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EAA Submits Comments on Sport CFI NPRM

August 25, 2016 - EAA has submitted comments on an FAA notice of proposed rulemaking (NPRM) that, among other provisions, responds to a longstanding EAA request to allow time logged with a flight instructor with a sport pilot rating (Sport CFI) to count toward higher ratings. Current FAA policy only allows time logged with a Sport CFI to count toward the sport pilot rating, whereas time logged with a traditional CFI toward a sport pilot certificate can be applied toward the dual training requirements of higher ratings such as the private pilot certificate.

The FAA’s proposal in the NPRM is to allow time with a Sport CFI to count toward up to half of the dual requirement for higher ratings, although the agency also noted they were willing to consider allowing unrestricted credit for such time. EAA urged the FAA to implement the latter choice.

“There is no safety benefit to the limit [on credit for hours proposed in the NPRM],” EAA wrote in its comments. “The light-sport certificate provides the pilot with the same fundamental knowledge that any other certificate is built upon, and a [Sport CFI] is equally capable of delivering instruction on any of these points as any other CFI.”

EAA also noted that requiring students and DPEs to sort out which instructors have particular ratings is a recordkeeping and administrative burden, particularly if a student resumes training at a later point and is unable to verify if a former instructor is a Sport CFI or otherwise.

“We are very happy that the FAA took action to fix this shortcoming in the sport pilot rule,” said Sean Elliott, vice president of advocacy and safety. “We hope that the agency will adopt a straightforward and common-sense approach to crediting hours toward higher ratings, and not needlessly overcomplicate the process.”

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