FAA Should Serve Training Safety & Reality

By Scott Spangler on October 6th, 2010

Not long ago the FAA brought the number of fatal accidents in amateur-built experimental aircraft to the attention of the aviation community. It got more specific about the problem—and its solutions—in its Aviation Safety business plan for fiscal year 2010.

Working toward the goal of reducing the accident rate by 10 percent over 10 years, FAA-industry committees will “review policy and guidance, training, testing, and checking procedures.” They can start with Change 104 to FAA Order 8900.1, published on September 7, 2010, which makes it harder to use amateur-built aircraft in training for compensation or hire.

Shrinkage of the already small pool of available homebuilts will surely follow because of an increasingly poor return on the time, money, and effort invested in a FSDO’s blessing. To rent a homebuilt, the owner must have a Letter of Deviation Authority (LODA), which allows training that does not lead to the issuance of a pilot certificate or rating.

As a result, the accident rate will stay the same, or get worse. Certainly, this was not the FAA’s intent, but it should be expected when ignoring the real world and drafting policy for the perfect world. Further erosion of the pilot population might be another consequence because flight for personal reasons (aka recreation) accounts for roughly half of all GA flight hours.

Most pilots will agree that safety depends on proficiency, and proficiency depends, in part, on frequently flying their usual set of wings. All pilots will surely agree that given the cost and the economy, they are not flying as frequently as they would like, let alone as much as they need to maintain proficiency.

Crafting policy that serves safety in the real world seems simple. Maintain the rigorous LODA requirements, which includes, among other things, 100-hour inspections, just like store-bought trainers. And allow training for certificates and ratings only, including solo flight.

The policy’s current ban on all solo flight rentals makes understandable safety sense. It prevents owners from renting their amateur-built experimental aircraft to Joe Pilot off the ramp. But there is a safe way around it for pilots training for a certificate or rating: include the required solo flights in the training plans one must submit with the LODA

Prohibiting solo rentals to pilots who already hold a certificate would be no more difficult than this declarative sentence. Pilots wishing to rent the homebuilt for honest transition training will not be flying solo, so that should satisfy the goal of the current ban on all solo flight.

Some might say that allowing new pilots to earn a certificate or rating in a homebuilt tempts safety, and it might. But how is a four or 10-hour transition course any different than 40 or 50 hours for a sport, recreational, or private pilot certificate?

Giving a checkride in a homebuilt might be an easy answer. After all, its policy says: “The FAA does not require flight instructors, pilot examiners, and aviation safety inspectors (ASI) to fly in experimental aircraft.”

But it does not prohibit it either: “The decision whether or not to provide flight training or conduct a check in an experimental aircraft is left to the discretion and judgment of the individual.” Certainly designated pilot examiners—and maybe even some ASIs—would be happy to fly in amateur-built aircraft whose owners and builders they know and trust.

Crafting safety policy for the real world would surely help the FAA achieve its safety goal by making homebuilts for transition training more widely available. And it might slow the shrinking pilot population because non-pilot homebuilders could learn to fly in the airplane taking shape in their shops.

Prohibiting solo flight for certificated pilots would prevent most abuses, simple economics would deter all but the determined and wealthy, and FAA enforcement of the policy should take care of them. Consider the possibilities of deviation toward the real world. –Scott Spangler

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