Comment made on post

[mhaleem]

I was reading a post on another forum where a guy asked a question regarding the feasibility of making a living as a SPI or CFI. The gentleman who responded stated he should become a "full-fledged cfi" and get the instrument, commercial and regular cfi. Why do people make these stupid comments? A sport pilot instructor is a full fledged cfi that specializes in sport training. A flight instructor who teaches only instruments is a full fledged instructor who specializes in instruments. Why do people aim to separate. The last time I checked general aviation needs good people to join its ranks. When a student comes into a flight school and requests info about becoming a sport pilot, don't assume he/she has not done their research; stop thinking about yourself and focus on what the customer wants.

[RyanShort1]

I was reading a post on another forum where a guy asked a question regarding the feasibility of making a living as a SPI or CFI. The gentleman who responded stated he should become a "full-fledged cfi" and get the instrument, commercial and regular cfi. Why do people make these stupid comments? A sport pilot instructor is a full fledged cfi that specializes in sport training. A flight instructor who teaches only instruments is a full fledged instructor who specializes in instruments. Why do people aim to separate. The last time I checked general aviation needs good people to join its ranks. When a student comes into a flight school and requests info about becoming a sport pilot, don't assume he/she has not done their research; stop thinking about yourself and focus on what the customer wants.

I think he's right if you want to make a living. I doubt that Sport Pilot alone in MOST markets is good enough to make a decent living. A PPL candidate is probably good for at least 20-30 hours of flight training for the instructor - which means let's say a $800-$1000 return on the instructor's recruiting efforts. A SP candidate may be worth just over half of that. Also, I'm personally seeing a LOT more PPL candidates than SP with all of the CFIs I know of, and most CFIs are NOT getting wealthy fast. Becoming a full CFI is probably not that much more work, and gives you a much broader base of things to do when you aren't busy enough. If you limit yourself to SP instruction, then you'd better have a really good marketing plan! I'm a "regular" CFI - and I have three Light Sport students for sure right now - just soloed two of them, and have several other "every once in a while" students, too. Light Sport is OK, but again, it probably won't pay the bills by itself unless you have a LOT of volume.

Ryan

[Jim Stewart]

Although I agree with you about unity of the flying community, I disagree that there is much commonality between a LSA instructor and a CFI. Looking at the hours, the prerequisite ratings and the difficulty of passing the CFI knowledge, oral and checkride, I find there is less rather than more in common with the two. As my instructor said, the most difficult checkride a person can take is the CFI.

[drseti]

Another thing to consider is that, as the FARs currently exist, training received from an FAR 91 Subpart K instructor (the so-called Sport Pilot CFI) does not count toward higher ratings. Any student planning to go on for the Pvt, Commercial, Instrument, ATP, etc. must either train with an FAR Subpart H instructor (the "full" CFI), or will have to repeat training. This fact alone makes it very hard for a Subpart K instructor to make a decent living.

For this reason, I will only hire Subpart H instructors in my flight school. This in no way reflects negatively on the skills, talents, and abilities of the Sport instructors; it's just based upon financial realities.

There is a proposal before the FAA to change this restriction. The committee that drafted it (on which I was privileged to serve) made some cogent arguments. Whether FAA will view them as reasonable remains to be seen.

[zdc]

for this reason, I will only hire Subpart H instructors in my flight school. This in no way reflects negatively on the skills, talents, and abilities of the Sport instructors; it's just based upon financial realities.

.

a

That is an interesting statement. Since you have said before that you do not have a III class medical, under FAR 61.23 you are exercising the privelages of a Flight Instructor with a Sport Pilot rating. So, I do not see how any instruction you give would count towards a Private rating.

[drseti]

you do not have a III class medical, under FAR 61.23 you are exercising the privelages of a Flight Instructor with a Sport Pilot rating.

That's not entirely correct. According to the FAA, I am still a Comml/Instr/CFI/CFII, and those ratings are still valid. The medical is an issue only for those operations requiring a medical. Obviously, I cannot fly at night, or actual IFR, because that requires a medical. And, I cannot be PIC in anything other than an LSA or Sport Pilot- eligible certified aircraft. But, in an LSA, I can be PIC, and am still a Comml/Instr/CFI/CFII, not a Subpart K instructor. As long as I keep my CFI current, this is completely legal.

BTW, lots of CFIs continue to give instruction without a medical. They just can't be PIC, except in an LSA. This is covered in the FIRC we all take every two years.

[zdc]

you do not have a III class medical, under FAR 61.23 you are exercising the privelages of a Flight Instructor with a Sport Pilot rating.

That's not entirely correct. According to the FAA, I am still a Comml/Instr/CFI/CFII, and those ratings are still valid. The medical is an issue only for those operations requiring a medical. Obviously, I cannot fly at night, or actual IFR, because that requires a medical. And, I cannot be PIC in anything other than an LSA or Sport Pilot- eligible certified aircraft. But, in an LSA, I can be PIC, and am still a Comml/Instr/CFI/CFII, not a Subpart K instructor. As long as I keep my CFI current, this is completely legal.

BTW, lots of CFIs continue to give instruction without a medical. They just can't be PIC, except in an LSA. This is covered in the FIRC we all take every two years.

I attended a FAAST meeting where the FAAST reps disagree with your assertions. You can not instruct for Private without a medical, no matter if it is an LSA or not. If you do not possess a medical you are exercising part K privelages not Part H when giving instruction.

[drseti]

I am a FAASTeam lead rep, and my FSDO is of a different opinion.

[zdc]

It is not unusual to get different opinions from different FSDO's. Someone will eventually write a letter to the FAA requesting clarafication on this issue. No matter how you spin it, you can't get around FAR 61.23.

[zdc]

The medical is an issue only for those operations requiring a medical. ]

Exactly. According to 61.23, you need a medical to exercise the privileges of a Flight Instructor [other than Sport] and be a PIC. To exercise the privileges of a Sport Flight Instructor you need either a medical or a drivers license. When you give instuction in your EVEKTOR and you are PIC, without a medical, you are obviously exercising the privileges of a Sport Instructor.

[drseti]

Let's look at the intent of the reg (that's the approach my local FSDO takes, though other FSDOs may certainly view things differently). The Subpart H CFI has received training and demonstrated proficiency as a commercial and instrument pilot. The Subpart K instructor is not necessarily required to have done so (though he or she may indeed have the requisite skills and training). To instruct toward Private and above ratings, one must have demonstrated and retained the skills and proficiency required of a Subpart H instructor. Allowing one's third class medical certificate to lapse certainly does not, in and of itself, take away any acquired training, skill, or proficiency.

[zdc]

If a Flight Instructor is giving instruction and is also acting as PIC, the Flight Instructor is operating under Subpart H or K. If the instructor has a drivers license but no medical that instructor is operating under Subpart K and therefor the hours would not count towards a Private rating. For the instruction to count towards Private, it is a matter of what section of the regulations the instructor is operating under.

[zdc]

Let's look at the intent of the reg (that's the approach my local FSDO takes, though other FSDOs may certainly view things differently). The Subpart H CFI has received training and demonstrated proficiency as a commercial and instrument pilot. The Subpart K instructor is not necessarily required to have done so (though he or she may indeed have the requisite skills and training). To instruct toward Private and above ratings, one must have demonstrated and retained the skills and proficiency required of a Subpart H instructor. Allowing one's third class medical certificate to lapse certainly does not, in and of itself, take away any acquired training, skill, or proficiency.

You are now making an argument that a subpart K instructors instruction shouldn't count towards a private. Other than completing an online course every two years, what proof is there that a subpart H instructor has demonstrated or retained any proficiency?

You can exercise the privileges of a subpart H instructor for operations not requiring a medical. FAR 61.23 is very clear that to exercise the privileges of a Flight Instructor [part H] and be PIC you must have a medical, LSA or not, it doesn't differentiate.

[drseti]

You are now making an argument that a subpart K instructors instruction shouldn't count towards a private.

As a matter of fact, the recommendation made to FAA by the EAA/AOPA/NAFI team was that instruction by Subpart K instructors should only count for higher ratings in those specific areas of operation where the PTS tasks and standards are identical for SP and PP. So, yes, to some extent, I am making the argument that some instruction given by Subpart K instructors shouldn't count.

FAR 61.23 is very clear that to exercise the privileges of a Flight Instructor [part H] and be PIC you must have a medical.

I do understand (and respect) that, as an FAA employee, you were trained to think like a lawyer. Unfortunately, I was trained to think like an educator -- so, we'll always disagree.

In fact, for my flight school, this whole discussion is academic anyway. The one SP I have who's going on for his PP will have enough time logged with my Adjunct Instructor (who does have a valid medical) to satisfy the requirements, so my lack of medical is moot. But, this does raise another, related question.

The operative part of your post is:

and be PIC

I think we all agree that a CFI with a lapsed medical can give any instruction he or she wishes, as long as the person receiving the instruction is able to serve as PIC. This is how CFIs with lapsed medicals gave BFRs to current pilots, for years before there even was a Sport Pilot rule. In the case of a SP going on for higher ratings, if current and flying an LSA, the student can be PIC. So, if the additional training toward PP meets the hours requirement, doesn't it seem logical that it can be given by a CFI with a lapsed medical (as long as the instructor isn't PIC)?

[zdc]

No insult intended, but you guys [local FAAST , FSDO] are spinning the heck out of FAR's so that subpart H instructors can exercise almost full privileges under subpart H and not have a medical. If an instructor is giving instruction and acting as PIC, he/she is exercising the privileges of a subpart K instructor only.

When you hop in your Evektor, ask yourself, what privileges am I exercising?