> Display difficulties? View as web page
> Stay informed. Join our mailing list
> Be noticed, place an ad. Get our ad rates
> Join FSANA. Application here
June 2, 2022
FSANA Fully Opposes Republic Airways Petition Exemption for Restricted ATP Training Requirements
Republic Airways LLC (Republic) has filed a petition for exemption from C.F. R. 61.160 (a)
(click here to see the full request). FSANA has received much input since the petition was filed. A FSANA survey was recently conducted and 78% of the responses were 100% opposed to the FAA agreeing to the Republic exemption.

If the FAA were to approve the Republic request, pilots would be permitted to be seated in the right seat of Republic regional jets with 750 TT. This would be a 50% reduction from the current 1,500 TT rule. Congress passed the 2010 Airline Safety and Federal Aviation Administration Extension Act which was driven by the Colgan Air fatal accident in Buffalo, NY on February 12, 2009, which killed 49 people on board and one person on the ground.

Data in the past has shown a direct correlation between applicant practical test pass rates and periods of high instructor turnover. In other words, the more experience that a CFI has, the more likely the quality of the pilot candidate.

Bob Rockmaker, President & CEO of FSANA noted that the association has received several phone calls from flight training providers who said they would put their schools up for sale if the FAA approves the Republic exemption request. The increased CFI turnover rate will be devastating to their flight school model and decrease safety.

FSANA has identified several primary concerns with the request that include:

  • A deviation from regulatory practices that have served to produce the safest period of airline travel in the United States since they were implemented;

  • A fundamental flaw in the deviation request that attempts to indicate that the training provided in the Republic Airways process would meet and/or exceed that of military training, a statement in which FSANA does not agree;

  • A significant turnover of CFIs would result from further reduction of R-ATP experience requirements that would actually hinder the overall industry ability to produce more pilots;

  • That Republic Airways indicates that its training meets ACS/PTS standards which are a minimum standard, not an enhanced standard that would warrant a reduction in requirements due to higher standards in training provided.

There are other concerns with the exemption request but the fundamental points are that a reduction in R-ATP or ATP minimums right now will do more to harm the industry and decrease safety than enhance it in the opinion of FSANA and those in the flight training industry with whom we have received input.

FSANA welcomes input from members and the overall flight training community when issues such as this develop. The association is here to advocate on behalf of the best interests of the flight training community and our members. While we know there will be those within the industry with whom our position does not agree, we feel it is critically important that we remain focused on the mission of this association while also working to improve the overall flight training community to deliver a safe, vibrant, and healthy aviation sector.

FSANA encourages all interested parties to submit their comments to the Federal government on this critical matter. Please comment here: https://www.regulations.gov/document/FAA-2022-0535-0001/comment
Recommendations Regarding FAA Changes to CFI Renewal and Currency Requirements Presented by FSANA and Industry Representatives
On April 20th, 2022 FSANA brought together industry representatives from the training sector and aviation associations to discuss potential changes coming in currency requirements for CFIs and who would be eligible to train initial CFI candidates.

Meeting with over 20 representatives in Dallas, TX, the group discussed potential changes that have been rumored and some that have been indicated in official rulemaking publications by the FAA. While official final changes have not been produced in an NPRM by the FAA at this time, the group was concerned that potential changes should have input from the industry prior to the FAA publishing the NPRM.

The practice of collaboration and communication in advance tends to create better outcomes. Having industry input helps to influence what changes the FAA may consider and are finally produced in a NPRM that would then receive comment from the industry prior to implementation of any final changes.

The aviation system in America has been changing over the past 24-36 months and processes and systems that perhaps might have worked then are now time dated.
ARAC's and ARC reports that were completed 4-5 years ago in many cases are timed out due to changes that have come about within the aviation industry.

"The first goal is to always ensure that we have a safe training system," said FSANA President & CEO Bob Rockmaker. "We support changes that could enhance efficiency as long as the quality of training is maintained and the changes are such that all training providers are able to do business on a level playing field. Changes to training regulations should not be promulgated to meet one specific interest group, a carve-out, based on political influence."

A result of the meeting and its work over the past month since the meeting is a position paper that is being shared with the aviation community suggesting the following changes be considered. The group suggests that the FAA:

  • Transition to a process that does not require subsequent reissuance of a physical CFI certificate when renewed and that the tracking of currency or reinstatement after a lapse in currency can be completed through a digital airman registry tracking process. Also, the FAA should not reduce or remove the current regulatory requirements to maintain the eligibility to exercise the privileges of a CFI.

  • Add to 14 CFR 61.183 a requirement for “3 hours of flight training with an authorized instructor in the category and class of aircraft in which the test will be given in preparation for the practical test, which must have been performed within the preceding 2 calendar months from the month of the test.” This would ensure at least a minimum amount of training from an authorized instructor specifically related to the issuance of the initial CFI certificate and is a parallel requirement as is currently in place for all other initial certification levels and the instrument rating, but not in place for a CFI certificate aeronautical experience requirement.

  • Amend 14 CFR 61.195 (h) by removing the words “who serves as a flight instructor in an FAA-approved course for the issuance of a flight instructor rating. ”This will allow flight instructors who meet higher hours of total flight instruction with a positive demonstrated pass rate to provide training to initial CFI applicants sooner in all sectors of aviation training; not just as a part of an FAA-approved 141 course. This will maintain quality while expanding the potential human resource base of instructors who can provide for initial CFI training.

  • Ask that the FAA establish an Aviation Rulemaking Advisory Committee (ARAC) Working Group and/or Aviation Rulemaking Committee (ARC) should any further changes of Restricted ATP (R-ATP) requirements be considered prior to any NPRM issuance.

The workgroup agreed these specific changes would potentially enhance the throughput of training and reduce regulatory burden, while at the same time not reducing safety in our training system.

The full recommendation has been sent to the FAA for their review in any future regulatory change proposals they develop.

A fuller document including more background and detail of the recommendations is available by clicking here.
Fuel Pricing Driving Price Increase for Aircraft Use According to Survey Results
Fuel prices are a factor in many sectors of the economy currently, and flight training is no different. To help understand how it is affecting flight training, this past week FSANA did a quick survey of our contacts to learn more about if fuel price increases are being implemented and how they are being done. We also asked about how big of increases are being implemented. Here is what we found.

The vast majority of respondents have indicated that they have implemented increases in flight training aircraft use costs due to fuel prices.

With increases in fuel prices around the country, has your flight training operation had to increase aircraft rates to customers at this time?
  • Yes - 83%
  • No - 3%
  • Not yet, but we expect to soon - 12%

When it comes to how locations are implementing price increases, it was relatively close in percentages between whether a price increase is implemented using a per hour surcharge or increasing the hourly base use rate.

If you have increased prices or are going to, how have you done it?
  • A fuel surcharge per hour - 51%
  • Increase the base rental rate per hour - 48%

We also asked about how much the increase was in their experience. This is what we found:

How much of an increase in price have you or are you going to implement at this time? (for single-engine aircraft)
  • $0-$5 per hour of use - 15%
  • $6-$10 per hour of use - 38%
  • $11-$15 per hour of use - 27%
  • $16-$20 per hour of use - 10%
  • $21-$30 per hour of use - 3%
  • More than $30 per hour of use - 3%

We also took open ended comments as a part of the survey and some of the highlights included comments that noted the following:

  • Many expect to have to increase prices more in the future;

  • The increase is starting to affect students' ability to pay for training or train as frequently;

  • Fuel isn’t the only price increase being experienced, oil, parts, and lack of supplies to keep the aircraft flying are also driving price increases

There is no doubt that the variable costs affecting flight training providers will affect the prices that those seeking pilot training will incur. As prices go up, it becomes more challenging for those seeking aviation careers to pay for the training they seek. FSANA will continue to engage with the training community and track these effects and share what we find with our members and readers.
Results of Designated Pilot Examiner System Survey by Middle Tennessee State University
Recently, Wendy Beckman from Middle Tennessee State University conducted a DPE System Survey attempting to better understand many of the concerns, opportunities, and factors affecting the provision of practical tests around the United States.

The survey received a robust response from DPEs and the flight training community. Some of the topics in the survey directed related to the current state of the DPE system and some of the major recommendations of the DPE Reform Working Group (DPERWG). Over 300 DPE’s and 770 flight schools participated in the nationwide survey. Perspectives between DPE and flight school respondents differed regarding the current availability of check rides, with flight schools perceiving a greater issue. Specifically, DPE’s indicated less than a two week wait for a check ride for 80% of applicants, while flight schools indicated less than a two week wait for only 40% of applicants. In addition, significantly more flight schools (83%) perceived there were too few DPE’s available in their geographical area than did DPE’s (21%).

There was agreement between the two groups that approximately 20% of applicants travel outside of their geographic area for a check ride, and that an additional 20% of check rides are conducted by DPE’s who have traveled outside of their geographic area. Due to the nature of geographic boundaries in some cases this does not mean a significant distance was traveled, but given that 94,000 check rides were conducted by DPE’s in 2021 this does mean over 37,000 check rides were done were either the applicant or the DPE were outside their geographic area.

Importantly, there was significant agreement from both groups on several of the recommendations from the DPERWG. These included:

  • The need for improvement to the current FAA’s DPE locator website, which was perceived as effective by only 50% of both DPE’s and flight schools. Many comments were provided regarding the need to make the locator more user-friendly, especially regarding authorization types and the provision of additional search parameters such as city name or zip code. Flight school respondents indicated the ability to see check ride availability of DPE’s and even schedule check rides through the website would be advantageous.

  • Strong support for DPE’s to be able to conduct an oral test even if it were unlikely a flight test could proceed after successful completion of the oral (i.e., due to weather). There was strong consensus by both groups (86% support by both) that this change would be beneficial. There was also agreement that a flight test should not be administered if the oral test was not completed successfully, although DPE’s had a stronger preference on this item (81% agreement) than did flight school personnel (59% agreement). 

  • Strong support (80% from both groups) for allowing DPE’s to conduct check rides under the provisions of BasicMed as appropriate by aircraft and operating requirements, versus continuing to require a minimum of a third class medical for all DPE’s. There was less support for allowing DPE’s who are no longer able to maintain their medical to conduct oral tests (62% agreement by flight schools and 49% agreement by DPE’s).

  • Solid support for the development of a confidential survey feedback system, administered by the FAA, by which applicants are encouraged to complete a survey regarding their check ride experience (82% of flight schools were in favor, and 56% of DPE’s were in favor or had no preference about the implementation of such a survey).

Only national level analysis has been conducted on the survey results at this point, with more detailed analysis (i.e., by geographic region) planned in the near future. A complete summary of the results of both the DPE and flight school surveys can be reviewed in the full document by clicking here.
FAA Launches Real Time Tracking of Medicals
The FAA has added a new feature to MedXPress that allows pilots to track the status of their medical certificates online throughout the application and review process. Prior to adding this new feature, pilots had to call the Office of Aerospace Medicine to check their application status.

“If you can track where your ridesharing car is or the status of a company delivering your package, pilots should be able to see online the real-time status of their application,” said Federal Air Surgeon Dr. Susan Northrup. “We will continue to explore how we can be more transparent with the aviation community.”

As soon as an application is submitted, it will appear in the pilot’s MedXPress profile. Status updates will change as the application moves through the FAA’s review process. If an application is deferred or denied, the applicant will receive detailed information through the mail. The certification process itself does not change. You can learn more about FAA’s medical certification process at:
Former members of the FAA's Women in Aviation Advisory Board (WIAAB) and former FAA administrators recently discussed recommendations from the WIAAB's report to Congress to ensure a safer, more innovative, and prosperous aviation industry by recruiting, retaining, and advancing the best possible talent.

You can see the replay of this webinar by clicking here.
Save the Date - International Flight School Operators Conference will be in Orlando March 1-3, 2023
Plans for the 14th Annual International Flight School Operators Conference are moving along. The 2023 edition is returning to the Rosen Plaza in Orlando, Florida, on March 1-3, 2023.

More information is forthcoming, but for now, mark your calendar to join FSANA and a wide variety of industry partners and fellow flight training providers for the event that each year brings these groups together.

DPEs Available to Travel
FSANA has been collecting DPE names who have expressed a willingness to travel to help flight training providers secure practical tests.

An up-to-date List of Travel-Willing DPEs with contact information is available on the FSANA website. If you are a flight training provider who is finding a challenge of scheduling DPEs in your local area, feel free to reach out to these individuals. They may be able to serve some of your local testing needs.

While this effort is being made in general, it is even more relevant as many DPEs self-selected to delay a return to providing practical tests during this period of COVID-19 uncertainties.

If you are a DPE who is not on this list but would like to be, please let FSANA know by emailing us at info@fsana.com with your name, city, state, email and phone number and we will add you.
Have feedback concerns about FAA practical tests? Email inquiries here
Practical Test Feedback
Email Feedback Concerns about FAA Practical Tests to:

Tell us what is important to you as a school owner, manager or chief flight instructor. We will share comments in an upcoming edition of Flight Training News. Send your thoughts to info@fsana.com.
V I S I O N A R Y •• P A R T N E R S

D E V E L O P E R •• P A R T N E R S
B U I L D E R •• P A R T N E R S
L E A D E R •• P A R T N E R S
Established in 2009, the Flight School Association of North America (FSANA) is the first and only association of its kind dedicated solely to the flight training industry. FSANA represents flight schools, firms that provide products and services to the flight training or aviation industry, and other supporting partners.

The Mission of the Flight School Association is to support, promote and advocate for the business of flight training; to provide knowledge, programs and services that help its members thrive and better serve their customers and communities; to foster best business practices; to educate and inspire youth; to increase the global pilot population; to improve general aviation safety; and to work in alliance with the aviation and aerospace industry.

fsana.com / 610-791-4359 / bob@fsana.com