All training from Sport CFI now counts towards higher ratings

Finally, a place for sport pilot instructors and/or wannabees to talk about instructing.

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TDFlyer
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Re: All training from Sport CFI now counts towards higher ratings

Postby TDFlyer » Fri Dec 21, 2018 4:48 pm

If i read the new rules correctly, you can't apply training from a Sport CFI towards a Private unless you actually have COMPLETED your sport rating?
"b) The holder of a sport pilot certificate may credit flight training received from a flight instructor with a sport pilot rating toward the aeronautical experience requirements of this section if the following conditions are met:"

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drseti
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Re: All training from Sport CFI now counts towards higher ratings

Postby drseti » Fri Dec 21, 2018 5:07 pm

That would appear to be the case. So, if one begins SP training with a CFI-S, he or she should plan to complete the SP rating before continuing on for PP. If unsure, one should start off with an FAR 61 subpart H CFI.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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bryancobb
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Re: All training from Sport CFI now counts towards higher ratings

Postby bryancobb » Wed Jan 09, 2019 5:36 am

Warmi wrote:...It is shame thought that it took 6 years to get such common sense and uncontroversial change thru ...


It was that way from the very beginning until some moron felt Sport CFI's were not "real" instructors and the way the FAR was worded created a little air leak to support that view. This person backed the FAA into a corner by writing the Legal Department for a definitive judgement.

Once Legal made the call, it built the wall between "real" CFI's and "pretend" CFI's. Now the wall is down. Thanks Helen and others.

MORAL: NEVER write FAA Legal for a ruling on something you are arguing with pilots about.
Bryan Cobb
Sport Pilot CFI
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Re: All training from Sport CFI now counts towards higher ratings

Postby drseti » Wed Jan 09, 2019 9:10 am

bryancobb wrote:MORAL: NEVER write FAA Legal for a ruling on something you are arguing with pilots about.


Well, not if there's any chance at all that FAA Legal might give an answer that you (or I) might not like!

Jest aside, there have been cases where two different pilots have requested an interpretation from FAA Legal on the same issue. The requests went to two different FAA attorneys, who then issued two completely different, conflicting decisions.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
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TimTaylor
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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 1:16 pm

Personally, I want the correct answer whether I like it or not. I don't want to be flying around in violation of FAR's because I have misinterpreted something. Unfortunately, since the FAA is just people (Soylent Green is people), sometimes individuals within the FAA might misinterpret something also. The FAR's really need a complete top to bottom harmonization to remove all of the ambiguity. They need to be rewritten by my 12th grade English teacher.
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Re: All training from Sport CFI now counts towards higher ratings

Postby bryancobb » Wed Jan 09, 2019 8:13 pm

TimTaylor wrote:...I want the correct answer whether I like it or not. I don't want to be flying around in violation ...


Tim,

Sometimes, as what happened years ago pertaining to not counting Sport CFI dual toward Private licenses proves, there may not be a "correct" answer.

The authors of the Sport Pilot reg's intended one thing. The legal department interpreted those reg's differently than the authors. And the Paul tells of different interpretations, depending on which FAA lawyer is reading your question.

Obviously not a right answer and a wrong answer, the only fact about Legal interpretations from the FAA is ...it's binding once published.
My stance on ambiguous reg's is...any pilot who is trying in earnest to be a safe pilot, is not going to get in any trouble as long as they can present a compelling reason to the FAA why they interpret the reg's like they do.

Here's a recent example: When Basic Med became law, I went to the FBO to confirm whether or not I would be allowed to rent their 172's. A busy-body M.D. and his Lawyer buddy just happened to be in the FBO and heard my questions. He butted-in and he and his lawyer friend gave me a 10 minute rant on how the FBO would NEVER allow it.

I wound up calling the FBO's attorney who is the pilot that brought the Ebola Doctor back from Africa in a Gulfstream G-III a few years ago. I asked him. He didn't know the answer so after he called their underwriter, he gave me an unequivocal "YES, they said if the FAA says legal, we will cover it."
Bryan Cobb
Sport Pilot CFI
Commercial/Instrument Airplane
Commercial Rotorcraft Helicopter
Manufacturing Engineer II, Meggitt Airframe Systems, Fuel Systems & Composites Group
Cartersville, Ga
bryandcobb@att.net

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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 8:17 pm

Allowing Sport Pilot CFI time to count toward a Private is not a misinterpretation, it's a change. But, even if it was a misinterpretation, you don't just assume something and cause your students problems down the road.

The insurance question you described has nothing to do with the FAA. There was speculation that some insurance companies would not allow it. Nobody intentionally writes the FAR's to be ambiguous and intentionally open to different interpretations. That is a ridiculous idea especially coming from a CFI.

There is always a correct answer. It's what was intended when the regulation was written. Sometimes regulations get changed. Frequently, the regulations are not clear, leaving them open to unintended interpretation. Let's not make up false information here. I prefer to follow the FAR's, not have to defend an incorrect interpretation in court.

I think it is dangerous and irresponsible to suggest to other people that they should interpret FAR's as they see fit to meet their own needs.
Last edited by TimTaylor on Wed Jan 09, 2019 8:32 pm, edited 2 times in total.
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bryancobb
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Re: All training from Sport CFI now counts towards higher ratings

Postby bryancobb » Wed Jan 09, 2019 8:28 pm

TimTaylor wrote:Allowing Sport Pilot CFI time to count toward a Private is not a misinterpretation, it's a change. The insurance question you described has nothing to do with the FAA.

There is always a correct answer. It's what was intended when the regulation was written. Sometimes regulations get changed. Frequently, the regulations are not clear, leaving them open to unintended interpretation. Let's not make up false information here.



Precisely! When the Sport reg's were written, a very important intent of them was to have legitimate Certified instructors teaching Sport students and their training and the rating being an entry level stepping stone to higher ratings. The ruling letter from legal totally prevented that! Until just recently.

What was the "correct answer?" The intent? or the legal ruling? Up until the idiot asked the question, all Sport CFI's were teaching students and those students could have applied the time toward the Private.
Bryan Cobb
Sport Pilot CFI
Commercial/Instrument Airplane
Commercial Rotorcraft Helicopter
Manufacturing Engineer II, Meggitt Airframe Systems, Fuel Systems & Composites Group
Cartersville, Ga
bryandcobb@att.net

TimTaylor
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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 8:33 pm

I'm not going to argue with you. I'll just ignore you.
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Warmi
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Re: All training from Sport CFI now counts towards higher ratings

Postby Warmi » Wed Jan 09, 2019 8:39 pm

TimTaylor wrote:Allowing Sport Pilot CFI time to count toward a Private is not a misinterpretation, it's a change. But, even if it was a misinterpretation, you don't just assume something and cause your students problems down the road.
...


In other words, both Bryan and Paul have more charitable interpretation of the logic behind the rules - the left hand sometimes doesn't know what the right hand is doing or intends to do while Tim's position is .. no , the left hand knew all along what kind of stupid rule they were writing in and they are now consciously changing it because they recognize it was stupid in the first place.
:D
Flying Sting S4 ( N184WA ) out of Illinois

TimTaylor
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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 8:45 pm

Please don't speak for me. I'm saying the FAA does not intentionally write FAR's that are ambiguous and open to different interpretations. When they are written, the author knows precisely what the intent is. However, the FAR's, as written, are sometimes confusing and not as clear as the author intended. Also, they are sometimes changed for one reason or another.

I differ with anyone here who thinks you should NEVER ask the FAA for an interpretation because you might not like their answer.

If I was an active Sport Pilot CFI, I would never log instruction in a students logbook for Private Pilot training if I wasn't certain that time was allowed by the FAA. If I thought it might be, but wasn't sure, I would contact the FAA to find out.
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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 8:55 pm

drseti wrote:I've just skimmed the entire 53 page rulemaking, and must say this is a major victory for us all. My undying gratitude to our own Helen Woods, who pulled together and headed up the ad-hoc committee that drafted the initial petition to the FAA, something like 6 years ago. It was an honor and a pleasure working with you, Helen, and the results were certainly worth the protracted wait.
Commercial Pilot Airplane Single & Multiengine Land; Instrument Airplane
Sport Endorsement Airplane Single Engine Sea
Flight Instructor Airplane Single & Multiengine
Ground Instructor Advanced Instrument

TimTaylor
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Re: All training from Sport CFI now counts towards higher ratings

Postby TimTaylor » Wed Jan 09, 2019 8:57 pm

TDFlyer wrote:If i read the new rules correctly, you can't apply training from a Sport CFI towards a Private unless you actually have COMPLETED your sport rating?
"b) The holder of a sport pilot certificate may credit flight training received from a flight instructor with a sport pilot rating toward the aeronautical experience requirements of this section if the following conditions are met:"
Commercial Pilot Airplane Single & Multiengine Land; Instrument Airplane
Sport Endorsement Airplane Single Engine Sea
Flight Instructor Airplane Single & Multiengine
Ground Instructor Advanced Instrument


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