If you’ve been reading my blog for any length of time (and I found out this past weekend I have at least one reader…and he’s not in my family!), then you know I’ve felt like the FAA, EAA, and AOPA have been disregarding Light Sport. In particular, the press for Third Class Medical Reform seemed to have buried two issues near and dear to my heart as a Light Sport Instructor. The biggest injustice was that dual instruction toward a light sport certificate given by a Light Sport instructor (Subpart K, Part 61) didn’t seem to count toward a private or recreational pilot certificate (and I say “seem” because that was the interpretation of an FAA legal office opinion not actually codified into law). This held the potential to handicap a CFI-S trying to get new students that knew they wanted to go on to a higher certificate and privileges. (It didn’t seem to impact us when we had our flight school going as about half our students were “new starts”.) It also wasn’t fair to the students; if they wanted to train in a particular Light Sport aircraft, why shouldn’t they be able to train with the instructor they wanted, especially if he/she had the most experience in that aircraft, without taking a penalty?
The other piece of the Part 61 regulations that was troublesome was the fact that a Light Sport instructor without any other pilot ratings couldn’t give the required instrument training for their student pilots to go solo cross-country as required by 61.93 (e)(12). The NPRM corrects this deficiency by allowing Light Sport instructors who wish to give that instruction to do so after getting one hour of ground instruction and three hours of flight instruction and a competency endorsement from a Subpart H instructor. The NPRM also allows the CFI-S who has the endorsement to act as “safety pilot” under these conditions, closing the other legal loophole created by today’s regs. (That said, I was convinced that the current regs allowed a CFI-S with at least a private pilot certificate rating to act as safety pilot in an LSA even using a “driver’s license medical. Ask me sometime and I’ll show you; but it’ still nice not to have any ambiguity left.)
As you might guess, I’m going to fully support this NPRM and hope you will, too. I do have one comment to make on the first part (the CFI-S training requirement) in that the rationale for training is that they assume the CFI-S has no instrument experience. I’m going to suggest that the training requirement as written is overkill for a CFI-S who holds private or commercial pilot certificates with an instrument rating and that a Subpart H instructor endorsement of competency should be adequate. I’d have no issue with an hour of ground and an hour of flight to get a refresher; my CFI and I did “hood” work as a normal part of me working up for my CFI-S. Why not, though, just let the Subpart H instructor decide what it’s going to take?
For me personally, the timing of all this could not be better. I’ve been moving toward getting more into instructing; I’m hoping to test out for my Advanced Ground Instructor rating in the next two months. I just had a chat with the folks over at Coastal Skies Flying Club about Light Sport in general, and they, like me, are interested in growing it. So, I’ll be joining up (a decision reinforced when I found out one of the pilots I flew with in VF-51…and my roommate on the Vinson cruise…is a member) and getting checked out in the Remos to start instructing there. Hope you’ll come join me! This’ll be fun!