Flight instructors as Charter Pilots

This proposal turned up on AVweb. It was sent to DOT as an idea on how to
make flight instruction a more viable career path by allowing flight
instructors to conduct limited air taxi flights without a part 135
certificate. I have rather mixed feelings about the idea, not least of which
whether it really would provide any economic benefits to career flight
instructors. Anyway, this is the proposal:

"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 Instructor 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 six 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
a 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."

--
Christopher J. Campbell
World Famous Flight Instructor
Port Orchard, WA


If you go around beating the Bush, don't complain if you rile the animals.

"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.

C J Campbell wrote:

must be a citizen of the United States of America

You know about "Equal Employment Opportunity"?

99% (give or take a few) of all citizens of this country do stem from
people who weren't citizens at one time.

Cheers,
Jens

--
I don't accept any emails right now. Usenet replys only.

"Jens Krueger" wrote in message
...
| C J Campbell wrote:
|
| must be a citizen of the United States of America
|
| You know about "Equal Employment Opportunity"?
|
| 99% (give or take a few) of all citizens of this country do stem from
| people who weren't citizens at one time.
|

Thought that one was a little funny myself. We allow non-citizens to be
airline pilots. Why wouldn't we allow non-citizens to do this?

"C J Campbell" wrote in message
Thought that one was a little funny myself. We allow non-citizens to be
airline pilots. Why wouldn't we allow non-citizens to do this?

may be the same reasoning that requires (unarmed) security personel
at the airport -- the ones who pat you down and check the contents of
your carry on for nail clippers or knitting supplies -- to be citizen,
while the machine guns holding soldiers patrolling the same airport do
not have to be...

--Sylvain

Wasn't this a long time ago?

Interesting idea, but I think there are serious practical hangups to
it - primarily the VFR restriction.

Most people chartering a plane are doing it for business reasons, and
need to get somewhere at a specific time and date. The VFR only
restriction make it difficult to dispatch (in many areas of the
country). And it probably will take only one flight delay that loses
a deal for the FBO to lose a customer for good.

Also, it could be said that this kind of legislation encourages
scud-running. I could see situations where the departure weather is
VFR, mid-way is MVFR, and destination is borderline IFR.

Per the regulation, the CFI can't do the prudent thing and file
instruments. A paying charter customer with an appointment at the
destination airport is a big incentive to NOT land, which means
scud-running... Not a big deal if you are familiar with the area, but
if not - it is dangerous, particularly in a fast moving plane.

-Nathan




On Thu, 22 Jan 2004 08:35:10 -0800, "C J Campbell"
wrote:

This proposal turned up on AVweb. It was sent to DOT as an idea on how to
make flight instruction a more viable career path by allowing flight
instructors to conduct limited air taxi flights without a part 135
certificate. I have rather mixed feelings about the idea, not least of which
whether it really would provide any economic benefits to career flight
instructors. Anyway, this is the proposal:

"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 Instructor 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 six 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
a 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."