(Snowbird) wrote
In my opinion, the real solution is to change the FAA rules so
that there's a realistic way for wanna-be professional pilots to
build the hours they need without flight instruction. Then we
can hear bellyaching about 'slavery in aviation' flying night
cargo or pipeline patrol or what-have-you.

The issue is not FAA rules. According to the FAA, you can fly
pipeline, drop jumpers, tow gliders, fly aerial photo missions and
sightseeing flights, crop dust, tow banners, or even fly passengers
and cargo for a company (assuming it's business is not the transport
of passengers or cargo) as soon you get a commercial, and in some
cases sooner. You can be PIC in a Part-135 charter at 500 hours, and
SIC (required for passenger-carrying IFR unless there is an autopilot
AND the PIC has 100 hours in make and model) with no hour minimums at
all. The FAA rules are NOT the culprit here - they are actually quite
liberal.

The issue is this - the vast majority of CFI's at the vast majority of
flight schools are simply not qualified to do those jobs - in reality
rather than on paper. In some cases, where the aircraft are insured,
the insurance companies set the experience and training requirements.
In other cases, the owner of the aircraft will do it. Either way,
someone with a solid understanding of what is necessary to maintain an
adequate level of safety WHILE GETTING THE JOB DONE is doing the
hiring.

I've towed for an operation where the insurance minimums are well
above FAA minimums, and the owner still rejects quite a few pilots as
unsuitable. At least half the tow pilots have run the planes out of
gas. When a full load of fuel is just over 30 minutes at full
throttle, when all flying except the descent is done at full throttle,
when the minimum reserves are only 8 minutes at full throttle, and
when pilots are flying 4+ hours including 20+ taildragger landings
(often downwind) on a hot summer day that's going to happen - there's
simply too little margin for error, and by the end of the day the
pilots are always tired, often hungry, and sometimes dehydrated.
There has never been an accident or an insurance claim at this
operation due to fuel exhaustion - every one of the pilots involved
dead sticked the airplane back into the field without damage. This
goes all the way up the food chain in such operations - I know a jump
pilot who had to dead stick a King Air for the same reason. You can
bet his job isn't going to some kid with 50 hours of multi time in a
Seminole and a high performance rating - even if he does have a
college degree and a clean record (the pilot in question has neither).

You can talk about judgment and being a safe pilot until you're blue
in the face - the owner knows the reality. Small GA operations are
always on the edge of profitability (often the wrong edge) and the
safety margins often have to be reduced to get the job done. When
that happens, mistakes are going to be made. Unless you want to lose
your aircraft or your insurance coverage, you want a pilot with the
skills to recover from the mistakes he will inevitably make. The
average low time pilot lacks these skills, and adding ratings does
NOTHING to rectify this shortcoming.

You also want a pilot who won't make too many mistakes - because
nobody is good enough to pull it out 100% of the time, especially not
the guy who thinks he is. That means you want a pilot who knows how
to tell the difference between an operation where the safety margins
are reduced (perhaps illegally) but still acceptable and an operation
where the safety pargins are simply too small (or non-existent). A
pilot who 'just says no' any time the flight is uncomfortable is
useless to you, but so it a pilot who will simply take any flight, no
matter what. The former won't get the job done, and the latter will
crash sooner rather than later. You're looking, in other words, for a
pilot with good judgment. The average low time pilot lacks such
judgment, and adding ratings does NOTHING to rectify this shortcoming.

The reason unskilled low time pilots can't get flying jobs other than
instruction has nothing to do with the FAA - the reason is simply that
they are low time and unskilled.

Being a CFI is the ONLY flying job I can think of where you can
usually get in the seat just by meeting the FAA requirements.
Therefore, the pilots who can't pass muster for any other flying job
instruct - until they can get some other flying job.

So what makes being a CFI so different from other flying jobs? Why
are insurance requirements so lax? Mainly it's because there's no job
to be done. The only real job the CFI has is to keep the hobbs meter
running and the student coming back for more without bending the
aircraft. If the student happens to actually learn something in the
process, great - and if he learns enough to pass a checkride,
wonderful.

But I think it would be a dramatic improvement for student pilots.
They could be taught by people who want to instruct, and since
there'd presumably be fewer CFIs FBOs which wished to retain them
would have to treat them rather better.

Well, that's all true - but since we probably don't want airplanes
falling out of the sky because they're being flown by unqualified low
time pilots, some other solution is necessary.

The logical one is to effectively separate career track instruction
and recreational instruction. Here's how I would do it:

For Part 61 instruction, require 250 hours of PIC/NI
(non-instructional) time. That means dual given doesn't count, dual
received doesn't count, any solo flights used to satisfy the
requirements of a certificate or rating you hold don't count, and any
hood time and safety pilot time don't count. Eliminate the
stand-alone private under Part-141 - make the initial rating
private/instrument (some schools already do this). In other words,
make the program unattractive to non-career students. Career students
would not be affected, since they all go straight to the instrument
anyway.

The idea is this - the graduate of your average flight academy
(diploma mill) CFI/CFII/MEI has about 250-300 hours total time, of
which AT MOST 100 hours is PIC/NI. At this point, if he can either
shell out the money and buy 150+ hours (unlikely) or get a non-CFI
flying job and build 150 hours+ (even less likely) he can instruct
under Part 61. Otherwise, he can instruct for a Part 141 school,
teaching exclusively professional students - and none of the time he
logs in the process will get him any closer to being able to instruct
under Part 61.

Michael