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GA Groups: Sport Pilot Instruction Should Count Toward Additional Ratings


February 10, 2011 — EAA, AOPA, GAMA, and NAFI have collaborated to formally request that the FAA initiate a process that would change the rules that currently prevent instruction time received for sport pilot training from being applied toward additional certificates and ratings. The groups submitted a petition that asks the FAA to begin a rulemaking process. When it was created, the sport pilot certificate was intended in part as a less expensive entry into the world of general aviation, and for some pilots a stepping-stone to higher certificates.

The FAA’s proposal of the sport pilot rule in 2002 said, “Under this proposal, certificated sport pilots could credit ultralight flight time toward higher-level certificates, which would increase the experience level and qualification of sport pilots.” Specifically, the groups have asked the FAA to amend FAR Part 61.99 and 61.109 to clearly “permit the instruction time received in pursuit of a sport pilot certificate to be credited towards the instruction requirements of additional certificates and ratings.”

Anyone wishing to obtain a recreational or private pilot certificate would still be required to obtain training from a subpart H CFI on all areas defined under the knowledge and flight proficiency requirements of that certificate. They would also be required to complete the elements that sport pilot instructors cannot complete, such as night training and three hours in preparation for the practical exam. 

A 2009 letter of interpretation from the FAA argued that allowing training provided by a CFI-S to count toward the aeronautical experience requirement for a private certificate “would be the functional equivalent of permitting that instructor to provide flight training for the issuance of the private pilot certificate with those ratings.”  It has been suggested that flight training given by a sport pilot instructor (CFI-S) could not be credited toward the hour requirements for future certificates and ratings, such as the private or recreational certificates. 

EAA, the Aircraft Owners and Pilots Association (AOPA), the General Aviation Manufacturers Association (GAMA), and the National Association of Flight Instructors (NAFI) are petitioning the FAA to change the regulations with the belief that training received from a sport pilot instructor should count toward other certificates and ratings.

“Experience begins to accrue the very first day that a student pilot sits behind the controls of an aircraft,” the petition reads. “The aeronautical experience obtained in pursuit of a sport pilot certificate should not be discredited, in essence resetting the clock on aeronautical experience as if that sport pilot was an initial student with no previous experience.”

Allowing sport pilots to transition more smoothly to higher certificates and ratings would not compromise safety, the groups said; in fact, it would give sport pilots greater incentive to pursue higher certificates. Safety is enhanced as a pilot receives additional training and pursues higher certificates and ratings, the groups said.


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