Recent Changes to Part-61 and Why They Are FANTASTIC!

By Rod Machado

Am I happy about the recent changes to FAR Part 61? You bet I’m happy. These changes will be helpful to general aviation in much the same way a corkscrew is to a Frenchman on Bastille Day. Considering all the (well deserved) grief I've given the folks on the FAA's ACS committee for the past five years, it's nice to give a pat on the back to a group of individuals within the FAA for doing such a wonderful thing to promote aviation.

Before discussing these changes, let me identify what appears to be the FAA’s underlying motivation at making them. First, the FAA seems quite concerned about the cost of flight training in today’s aviation market. That’s refreshing. For this reason, the FAA offers an estimation of the cost-reduction and benefits-increase that these changes might provide for both the career-path and recreational/business aviator. Let it be said that the FAA did a good deed for general aviation with these changes. It’s a deed worthy of popping a cork or two.

So here are a few of the highlights of these recent FAR changes and my commentary. You’ll have to read then entire preamble if you want the interesting little details, which actually aren’t so little.

First, the FAA now allows instrument rated pilots to accomplish instrument recurrency in an FFS, FTD or ATD without having an instructor present. (A FFS is a full flight simulator. It’s the real deal. Think “Flight Safety” or “Airline training” simulators. A FTD, however, is not a machine used to deliver flowers. It’s a flight training device—think Frasca’s Piper Seminole FTD. An ATD or aviation training device is of lesser sophistication but still worthy. Think Frasca’s Cessna 172 Mentor.)

Consider the FAA’s reason for making this change. If you could retain your instrument currency with a non-CFI safety pilot in an airplane, why do you need a CFI in an ATD or FTD to do the same? Well, you don’t, or shouldn’t. Instrument “recency of experience” isn’t about training, it’s about recent “experience.” The FAA wisely suggested that instead of decreasing safety, this change will allow pilots to acquire more “experience” on their own. It will also reduce the cost of acquiring this experience and make it more likely that pilots will practice important skills such as handing equipment failures and flying different approaches in variable conditions. Bravo! Vive la Frasca! (or any other ATD, FTD manufacturer).

Second, the FAA now allows pilots to accomplish the 10 hours of required flight training for the commercial airplane certificate in either a complex airplane or a technically advanced airplane (TAA) or any combination of the two. (This rule becomes effective on August 27th of this year.) For the purposes of this discussion, the FAA considers a TAA to be an airplane with a primary flight display (PFD), a multi-function display (MFD) and a two-axis autopilot capable of holding altitude and tracking a “predetermined GPS course or heading selection and… able to hold a selected altitude.” There are many variables regarding this equipment in the NPRM, but that’s the gist of it.

That said, this ruling is FANTASTIC! Now, for those of you who know my predisposition to basic stick-and-rudder training, you might find your wheel pants in quite the bind here. So let this heretic explain why this change is so great.

Today’s commercial pilot applicant—think captain Rushmore—won’t be flying an ancient Boeing 707 accompanied by three other flight crew members who stare at a panel full of needles, numerals and toggles and worry about the life span of their vacuum-tube driven autopilot. Instead, two pilots (or one pilot and one pilot trainee) will be interfacing with an aircraft so sophisticated that it can fly itself safely to any destination with very little intervention by the interfacing specialist (the person who is still called a pilot, today). When I look at the trajectory of aviation technology, I don’t ask myself, “What do I want to see?” Instead, I ask, “What do I see?” What I see are airplanes needing less and less stick-and-rudder skill to fly while needing more interfacing skill to operate (think FMS, AI, buttonology). If that offends your romantic notion of flying airplanes, then I do feel your pain. The romantic side of me longs for pilots to retain the authority, independence and stick-and-rudder skill-set of yesterday’s commercial aviation culture. What I don’t desire is the high accident rate concomitant with yesterday’s commercial aviation culture. That’s why technology is gradually replacing cockpit participation by commercial airline pilots on several levels. You can’t have as much human error “in the cockpit” if humans don’t participate as much “in the cockpit.” (Yes, you can have other types of errors but this isn't relevant to our discussion here.) 

Clearly, the FAA recognizes this trend in aviation technology. Allowing a commercial pilot applicant to use a TAA to meet the 10-hour training requirement will assist that person in adapting to today's and tomorrow’s commercial aircraft. Yes, there are other good reasons for this change, not the least of which is the decreasing availability of complex airplanes for rent or the mechanical reliability of those same airplanes.

As the FAA sees it, a "...demonstration of proficiency in an airplane that is electronically complex will be comparable to the demonstration of proficiency in an airplane that’s mechanically complex." If you think about it carefully, that’s a very insightful statement by the FAA. Knowing how to control the landing gear and adjust propeller RPM will be a great skill to have if Southwest airlines starts operating Lockheed Constellations in lieu of 737s. However, fidelity at using complex PFD/MFDs and autopilots is a skill set more applicable to today’s and tomorrow’s commercial flying machines.

Finally  we come to the BIGGEST and the BEST change of all. The FAA now allows all flight training time received from a sport pilot instructor to apply toward meeting the flight time requirements for the recreational or private pilot certificate. NOTE: The only catch is (and I'm eating crow here because I didn't catch this when I originally wrote this post) the applicant applying that flight time to the private pilot certificate must already have a sport pilot certificate. Said another way, you can apply sport pilot flight time to a private pilot certificate only if you've first earned a sport pilot certificate.

For years I’ve advocated resurrecting an old (circa 1956) FAA certificate known as the Limited Flight Instructor Certificate or LFIC. This certificate allowed non-instrument rated private pilots to train others to be private pilots. The program was successful in 1956, then the FAA eliminated it for reasons having nothing to do with safety. I was a fan of the LFIC for one very important reason: Limited flight instructors were likely to train others (think friends and family) because they “wanted to do it” and not because they “had to do it” (think, “Time builders who might not be responsibly committed to training their students properly”). Well, guess what? This rule change provides us with many of the benefits of the LFIC.

As you know, you can become a sport pilot instructor with a minimum of 150 hours of flight time. This rating allows you to train others to become a sport pilot. Yes, a sport pilot instructor has to demonstrate the same ability to teach as a traditional CFI candidate (known as a “Subpart H” instructor). He or she doesn’t, however, need an instrument rating and a commercial airplane certificate. Obtaining a sport pilot instructor rating is a lot less expensive than obtaining the traditional CFI certificate. As a result of this rule change, the training provided by a sport pilot instructor in a light sport airplane can be applied to flight time requirements of the recreational or private pilot certificate (we’re assuming training in the same category and class of aircraft, of course). Therefore, the sport pilot instructor has almost the same ability as the LFIC once did. There are, however, a few restrictions to consider.

First, the sport pilot instructor can provide the instrument instruction required by the sport pilot, recreational pilot and private pilot regulations. To do so, however, the sport pilot instructor must take at least three hours of flight training and one hour of ground training on maneuvering by reference to instruments from a traditional CFI (a Subpart “H” instructor). Second, since sport pilots (and sport pilot instructors) can’t fly at night, the night training required for the private certificate must be given by a traditional CFI. Since sport pilots are not required to receive training in “recovery from unusual attitudes” while private pilots are, this training must be provided to private pilot applicants by a traditional CFI. Finally, it’s the traditional CFI that must do the three hours of flight training preparation and provide the sign off for the practical test. So no matter how skeptical you are about this change in regulation, a recreational or private pilot applicant trained by a sport pilot instructor isn’t going to escape being evaluated by a traditional CFI and pilot examiner before becoming certificated. Yes, there are many more subtleties in the preamble to these reg changes, so you might want to read it yourself…when you have time to consume 50+ pages.

Am I happy with this change? You bet I am. There’s a lot of good here for aviation and the FAA is to be commended for its logical reasoning and its ability to resist some of the well meaning but ill considered arguments offered against these regulation changes. Once again, BRAVO! Well done.

By Rod Machado | | All Rod's Posts, CFI Resource Center, Your Flying Career | 6 comments
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  • Dave Bonnar - September 02, 2019

    What’s the latest on this? Have interpretations been clarified? I’m a PP w/AGI today, considering CFI-Sport to avoid the added time/expense of an Instrument Rating that I wouldn’t use.

  • George Charles Allen - October 20, 2018


    I am curious if you have any insight as to why this roadblock may have been … overlooked? Or purposefully engineered? According to the FAA Final Rule explanations:

    **Flight instructors with a sport pilot rating are trained and tested on the same fundamentals of instruction as a subpart H instructor.

    **Flight instructors with a sport pilot rating provide flight training on many of the same tasks and maneuvers as subpart H instructors because many of the training requirements and practical test standards for the recreational and private pilot certificates are identical to those required for the sport pilot certificate.

    **As stated in the NPRM, ten of the twelve areas of operation required in the airplane practical test standards for private pilot are also listed in the airplane practical test standards for sport pilot.

    **These areas of operation must be performed to identical standards.

    So … if that is the case, I could see a few solutions to this conundrum. The easiest being a minor amendment to the rule that allows for a CFI-L (limited) who would be able to teach, without limitation, sport, recreational and private only.

    What would that look like? Well, if a CFI-S can teach sport pilots, and their training is good enough to qualify for the majority of private training requirements because the FAA considers it to be at the same standard. Why not allow a CFI-L designation for a fully certificated Private Pilot to teach sport, recreational, and private?


    George Charles Allen
    AOPA Flight Training Advisory Board Member

  • Hal Ellis - July 21, 2018

    Rod – I’ve noticed no one is commenting on the IPC change. The FAA has eliminated the Part 61 reference to the PTS and has specified the content of an IPC in Part 61. Much like a Flight Review, it seems to put he content of an IPC back into the hands of the CFI conducting the check.

    Note on the bottom right corner of Page 30270 it says “Finally, § 61.57(d) is being revised to remove the reference to the practical test standards and codifying the areas of operation and instrument tasks required for an IPC.” The new wording for 61.57 C(2)(d) is on the top right hand corner of Page 30277. This new rule becomes effective 27 July 2018.

    Am I missing or misinterpreting something?

    Hal Ellis

    See you at OSH!

  • Rod Machado - July 14, 2018

    NOTE: I’m eating crow here because I read the entire 50+ page preamble to this reg and didn’t catch this when I originally wrote this post. With respect to sport pilot time being allowed for private pilot certification, the applicant applying that flight time to the private pilot certificate MUST ALREADY HAVE A SPORT PILOT CERTIFICATE. Said another way, you can apply sport pilot flight time to a private pilot certificate only if you’ve first earned a sport pilot certificate.

    I just didn’t notice that requirement. No, I’m not particularly happy about this limitation because it’s unnecessary, wasteful and seems contrary to common sense. But it’s better than what we had before.

    My apologies for not seeing this from the beginning.

    Rod Machado

  • Scott K. - July 14, 2018


    The way I read the actual proposed rule language for 61.99 and 61.109, instruction from a CFI-Sport will only be applicable to a higher certificate IF the candidate has first secured a sport certificate.

    Proposed 61.109: Aeronautical experience.
    (l) Permitted credit for flight training received from a flight instructor with a sport pilot rating. The holder of a sport pilot certificate may credit flight training received from a flight instructor with a sport pilot rating toward the aeronautical experience requirements of this section if the following conditions are met:

    That’s contrary to all the FAA’s explanatory text (and your interpretation that "The FAA now allows all flight training time received from a sport pilot instructor to apply toward meeting the flight time requirements for the recreational or private pilot certificate. ")

    That time with a CFI-Sport will only be credited IF that Private Pilot candidate first secures a Sport Pilot certificate.

    In the case where a student starts as a Sport Pilot candidate with a CFI-Sport, and then switches to the Private track, that student is screwed. None of the dual done with the CFI-Sport would apply.

    I’d love to be missing something here (as I am a CFI-Sport). Would love your thoughts on the matter.


  • Randy Whitson - July 13, 2018

    Great article Rod. I couldn’t agree more – especially with the FTD, ATD rule change. I believe this will make us all much safer due to the fact that we will able be able to practice/train more.

    Keep up the good work!

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