

I personally don't see much point in knowing the nominal/min/max system hydraulic pressure if it's marked on a gauge or if there's no gauge at all nor do I see any point in knowing how much fluid the system holds, yet all of these seem to be a significant part of what's covered on some checkrides.

Knowing how much it holds can be important when supervising servicing, although I agree that knowing gauge markings isn't approrpriate. However, the issue on a practical test is practical knowledge, and when you get away from the actual systems on the test airplane, you're going into theory, not practice.

What should be known IMO is how the emergency extension is used and when to use it, plus some idea of what to do if the landing gear won't extend fully, when and how to check for proper operation of the gear, and a little about the variety of extension systems (manual, electric, hydraulic, electric/hydraulic). Why couldn't the oral given to a commercial applicant flying a Cirrus include a discussion along those lines?

Because they all work differently. What's the right answer for what to do when the gear doesn't extend fully? The Mooney answer? Electric or manual? The Piper answer? Arrow or Comanche? They're all different, other than to say, "I'd follow the procedure in the AFM/POH," which really is kind of a pointless exercise in Q&A.

Same for constant speed prop operation, basic design info of a few common types plus a bit on proper use.

Again, there are differences between designs, and this is a test of practical skill, not theoretical knowledge.

 

[poadeleted20]

AFaIK with today's regs and PTS you can do all the maneuvers in a fixed gear single, then perform a takeoff and landing or two in a complex airplane and be good to go.

There's also the issue of getting 10 hours of training in a complex airplane before you take the test. That means the flight school has to keep one old Arrow or Cutlass or Sierra around on their flight line in airworthy condition (harder and harder to do) and you have to get 10 hours in it before you take the CP practical test mostly in a glass-panel Cirrus.

 

[gismo]

Given the wide range of gear system designs out there, how do you cover that on the practical test for a plane with no gear retraction system

I didn't mean that the applicant would be grilled on the specific design and use of multiple retract systems but rather be asked to tell what aspects of a retract system should be learned before flying a new type. And for that matter I don't see why the applicant couldn't simply select one particular aircraft type and be conversant with it's design and operational issues as explained in the POH for that aircraft type. All a school would need to support that would be the POH not the aircraft.

The FAA's answer is that when it comes to systems knowledge on the practical test, you are quizzed on the aircraft in which you show up. Anything else is "impractical."

I realize that this is the status quo, and was suggesting what I think is a "practical" alternative that preserves most of the existing benefit WRT complex system knowledge demonstrations on the checkride.

Because they all work differently. What's the right answer for what to do when the gear doesn't extend fully? The Mooney answer? Electric or manual? The Piper answer? Arrow or Comanche? They're all different, other than to say, "I'd follow the procedure in the AFM/POH," which really is kind of a pointless exercise in Q&A.

Like I said, (but left out of the earlier post) the applicant could simply pick one complex aircraft and work from it's POH.

this is a test of practical skill, not theoretical knowledge.

Seems to me there are other areas covered by the PTS that are more theroetical than practical such as the aeromedical factors and weather knowledge so it shouldn't be too big a leap to venture into "theory" here. That said, I agree completely that it would be "impractical" to require detailed knowledge of systems on a variety of aircraft.

 

[poadeleted20]

And for that matter I don't see why the applicant couldn't simply select one particular aircraft type and be conversant with it's design and operational issues as explained in the POH for that aircraft type.

That's the way it is now -- using the aircraft the applicant shows up with. Going beyond that goes beyond the FAA's concept of the practical test.

I realize that this is the status quo, and was suggesting what I think is a "practical" alternative that preserves most of the existing benefit WRT complex system knowledge demonstrations on the checkride.

Where do you draw the line? Complex? HP? Tailwheel? Turbocharged or turbine-powered? Hydromechanical flight controls? Fly-by-wire systems? It's just too big a can of worms to open.

Seems to me there are other areas covered by the PTS that are more theroetical than practical such as the aeromedical factors and weather knowledge

Those are tested in a very practical manner on the practical test. For example, they don't ask about the physiology of "the bends," they just ask how long you should wait before flying after diving (or, for the commercial, what to ask your pax about any diving they did when you pick them up in the Bahamas). Likewise, they don't ask how the forecast was arrived at or how the ceiling was measured, just whether the weather is good enough to make the flight legally and safely. Very practical stuff.

 

[TMetzinger]

You can make that comment, but it's not relevent there's nothing in the regs requiring complex for CFI-A. That is in the CFI-A PTS because of a policy, not a regulation, and I've already been told by AFS-800 that if complex goes out of the CP-A reg, it will go out of the CFI-A PTS, too. However, that's not part of the rulemaking process -- first they go final on the rule, then they rewrite the PTS as required to fit the new rule.

Good, then my comment may remind them to be sure to check the CFI PTS, not just the commercial PTS.

 

[TMetzinger]

It's in the proposed reg:
Sounds a lot like IR training, doesn't it?

It does. And if the commercial pilot has an instrument rating, he'll be proficient at it. If he doesn't, what use is it? If he's not rated or proficient on instrument flying, he really needs proficiency in basic instrument manuevers, including emergencies and unusual attitudes by instrument, NOT training in instrument procedures he can't legally fly in the soup anyway.

Another suggestion to file, then.

 

[vontresc]

So this is a more pragmatic question. when would this NPRM become effective? I was looking at doing my SE Comm this winter, but I really didn't want to deal with the POS Arrow at our FBO.

 

[poadeleted20]

So this is a more pragmatic question. when would this NPRM become effective?

The NPRM for the Part 61 rewrite which just went final and is effective next month was released in Feb 2007. OTOH, minor changes like this often become effective in a matter of months after the NPRM. I'm thinking mid-2010 for this one.

 

[dmccormack]

There's also the issue of getting 10 hours of training in a complex airplane before you take the test. That means the flight school has to keep one old Arrow or Cutlass or Sierra around on their flight line in airworthy condition (harder and harder to do) and you have to get 10 hours in it before you take the CP practical test mostly in a glass-panel Cirrus.

The "Glass panel Cirrus" may be the norm at Pilot mills, but out here in average-Joe-schmoe world, the trainers are still C152s/C172s.

 

[poadeleted20]

The "Glass panel Cirrus" may be the norm at Pilot mills, but out here in , the trainers are still C152s/C172s.

Since the new rule gives the option of doing either 10 hours of complex or 10 hours of advanced instrument, the "average-Joe-schmoe world" can keep doing what they're doing. Or not -- you'll be able to do the whole commercial training program in a C-152 with a GS, almost like when I got my CP in a C-150 in 1972 (didn't need any radio then).

 

[jdwatson]

It does. And if the commercial pilot has an instrument rating, he'll be proficient at it. If he doesn't, what use is it? If he's not rated or proficient on instrument flying, he really needs proficiency in basic instrument manuevers, including emergencies and unusual attitudes by instrument, NOT training in instrument procedures he can't legally fly in the soup anyway.

Another suggestion to file, then.

But it doesn't sound like advanced training, sounds like the very basics.

 

[dmccormack]

Since the new rule gives the option of doing either 10 hours of complex or 10 hours of advanced instrument, the "average-Joe-schmoe world" can keep doing what they're doing. Or not -- you'll be able to do the whole commercial training program in a C-152 with a GS, almost like when I got my CP in a C-150 in 1972 (didn't need any radio then).

It seems like a good compromise, but doesn't seem to abide by what seems to be the intent of the Commercial certificate -- the evidence of a higher level of knowledge of, and control within (and without) the edges of, a likely-to-be-flown aircraft.

The IFR requirement seems silly. Frankly, I think the IR should be required for the Comm, but can understand why it's not (lots of pilots never see a cloud in certain parts of the country). 10 Hours of IR is more likely to impose false confidence than any real save-your-life proficiency in IMC.

 

[poadeleted20]

10 Hours of IR is more likely to impose false confidence than any real save-your-life proficiency in IMC.

The new rule would require either 10 hours of instrument plus 10 of complex or 20 hours of instrument.

 

[TMetzinger]

I see the value in eliminating the complex - I don't see the value to the VFR commercial pilot in adding 10 hours of instrument work. Either a pilot is instrument rated (and proficient), or he's not. I suspect that someone didn't want to reduce the number of hours required for fear of accusations of compromising safety.

Now, if you asked me about combining the commercial and instrument curriculum, I'd say you could make someone capable of flying both rides with less dual than it takes an average pilot to do them in sequence. But that's not what's going on here.