Flight Training Changes
The Federal Aviation Administration (FAA) notified UND that our Commercial/Instrument Pilot Airplane - SMEL training course outline (TCO) was not in compliance with Federal Aviation Regulation (FAR) Part 141. The FAA is requiring UND to amend and increase the flight training times; this affects AVIT 221, 222, 323, 324, and 325. It is important to understand that UND is not alone with this challenge. Several other collegiate aviation programs with similar training course outlines have been or are currently being directed by the FAA to change their commercial and instrument training.
The FAA stated if the training courses were not changed, UND could continue to use them but would lose examining authority (self-testing). UND has been operating with FAA-approved examining authority in this specific TCO for over 20 years. Maintaining in-house examining authority is our priority, as losing this would require all students to take check rides conducted by the FAA. The FAA has indicated to us that they would not have sufficient resources to conduct these check rides.
UND submitted an exemption request to the FAA on August 7, 2020 asking to continue to operate a combined commercial and instrument pilot course, and keep examining authority. On June 21, 2021, the FAA responded to UND's exemption with a "Partial Grant of Exemption." Overall, UND's request to keep a combined commercial and instrument TCO, and maintain examining authority was denied. The FAA is requiring UND to write and use new separate TCOs:
- Commercial Pilot Airplane - Single Engine Land,
- Instrument Rating Airplane, and
- Additional Airplane Rating - Multiengine Land.
These courses will have examining authority. UND requested a 24-month period to transition our students from the old TCO to the new. The FAA rejected this request, instead only allowing a one-year period to complete students currently enrolled within our original combined TCO. That TCO will lose examining authority next summer on June 21, 2022.
The overall effect of this change is students will conduct flight training in three separate TCOs instead of the previous combined TCO. Much of the content and lessons have not changed; flight times have. Under the old combined TCO, UND was allowed to combine the flight times of Commercial SEL, Instrument Rating, and Additional Airplane Rating Multiengine to meet the Commercial Pilot (120 hours) and Instrument Rating (35 hours) requirements. The new TCO format now requires:
- Instrument Rating Airplane (AVIT 221 and 222): 35 hours instrument training
- Commercial Pilot Airplane SEL (AVIT 221, 323, and 324): 120 hours
- Additional Airplane Rating Multiengine (AVIT 325): 17.5 hours
The overall result of these changes will result in a total cost increase of approximately $4000 for a student over the completion of AVIT 221, 222, 323, 324 and 325. One argument UND expressed to the FAA in our exemption request was the concern and need to minimize the cost of flight training and reduce student expense. The FAA responded:
"The FAA finds that minimizing the cost of flight training for students and lowering student debt would not benefit the public as a whole. Generally, the FAA does not consider financial benefit to an entity or its students as being in the public interest."
Fall 2021 Semester Summary
Students will conduct all of their training in the new flight training courses. The estimated course cost has increased due to additional solo and dual cross-country time needed towards the 120-hour commercial pilot minimums.
Students will complete block 3 in the old TCO and then be transferred to the new separate Commercial and Instrument TCOs. All flight time in the old TCO will transfer to the new TCOs. Students will complete their instrument training in the new TCO and receive a temporary certificate for their instrument rating at the completion of the course. The AVIT 222 course costs are relatively the same. However, students will have the opportunity to accrue additional solo and/or dual time needed towards the 120-hour commercial pilot minimums.
Students enrolled in 323 will need to choose one of two options:
Option 1: Remain and finish all training in the old TCO
Option 1 is the preferred and recommended option. The student MUST complete the end of course stage check in AVIT 325 by June 21, 2022. This requires the student to complete AVIT 323 flight training in the Fall 2021 semester and AVIT 325 in the spring 2022 semester. The student must complete AVIT 325 training by June 21, 2022 to retain examining authority. If a student fails to complete by June 21, 2022 they will have to conduct all three FAA practical tests (Commercial Single Engine, Instrument Airplane, and Multi Engine) with an FAA Inspector or Designated Pilot Examiner (DPE); there is currently only one DPE in the Grand Forks area. If a student chooses to complete their checks with a DPE elsewhere, there are DPE costs associated with each check (approximately $800 plus aircraft fees).
Option 2: Transfer to the new TCOs
The June 21, 2022 deadline does not affect this option. Because of the transfer to a different TCO, the student is required to redo the Instrument Rating Airplane end-of-course stage check to meet regulatory requirements. Students will complete their commercial pilot training needing at least 120 hours. Overall cost is dependent on each student's specific hours, but most students will see an increased cost to get to the 120 hours.
Students will remain in the old TCO and are required to complete their flight training by June 21, 2022. Failure to do so will require three FAA practical tests as described in the AVIT 323 summary.
Commercial and Instrument TCO Estimated Costs
Rates effective as of 8/15/2021 were used to determine costs.
|Old Format||New Format|
Instructor Time (40 hrs)
Instructor Time (49.6 hrs)
Instructor Time (56 hrs)
Instructor Time (61.2 hrs)
Instructor Time (40 hrs)
Instructor Time (59.3 hrs)
Instructor Time (53 hrs)
Instructor Time (58.8 hrs)
|Total Cost||$35,530||Total Cost||$40,021*|
* Cost will vary depending on how students utilize their flex time throughout the Commercial SEL course
UND Aerospace understands that these changes can be very confusing for our student body and we plan to hold several informational sessions at the start of the semester to explain how these changes will affect each student.