The CFI-S Conundrum: Time for Change!

I had been thinking since I first started flying Light Sport I might want to go after my Light Sport Certified Flight Instructor Rating. I have always loved to teach and I have always loved to fly. Once it was clear to me that I needed a way to stay in aviation as the space shuttle program was being shut down with nothing to replace it, I knew I wanted to go after that rating and use it as a means of self-expression and a means of keeping my airplane (a Flight Design CTSW LSA). I engaged the help of a good friend and coworker who is a CFI and now a full-time Continental Express pilot and we have been working to teach me how to be a good teacher in the air for several months. I’ve been introducing him to Light Sport, so I like to think that, in addition to the checks I give him, it’s a good trade!

I almost decided against going down this road.

For those of you who don’t know me, I hold a Commercial ticket with an instrument rating for single-engine land and have about 1300+ hours of pilot time. That time includes various single-engine airplanes…Cessna’s, Piper’s, Mooney’s, Citabrias, Decathalon’s, Grummans, T-34B’s, T-28B’s and C’s, and even a little solo time in T-2B’s and C’s. There is also “unofficial” pilot time in both the Fixed and Motion Base Shuttle Mission Simulators flying to and from orbit, both nominally and in abort modes. I also have a little over 1200 hours as a Naval Flight Officer (Special Crew Flight Time) most of which was as a Radar Intercept Officer in the F-14A. For the last several years, ever since we decided to sell our Grumman Cheetah, I have been flying under Light Sport rules in a Flight Design CTSW both my wife and I love. For us, flying only under Day VFR is good enough; though I like flying IFR, my wife hates it. We had only been flying at night on occasion. Additionally, after sinking tons of money into the Cheetah only to mechanically catch it up, my wife refused to let me consider buying another 30 year old airplane. Light Sport allowed us to move to a newer airplane than we otherwise could have and it cost less to operate, too, though sometimes…

But I digress.

Soon after we started flying Light Sport, I realized I had enough hours to go after the Light Sport Instructor rating (which I have seen designated as CFI-SP and CFI-S, more often the latter). Two of my closest friends in aviation are both CFI’s, and knowing I might be able to work with one or both of them helped convince me to start investigating getting the rating. As I looked into it, though, I realized a rather incongruous and disheartening thing, i.e., that the FAA was saying that dual time received from a CFI-S would not count toward a Private Pilot rating. This sent an immediate message to me that the CFI-S was considered a “second class citizen”, something reinforced by the reactions of CFI’s around me who didn’t want the competition from this “new kid”, especially in an arena where most of them had absolutely no experience. In the end, after months of thinking about it, I decided to go after the CFI-S anyway. I knew that AOPA and EAA both felt that this situation was unjustified and that there was some wind blowing for change.

When Connie and I went to EAA Airventure 2011 last month, I stopped by the AOPA tent and discussed the petition that AOPA and EAA had sent to the FAA asking that the rule for CFI-S dual time accountability toward higher ratings be changed. Neither of the two gentlemen I spoke to really knew where that petition was in the FAA process, but one of them commented that “it could take years” for the FAA to respond. I am pleased to report he was wrong! Tonight, my CFI let me know he had seen an notice from AOPA that the rule change was being opened for public comment under Docket FAA-2011-0138. I IMMEDIATELY PUT MY TWO CENTS IN! All you guys who are thinking about flying LSA and going for your Private later and all you Light Sport pilots in general, now and in the future, PLEASE go to: http://www.regulations.gov/#!home and put in “FAA-2011-0138” in the Search bar and let it take you to the Docket and make a comment supporting this change. (Why should you do that? Because it gives you more options!)

Here’s what I had to say about it:

“I hold an FAA commercial/instrument rating ASEL, have been flying Light Sport for over two years and am currently pursuing my Flight Instructor Light Sport rating. Additionally, I am an ex-astronaut and flight controller trainer and have over 1000 hours as a Radar Intercept Officer in F-14 aircraft. Having started CFI training before, I can attest that there is no difference in the training I am currently receiving for CFI-S vice CFI other than not having to teach commercial maneuvers or night flying techniques. In every way, the day VFR skills for Light Sport translate directly into those needed for Private Pilot; indeed, the characteristics of the LSA I am flying make it harder to fly then many GA singles I have flown in the past. Therefore, to not count instruction I would give as a CFI-S toward the Private Pilot or higher certificate is not only illogical but does a great disservice to the CFI-S as well as the Light Sport movement, in general. Indeed, this discrepancy was a reason I almost decided not to pursue the CFI-S even though I love to fly and love to teach and Light Sport is and probably will remain my aerial province. If this is allowed to stand, it puts me and my flight school at an immediate business advantage that could result in the long run at my having to leave aviation altogether. Driving pilots out of the game is exactly the opposite of what the Light Sport rule is intended to do.

If there is a belief that CFI-S instruction is somehow inferior, then the FAA needs to revamp its training and testing systems. Otherwise, this petition needs to be adopted for the good of Light Sport and general aviation. There does not need to be a second class citizen known as the Light Sport CFI.”

The time to change this illogical and wasteful situation is now. Please support this change.

On Flying the New Light Sports

Whether you’ve never set foot in an airplane or are an experienced aviator simply looking to get into Light Sport flying, one of the best ways to do that is by learning to fly in a Flight Design CTSW.  Our model is a 2006 with the slightly larger stabilator, a Garmin 496 with XM weather, and a two-axis autopilot.  As that introduction suggests, just because this is a light-sport aircraft doesn’t mean it’s not a very capable little bird; I chose this model because of its cross-country capability.  By mastering Light Sport and the CTSW in particular with its helicopter-like visibility, one opens the doors to personal flight in its best sense.

That said, you may have noticed that recent FAA Safety promotional material is talking about higher accident rates in light sport.  Be sure to read what the FAA is saying carefully because they admit that overall accident rates are in line with other general aviation classes.  That said and having flown light-sport and the CTSW exclusively for a little over two years and a couple of hundred hours, I would like to share with you my picture of what about light-sport is different and do so mainly from a safety standpoint.  The caveat is that what I’m about to say to you and what the FAA is also saying to you is that every light-sport aircraft is different, and though you may be able to draw some overall conclusions about the category, it’s not gospel when it comes to talking about any individual light sport airplane.  There’s a lot of folks who still look down on light-sport, and it is that attitude that can lead to underestimation and accidents, as well as missing a really good time!

(1) Performance varies widely within the Light Sport class.

The FAA tri-fold brochure on Light Sport accidents being circulated now refer to light-sport airplanes as: “not as powerful, nor as capable, as some you may have previously flown”.  This is not a uniformly, across-the-board, true statement and believing it is can itself lead to accidents in certain light sport aircraft. While my CTSW can only haul a 584 pound useful load compared to our 830 lb useful load 76 Grumman Cheetah, the Grumman never saw 1000 fpm in a climb, something my CTSW can hit anytime it is flown single-pilot with half fuel.  Additionally, the CTSW will quickly accelerate from a Vy climb speed of 78 knots to a cruise at 112 knots, almost exactly equivalent to what I would flight plan with the Cheetah (110 knots).  In fact, one of the surprising things about the CTSW and one of the things that makes it more complicated to fly than the Cheetah—or most GA singles– is its flap configurations and limitations.  Nominal flaps up in every airplane I’ve flown before this one is at zero degrees, but in the CTSW it’s minus six degrees.   The aircraft accelerates very quickly from climb to cruise as the flaps go negative.  While the airplane approaches at 54 to 65 knots and stalls as slow as 39, it will easily slip into the pattern pushing 120 knots.

Certainly, there are plenty of light sport aircraft that don’t perform like this.  But my point is that you need to get to know the light sport aircraft you’re going to be flying in and exactly what kind of performance is at your behest.  The best thing you can do when deciding to fly or buy a light-sport aircraft is empty your brain of any preconceptions you have unless you’ve gained them with actual flight experience in the aircraft.

(2)  You’re going to have to take winds more into account.

By law, the light sport category tops out at 1320 lbs gross weight.  The light weight of the aircraft, especially when coupled with aerodynamic refinements of some of the newer models, means that the airplane is, more than likely, going to be more of a handful to fly in gusty winds, especially in a crosswind.  While the CTSW has the sane 16 knot crosswind limitation my Cheetah had, flying a crosswind landing in the CTSW gets your attention a LOT more, especially when any kind of flaps are down.  Additionally, the airplane is much more gust responsive in the air and on the ground, especially right after touchdown when aileron control is deteriorating but the wings still have significant lift.   While the Cheetah didn’t have any kind of operating restriction on the ground due to winds, Flight Design recommends that flight ops in the CTSW stop with any surface wind at or above 25 knots.  I’ve found the CTSW actually handles fairly well with no flaps in winds close to that and at or above the demonstrated crosswind limit, but becomes a “bubble on the water” with any amount of flaps.  The bottom line here is that you will run into days when the sun is out, the birds are chirping, and the smart decision is not to fly because the winds are at or above published limits or simply because you don’t need to test out your and your passenger’s iron stomachs or prove out your exceptional piloting skills which you will need to get down without crunching the airplane if you launch.

(3) Plan on getting instruction with a CFI that KNOWS the airplane before you go solo.

When we bought our airplane, AVEMCO required that I get five hours of flight time and ten landings as well as a BFR in the airplane with a CFI who also had at least five hours in the airplane. Admittedly, that’s not always an easy thing to do because of the shortage of instructors who have light-sport experience and especially experience in the airplane you want to fly.  But make sure you do.  It is well worth it. That said, make sure your CFI has good  knowledge of the aircraft he/she is going to fly.  Otherwise,  you’re just setting yourself up for an accident and are paying the CFI to take the risk that he/she will be blamed for it all as the Pilot-In-Command.  (A few weeks before I wrote this, a CTLS went down in a fuel depletion accident during just such a flight; I suspect neither pilot knew CT’s fuel system.)

(4)  Most accidents in CT’s..and the new Light Sport airplanes…occur with high-time pilots, not “fresh-outs”.

This gets back to making assumptions about flying light-sport and the CT series in particular.  Follow what I’ve said above and you’ll probably stay out of trouble.  The reality is, and this holds for experimental aircraft as well, that many accidents occur because of the pilot’s and/or instructor’s unfamiliarity with the aircraft.  When you’re in some kind of a box and the airplane doesn’t respond as you expected, it’s too late to figure it out then.  Thinking you’re a high-time pilot who can fly anything without any familiarization is the first step to getting there.

Ed Downs wrote an excellent article that sums up the flight characteristics of the new light sport aircraft that can catch pilots by surprise.  The article is entitled “Light Sport Flying With In Flight USA”.

(5) Maintaining a Special Light Sport is not much different than maintaining a certificated airplane, and may be harder. The FAA delegated the “requirements” for maintaining the aircraft to its manufacturer rather than having the manufacturer meet FAA specifications.  While light-sport aircraft are designed to ASTM specifications, the manufacturer’s requirements carry the weight of law.  In the case of the CTSW, Flight Design gets the say about who can do what when working on the airplane, and that authority is laid out in the airplane’s maintenance manual.  Likewise, the engine manufacturer (Rotax in the case of the CTSW) gets to say who gets work on its engines, and it has specified that even the simplest of engine tasks can only be performed by those with Rotax training.  While I can make a good argument about why this is overkill and is actually hurting the Rotax market in the U.S., it’s the ways it currently is.  On the other hand, if I want to install a new piece of equipment or avionics in my airplane, I only need seek approval from Flight Design and not the FAA.  Most CT owners know how to do this and it is not a difficult or time-consuming task.

S-LSA’s may be maintained by Light-Sport Repairmen as well as by A&P’s with the proper training, though not as many of the latter are Rotax qualified.  This is something to take into account when buying an LSA or flying it out of its home area.  You can find a good listing of Light-Sport Repairmen at: http://www.rainbowaviation.com/repairman.htm

(6) You need to know the rules, because there are several things that can become regulatory traps. I’ve spent a lot of time exploring and studying the Federal Aviation Regulations about light sport (including discussing some aspects of these laws with AOPA and EAA), and if you don’t know the rules, you can run afoul of them very easily.  Part of the reason for that is that they appear to be written for the 25-hour-and-no-other-experience pilot and part of the reason is that some operating limitations are found in FAR Part 61 instead of Part 91 where they probably belong.  Flying on your driver’s license for your medical lumps you in with the 25 hour pilot, no matter what rating or how much flight time you have.  For instance, you can be following the rules for visibility and cloud clearance criteria in 91.155 (Basic VFR Weather Minimums) and still violate Light Sport restrictions in 61.315 (What are the privileges and limitations of my Sport Pilot certificate?). In addition, 61.315 states that the light sport pilot must take surface visibility into account, something that makes sense when performing a takeoff or landing at an airport but not when at cruise.  Neither of those things are actions imposed on any other pilot rating, which is why they can become regulatory traps for the light sport pilot.

Personally, I believe the Light Sport pilot and aircraft category is indeed the best thing to hit general aviation in the United States in a long time.  For those of us flying Light Sport, the best thing we can do is fly as professionally as possible, talk up the advantages of flying Light Sport to everyone who will listen, and work to cut the disadvantages, of which there are still too many.