Response to Subpart K Sport Pilot Instructor Petition
By Helen Woods, for Light Plane World
The following comment was posted to the Regulations.gov website in response to the petition submitted by EAA, AOPA, GAMA, and NAFI to allow for sport pilot instruction to count toward higher ratings.
I am the chief flight instructor of Chesapeake Sport Pilot, the largest light-sport flight school in the country. While most of our staff is certificated under subpart H, we employ one sport pilot instructor, and he is one of the finest instructors on our staff.
It does not seem logical that while he instructs using the same syllabus, same airplanes, same FAA test standards, and same DPEs [designated pilot exams] as everyone else on the staff, his instruction is deemed less valuable by the FAA than that given by other members of our staff.
The current interpretation has made it difficult for us to employ more sport pilot instructors, even those we trained ourselves. The reason is simple. Most students seeking a sport pilot certificate believe that they will eventually seek higher ratings and as such request a subpart H instructor so that all of their dual instruction received while obtaining a sport pilot certificate will also apply towards a private pilot certificate. As such, our sport pilot instructor is largely relegated to teaching elderly students who have no plans for seeking higher ratings.
We have a large enough operation (he is one of 16 instructors) that we can afford to hire an instructor with such a limited client base. However, as sport pilot is a relatively small market, most sport pilot schools are too small to hire a sport pilot instructor because younger traditional sport pilot students refuse to fly with them out of fear of the instruction not counting towards a higher rating. This effectively means that excellent sport pilot instructors across the country are currently unable to find employment to teach students seeking a sport pilot certificate.
As was pointed out in the petition for rulemaking, the current legal interpretation in question was never the FAA’s intent. Certainly these unfavorable economic consequences that are the fallout from this interpretation were also not the intent of the FAA. I urge you to support the sport pilot flight training industry. Please correct the wording of this rule to effectively allow sport pilot instructors to find employment teaching students seeking a sport pilot certificate by allowing that training to count towards higher ratings at a future date.
If you want to make your opinion on this issue known to the government, read the petition and comments from others and submit your comment online here.