"C J Campbell" wrote in message
I have rather mixed feelings about the idea, not least of which
whether it really would provide any economic benefits to career flight
instructors.

It sounds like an attempt to legitimize what many are doing already (a
one-way flight lesson). The proposal doesn't readily explain how the general
public will be protected. The general public depends on pilots and operators
for their safety because the general public generally lacks enough knowledge
to know what is safe and what is not. Flight students are dependent for the
first few lessons but then quickly acquire enough knowledge to be able to
decide for themselves what is safe. That's why those of us who hold out to
the general public are held a higher regulatory burden.

What about insurance? This is a huge cost for me as a charter operator. I'm
required to carry a lot more insurance than my friends who operate flight
schools, just in case. Perhaps the proposal should include a clause for the
instructor to hand out a statement about the insurance he holds. At the top,
in large print, will be the following statement- "Who are your heirs going
to sue?" Or how about "Fly first class, or your heirs will!"

What about checkrides? I'm sure a 1000 hour CFI can fly 300 miles just fine.
However, I have given many, many flight evaluations to 1000 hour CFIs. Many
had extreme difficulties maintaining VFR on long cross-countries. Many had
trouble handling simulated emergencies. Some had situational awareness
problems. All of these CFIs will qualify to haul the general public under
the proposal. All were weeded out by the additional training and checkride
requirements imposed on legitimate charter operators.

What about accountability? The proposal doesn't mention anything about
paperwork. How does the proposal propose to prevent a fatigued CFI from
endangering a passenger? It's a big problem for those of us required to take
rest breaks (with documentation of such to hold us accountable). Why make it
a bigger problem by allowing a CFI with no requirements for mandatory rest
requirements to haul the general public? This is one of the big changes
coming for Part 91 time-share operators because it's a serious problem.

There's more, but I'll stop with a question about the proposal's requirement
to be a US citizen. 'Having the right to gainful employment' would be a
better way to word it. Just another example of the proposal not be fully
thought out.

D.