After years of requiring applicants to operate a complex aircraft in order to earn a commercial pilot certificate (single-engine airplane) or a flight instructor certificate, the FAA recently reversed its own standards to allow commercial applicants and CFI applicants to take the practical test in an aircraft that isn’t complex. No retractable gear, no constant speed propeller. A Cessna 152 will suffice.
As it happens, I earned my Commercial Single-Engine ticket, and my CFI, in a Cessna 152. The school I went to was crafty in its methods, and I appreciate the effort they put into making everything work out for my fellow students and myself.
We demonstrated proficiency in complex aircraft. We just didn’t do it on our single-engine commercial or CFI checkrides.
We earned our private pilot certificates in a C-152, then moved to the C-172 for instrument training. Our next conquest was the private pilot multi-engine rating, which we earned in either a Piper Seminole (the more popular choice) or the Seneca (my choice). The Seminole and the Seneca are both complex aircraft.
Our journey to professional pilot-hood was well underway.
We built a lot of time in C-152s as we prepared to step up to our multi-engine commercial tickets in those same Senecas and Seminoles. Then we added our single-engine commercial tickets in the C-152s we’d been building time in. No complex aircraft was required as we’d already demonstrated our abilities when we earned our multi-engine ticket.
Similarly, we earned our multi-engine instructor certificate before we applied for our CFI ride, which meant we could (and we did) fly Cessna 152s when we took our flight instructor practical test.
Almost all of us went on to fly C-152s, C-172s, Tomahawks, Cherokees, and Warriors at the flight schools where we earned our first professional dollars as pilots. All fixed gear airplanes with fixed pitch props. Although many of my old classmates now fly turbines across oceans for a living. Additional training made that possible.
Training is a lifetime commitment. We knew that going in.
This new rule change suggests that although complex training (and ostensibly) a complex endorsement is required to be recorded in the applicants log book, a new single-engine commercial pilot applicant can show up for his or her checkride with a C-152 and be allowed to take the ride. Just as I did all those years ago.
That’s progress in my book. Simple, cost-effective, and productive. I like it.
Now, in a perfect world, or at least one inhabited by rational, thinking human beings, that willingness to review and revise standards would also extend to your home town airport and mine. Consider this prime example of where that might be applied to great effect.
A vast majority of publicly owned airports include a document in their files known as the Minimum Operating Standards. Since these publicly owned airports are often operated by a municipality or a county with little understanding of aviation, and equally limited interest in the industry, they adopt a boiler-plate wording for their standards. It’s expedient and inexpensive to do so. It’s not necessarily in their best interest, however.
At my hometown airport, the minimum standards specify that a flight school will maintain a minimum of three airworthy aircraft, one of which will be a single-engine and one of which of which will be a multi-engine aircraft.
Why? That makes no sense. Can you imagine a commercial real estate leasing company requiring specific inventory to be in place at the stores they lease space to? It’s inconceivable.
Interestingly enough there are three flight training operators on my home field. Of those three, none has, nor has any use for, a multi-engine aircraft. Yet they operate successfully from a field where the official Minimum Operating Standards specifically documents their non-compliance.
Here’s my suggestion. Craft Minimum Operating Standards for your local airport that actually represent your Minimum Operating Standards.
Here’s the crux of the issue. If your airport’s rules specify that you have to have a multi-engine aircraft on the line to conduct flight training of any kind (and that is exactly what many standard MOS documents say) you’ve in effect told flight training operators that the only way to operate on your field is to do so at a loss.
Yes, at a loss. Your airport administration is asking a business to invest a significant amount of money into a piece of equipment that will be rarely, if ever, used, yet will cost thousands of dollars a year in maintenance.
How much? If the multi-engine aircraft in question was built any time in the last 30 years, a $250,000 investment would not be unreasonable. Other than the requirement itself being unreasonable to the point of counter-productivity.
Consider this instead, “Flight training providers must provide airworthy aircraft appropriate to the type of flight training being offered.”
That’s it. One well-worded sentence gets the job done. A school that specializes in primary training might have just one or two light singles on hand. An operator who does taildragger transitions might operate a Champ or a Cub. The provider who specializes in high performance IFR training might operate a Cirrus, or a Bonanza. And there’s still room for the operator who wants to do multi-engine instruction. Everybody is happy.
In short, recognize that your minimum operating standards are an indication of how welcoming your facility is to commercial operators. Develop standards that attract businesses to operate at your field. Scrap standards that are arbitrarily restrictive, effectively shunning potential tenants and employers.
If the FAA can see the light and reverse a restriction deemed unnecessary, certainly your local airport can find language in its documentation that is similarly outdated and in need of revision.
Let’s make that airport more appealing to providers. They’ll find a way to make it more appealing to customers — and your municipality or county will benefit in the long run.