TRAINING INSTRUCTOR CONCERN REGARDING FAR CHANGE WHICH PUTS PLTS AT RISK OF VIOLATING THE FAR.

Narrative

PRIOR TO AUG/93 THE FLT REVIEW REQUIRED BY SECTION 61.56 OF FARS DID NOT REQUIRE FLT INSTRUCTION FOR THE SATISFACTORY COMPLETION OF THE FLT REVIEW. AFTER AUG/93 SECTION 61.56(A) OF THE FARS NOW REQUIRES A MINIMUM OF A HR OF FLT INSTRUCTION TO COMPLETE THE FLT REVIEW. IN ADDITION; SECTION 61.56(E) REQUIRES COMPLETION OF 3 HRS OF FLT INSTRUCTION TO COMPLETE THE FAA SPONSORED PLT PROFICIENCY PROGRAM. PRIOR TO THE REQUIREMENT FOR INSTRUCTION THAT WAS EFFECTIVE AUG/XX/95; THE PLT OF A BEECHCRAFT BONANZA OR BARON WITH A SINGLE 'THROW-OVER' CTL WHEEL WAS ABLE TO COMPLETE HIS/HER FLT REVIEW WITHOUT OPERATING CONTRARY TO SECTION 91.109 SINCE NO FLT INSTRUCTION WAS CONDUCTED DURING THE FLT REVIEW. AFTER AUGUST/XX/93 A PLT WHO COMPLETED HIS/HER FLT REVIEW IN A BEECHCRAFT BONANZA OR BARON EQUIPPED WITH A SINGLE THROW- OVER CTL WHEEL WOULD; UNDER THE REVISED REQUIREMENT; BE FORCED TO EITHER TAKE THE FLT REVIEW IN AN ACFT THEY DID NOT NORMALLY FLY OR COMPLETE THE FAR 61.56(A)&(E) INSTRUCTIONAL REQUIREMENT IN A MANNER THAT MAY BE CONTRARY TO THE PROVISIONS OF FAR 91.109. THE CHANGE TO THE FLT REVIEW REQUIREMENT ON AUG/XX/93 PLACES BOTH THE PLT AND THE INDIVIDUAL ADMINISTERING THE FLT REVIEW IN REGULATORY ENFORCEMENT JEOPARDY. OPTIONS SUCH AS THESE ARE NOT IN THE PUBLIC INTEREST. CORRECTIVE ACTION. ON OR ABOUT APR/YY/95; WE PETITIONED THE FAA TO AMEND SECTION 91.109 TO AGAIN MAKE THE ADMINISTERING OF A FLT REVIEW IN A BONANZA OR BARON EQUIPPED WITH A SINGLE THROW-OVER CTL WHEEL NOT CONTRARY TO SECTION 91.109 OF THE FARS. CORRECTIVE ACTION COULD EASILY BE ACCOMPLISHED BY THE FAA ACTING FAVORABLY ON OUR PETITION. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATES THE ORGANIZATION IS THE BONANZA AND BARON PLT PROFICIENCY PROGRAM. THIS IS A TRAINING PROGRAM WHICH IS AN ADJUNCT OF THE AMERICAN BONANZA SOCIETY; BUT LEGALLY A SEPARATE ENTITY. LAWYERS FOR THE PROGRAM HAVE SECURED AN EXEMPTION FOR THE TRAINING PROGRAM ACTIVITIES BUT THERE ARE OTHERS WHO MAY NOT BE AWARE OF THE PROB CREATED BY THE NEW REGS. THE PETITION WAS SENT TO FAA HEADQUARTERS. RPTR STATED HE HAD JUST RECEIVED ACKNOWLEDGEMENT OF RECEIPT OF THE PETITION AND NOW HAS A DOCKET NUMBER; BUT WAS GIVEN NO FURTHER INFO REGARDING ANY ACTION. HE FEELS IT WILL BE A LONG TIME BEFORE THINGS START TO MOVE; UNFORTUNATELY.