NRPM:CFI's to conduct Air Taxi Ops

[TaxiDriver]

I just saw this proposed NRPM on the Landings web site. Not sure if this has been discussed before on this board....

WHAT IS THIS GUY THINKING????

===========================

Dr. BW Creighton, an aviation lecturer at Butte College in Northern California (community education dept.), the author of IFR Made Easy, and a flight instructor, sent us (FAA) the following proposed NPRM:

"Abstract:
Certified Flight Instructors will be allowed to carry passengers for compensation or hire on VFR only flights of up to 300 nautical miles from the point of origin of the flight, and disembark those paying passengers at a destination airport other than the original departure airport. A Certified Flight Instructors must be a Citizen of the United States of America, have logged at least 1,000 hours of Pilot in Command time, must have been a Certified Flight Instructor for a minimum of two years, must have logged over 200 hours as a flight instructor in the aircraft category and type, if required, to be used to carry passengers, and would be limited to flying paying passengers in an aircraft not to exceed 12,500 pounds in gross weight and carrying no more than 6 passengers. The flight instructor to exercise these rights must possess a valid and current commercial pilot's license with instrument rating, a current flight instructor's rating, and a current second class medical certificate. Possession of the Certified Flight Instructor's rating and a second class medical will automatically authorize commercial-rated flight instructor to operate the above referenced, limited air taxi service as long as he/she remains an active flight instructor. Eligible persons would be exempted from the Part 135 checkride requirements for air taxi operations while working as a Certified Flight Instructor logging a minimum of 10 hours of instructor time every six months.

"We need to keep Certified Flight Instructors (CFI) in the occupation, and make the profession more "desirable" as a terminal career choice for those considering a career in aviation. I respectfully propose a new rule be adopted by the FAA allowing an exemption for CFIs to operate an air taxi service automatically under FAR Part 135." - Dr. BW Creighton

 

[Flywrite]

I saw this a few weeks ago and was dumbfounded. I guess it goes to prove that "Dr." and "Doofus" are not mutually exclusive titles.

 

[sanford&son]

harm????????????

if you guys don't like this idea, please share with us what the harm is in it. the poll on landings showed that most people were in favor of this (beyond the NPRM). just curious.

 

[Flywrite]

Well...

the flying public are generally ignorant of what goes on behind the scenes of an air carrier operation. They assume, as is their right, that when they book a flight, whether it be on Delta Airlines or Delta Joe's Flying Service, that the aircraft and crew operate within certain boundaries and to certain standards to ensure their safety.

The problem with this NPRM is that it establishes no standards. It specifically notes that these CFIs will be exempt from 135 checkrides. It makes no mention whatsoever of maintenance standards or operating specifications. It sounds to me like any old Joe with a CFI and athousand hours can start a charter service, and all he has to do to maintain it is give 20 hours of dual a year.

Even under Pt135 some carriers stretch (and occasionally break) the limits in order to make an extra buck. Imagine the situation if there were thousands of basically unsupervised charter operators competing for the public's dollar.

As for the Landings poll...all in favor were probably 1000 hour CFIs. They must be the only ones who think this is a good idea.

 

[desert pilot]

Flying for hire-commercial pilot,teaching-cfi,how does that mix?a cfi in many cases is less qualified, as teaching hours are not always real flying hours,if the he means cancel 135-maybe...

 

[sanford&son]

regulation

agreed, perhaps there was a bit of regulatory language that is missing from the NPRM. i however, do feel that the concept warrants further developement.

it sounds as though your opposition to this proposal is based on concerns for both pilot proficiency and mct quality. my friends, these are problems that currently plague GA, regardless of the addition of an air-taxi clause to the current list of cfi privileges.

i can see how we should be concerned that would-be taxi ops would not be held to a particular standard, but they would certainly not be exempt from the same basic airworthiness items that any other commercial operation must adhere to (min equip, annual, 100hr, and the rest). maybe you are worried about who would do the mtc? well, who is doing it now for places like mom and pop flight schools, banners/ sky signs, aerial surveyor/ photographers, aerial applicators, and many others? a&p/ia mechanics! i just don't see a NEW breed of renegade wanna-be mechanics popping up to do half @$$ mtc, just because now cfi's can run a LIMITED taxi service. there are mtc jack-@$$es like that around now, and they need to be stopped! that is a whole other issue, and the solution to that problem, does not lie in keeping pilots from flying.

do you guys propose that part 61 flight schools, or anybody else that operates an aircraft for compensation, be operated to part 135 standards? are the standards currently applicable to these types of ops not sufficient for a 300nm vfr air taxi?

i think that as with so much of aviation, insurance would be the buzz-kill for the dreaded 1000 hr cfi. even though it is "allowed" for an individual who is a cfi to buy an airplane and give lessons on his own, it is becoming increasingly difficult to obtain insurance for "one ship" operations, and from a liability stand-point, impractical. on that note, i imagine that insurance for the one ship "any ole joe," type service would be cost prohibitive, thereby greatly limiting this type of pilots ability to participate. however, current operators of flight schools, for instance, with numerous aircraft and existing coverage, might be able to jump in on this, as a source of additional income in a business that is often feast or famine.

again, while i conceed the need for additional language on this issue, i fail to see the real harm. the market will keep itself free of the flood of the bottom feeders you seem concerned about.

still trying to understand your objections,
-lamont

 

[mike]

What would you save? How would you benifit?

The minimums are set for safety. 1200 hours for people, 600 hours for boxes with the X-C, night and instrument. If you had to comply with the paperwork minimums for part 135 and the experience minimums for part 135, you would not save a penny.

An example might be "How expanded single engine operations have affected traditional twin engine part 135 operations?". Not much.

 

[TaxiDriver]

As for the survey on Landings.com, I have a feeling that the majority of those voted are CFI's themselves and probably excited about the possibilities of doing FAR 134.5

What I am trying to understand about the whole NRPM is this....if you are trying to get low time pilots to fly charter...why limit it to active CFI's??? Why not open it up to all Commercial pilots with over 1000hrs. Looking back to my days of instructing...I don't see anything that due to my CFI certificate made me qualified to fly Air Taxi.....I could have gotten the same x/c flying experience if I was just a non CFI paying for my time.


I have a feeling that those who are in favor of this NRPM will be low time pilots or CFI's that do not have much Air Taxi experience. Those pilots that will be against the NRPM will be ones who have extensive Air Taxi experience......if not , I would like to hear your thoughts on this one....

 

[FL717]

Its not a well thought out idea, polls aside, and fortunately will not come to fruition.

If you look at the quick bio on this "aviation lecturer" who proposed this idea, he authored a book entitled "IFR Made Easy". Maybe his next book should be called "Part 135 Air Charter Made Even Easier"!

 

[TaxiDriver]

Originally posted by FlyChicaga

"What about management pilots at many companies? They often do not fly often at all, sometimes only flying to retain currency due to time constraints associated with their job. How are they more qualified (hours aside) than a CFI who is in that airplane observing, and mentally flying that plane with the student?"

================================

Do you have a point??? Please don't tell me you think that a CFI who flies the pattern everyday is more qualified than a management pilot who maybe only flies 5 - 10 times a month, but travels over 30,000 miles. Please understand something, I don't believe anyone is saying CFI's shouldn't fly Air Taxi....it's just that they should be held under the same regulations as everyone else. So if you have 500 hrs TT, go find an airplane, write a few manuals and take a VFR checkride with the FAA.....we will keep this industry safe. Fair enough?

Oh yeah....I remember being a CFI...observing my students and mentally flying the airplane like you referred to.......

Management, charter and airline pilots alike go through the same thing....it's called Captain with new F/O or Experienced F/O with IOE Captain