The FAA has issued a Notice of Proposed Rulemaking (NPRM) on proposed changes to FAR parts 61, 91 and 141. TheSAFEBoard of Directors has been discussing these changes and has formed an ad hoc committee headed by Directors Pat Knight and Donna Wilt to formulate an officialSAFEresponse.The committee is requesting member comments to be included in SAFE’s official response to the NPRM.

For more NPRM information, see: You can submit your own personal comments at the second link, which we strongly encourage you to do.

There are a couple of steps you can take:

1.Review the proposals for “advanced instrument training”, deletion of the 10 hours of cross country training for commercial pilots, and changes to the definition of “complex airplane”. Describe any problems you see with these areas. Specific examples really help prove our concern.

2.Look at the comments already posted on the FAA website to see if there are other comments that we should address to include in the SAFE response.


3.Look at your specific area of interest in the document, and document any problems. For example, I don’t deal with 14CFR141 right now, so there may be problems with those proposals that I would not have spotted.

The NPRM requires that the comments be submitted on or before November 30, 2009 so keep this moving along.

If you would like to serve on this committee or to submit your comments to the committee, please contact Pat Knight

About the author 

Doug Stewart (Lifetime Member)

MCFI/ DPE, 2004 National CFI OTY. Specializing in instrument training, tailwheel training, and sport pilot training. Currently SAFE Executive Director.

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