Things I Propose We Change in Initial Commercial Pilot Certification Standards and Experience Requirements

Ok, I know this post is going to be a long read, but play along with me and I hope you will find it worthwhile. Grab a cup of coffee and read it to the end if you have any interest in how we train and certify commercial pilots today and want to think about adjustments to improve that process going forward.

A few years ago we made the change to ACS from PTS in most main pilot training sequences, the commercial pilot included, but when we did that, we didn’t really take the time to go back to consider what it took to get a commercial certificate. It has been a long time since we critically evaluated what training requirements and maneuvers should be a part of the commercial pilot certification, and I think it might be time to look at a few of these.

There are a few things I would like to see us consider as changes to commercial pilot certification. When I think about these, the changes that I am going to present here are intended to either help training become more efficient (from a regulatory standpoint) or adjust maneuver requirements to be more realistic (and potentially safer) for what commercial pilots (especially in single-engine aircraft) might do with those skills in a job.

Wouldn’t that make more sense? I think so, but I am just one guy who sees training every day. I hope there are others who might have some opinions and chime in with thoughts on what I write here and what I may have missed.

So, with that, I have thoughts on some changes we might consider.

Let’s start with the dreaded Power Off 180 maneuver.

Fix the Power Off 180

The Power Off 180 maneuver has become something of a spot landing and an emergency operation all rolled into one, and as such, it is not practical for either purpose.

The current standards, to a designated touchdown point not to exceed 200 feet beyond it in an engine-out scenario, don’t represent what we would do if we had an emergency in real life. In real life, if we had an engine out, our goal would be to get down on the runway, not short of it, and appropriately at the beginning of the runway so we wouldn’t roll off the end, especially at an excessive speed. We wouldn’t be shooting for a specific spot on the runway, a spot landing.

We have somehow reached the point where our standards now include guidance in the ACS appendix that indicates (with some limited exceptions for safety) that “Initiating a go-around as a result of an applicant’s inability to complete this Task within the tolerances specified in the skill elements is considered unsatisfactory.”

But if this is a performance maneuver, one that is a landing demonstration, why is it listed in the Airplane Flying Handbook (FAA-H-8083-3C) in Chapter 9, Approaches and Landings, instead of Chapter 18, Emergency Procedures? It is likewise in the Commercial ACS (FAA-ACS07B) under Area of Operation IV, Takeoffs, Landings, and Go-Arounds, instead of Area of Operation IX, Emergency Operations. Perhaps it should be in both of those and transitioned truly into an emergency maneuver, which would not be spot landing, but instead an engine out proficiency demonstration of an ability to safely get down to the airport, not a specific point.

If we were doing a spot landing, we would have some control of power and the ability to manage that vertical descent rate using it appropriately. I get that is more like a short-field landing, but it is also why I do not think we should eliminate the skills in this maneuver as a part of training and testing. Just modify the maneuver

We are hurting planes out there doing it the way we are now. We are also not really training something that is the best practice in a real-world emergency, and honestly, going to end up hurting people at some point.

DPEs (and CFIs) are seeing applicants drive airplane noses down when they will be slightly long and cause porpoising, or worse. We are seeing applicants over-flare and try to stretch out a landing and stalling and plopping the plane down instead of managing energy if they think they are going to be a little short. This is all happening because the applicants are being taught to focus on a small point instead of aircraft energy management to a range of area on the runway for their touchdown in an emergency.

Many flight training operators will tell you this maneuver is causing damage to aircraft as people try to force planes down on a specific point due to an arbitrary designation of a landing point. I get it; that is a skill issue, but why don’t we fix this maneuver to make it a skill worth having?

To support this, I don’t think we should dump the maneuver. I think we should keep it, just make it one that is an actual emergency skill demonstration. We keep the short field landing to show people can land on a spot using proper power and aircraft control. But we make the power off 180 a maneuver to landing on the runway in a reasonable portion of the runway to where the pilot can’t be short, has a little bit of room to work with, and can demonstrate they could get down to the runway in the first portion of it and slow down in an emergency to a speed where they could stop on the runway or if it was a very short runway at least minimize energy and roll off the end slowly and cause the least possible damage to the plane, property, and most importantly, any occupants.

To do this,

I Propose:

The power off 180 be conducted with a simulated engine failure abeam the approach end of the runway and that the applicant be able to touchdown in the first third of the runway or no longer than 1000 feet down the runway, whichever is shorter.

This would be a very clear standard for the applicant and examiners to apply and not force anyone to drive the plane to a specific spot.

Don’t do 8’s on Pylons; Do Turns ON a Point.

Eights on Pylons is a fundamental advanced flight maneuver in pilot training, particularly in commercial and flight instructor curricula. It evolved as a practical application of ground reference maneuvers, designed to enhance a pilot’s ability to maintain precise control over an aircraft in varying wind conditions while considering pivotal altitude—a concept unique to this maneuver.

The origins of the maneuver trace back to early aerial navigation and military training. Before the advent of sophisticated flight instruments, pilots relied heavily on visual references to maneuver and maintain orientation. In the early 20th century, barnstormers and military aviators frequently used ground objects as visual cues for turns and orientation. This technique laid the groundwork for later structured training exercises.

As aviation became more formalized in the 1920s and 1930s, flight training began incorporating standardized maneuvers to improve pilot proficiency. The Civilian Pilot Training Program (CPTP) in the late 1930s and early 1940s emphasized ground reference maneuvers, including turns around a point and S-turns across a road. These exercises helped pilots develop wind correction skills, but instructors sought a more advanced maneuver that introduced dynamic lateral control and airspeed management.

Eights on Pylons emerged as an evolution of these exercises, requiring pilots to maintain a consistent visual reference on a fixed point on the ground while adjusting bank angle and altitude based on the aircraft’s speed. The key principle behind the maneuver—pivotal altitude—was formalized in the post-war flight training manuals, particularly in the 1949 edition of the Civil Aeronautics Administration (CAA) Flight Training Handbook. This altitude, at which a visual reference point remains stationary relative to the pilot’s perspective, is calculated using the square of the aircraft’s true airspeed divided by 11.3 (for knots) or 15 (for miles per hour).

By the 1950s, Eights on Pylons became a staple in commercial pilot training, reinforcing energy management, coordinated turns, and wind compensation. The maneuver was refined in FAA flight training materials, and its practical application extended to aerial photography, reconnaissance, and agricultural flying.

Today, Eights on Pylons remains a required maneuver in commercial pilot flight training, but I can’t think of a practical application for which I would actually use it. I can, however, come up with a good application for HALF of an eight on pylon; a turn ON a point.

If I was genuinely trying to mark a point and fly around it, I don’t know why I would leave that point to fly the “8” and then return to it. I would circle it multiple times, using the pivotal altitude to do this while keeping the reference point.

I can see the real-world practical application of the turn around a point for emergency rescue operations where a point is marked and referenced and maintained to keep it in view. Imagine being the person on the ground who the rescue plane found, circled, and then left. I would be a little worried on the ground if the pilot didn’t see me and was leaving. But if they kept going around, I would be a lot more confident they had good vision of where I was, and rescue was going to be coming! I could easily see this maneuver being used in practical commercial flying operations for fire spotting to help firefighting efforts. And I certainly could see it being used with a photographer onboard to keep a good reference line for a photo mission. All of these are much more practically applicable than doing an eight on pylons.

Doing a Turn ON a Point could be done at pivotal altitude, with a minimum of three circuits of the point, asking the pilot to show they can keep a stable bank angle without ending up in a degrading spiral while still referencing the point and going around multiple times. I think it still shows the skills, and is more practically useful.

An examiner could ask the applicant to perform this maneuver on either side, so the applicants would still have to be proficient both ways. Why both sides? Well, to show proficiency, and it certainly seems logical if this was being used for photographic reasons, the photographer could want to shoot the pictures out of either side of the aircraft. So, get good at it both ways.

I Propose:

We drop the eights on pylons and replace it with Turns ON a Point with three circles being flown while keeping the reference point.

Steep Spiraling Descent; not an emergency landing.

The steep spiraling descent has been a pet peeve of mine for a while. It isn’t that the maneuver isn’t a valid one, but that it gets trained and tested in a way that I don’t think is all that practical.

In some cases, I honestly think people are being tested and failed when they should not be, in a way that isn’t correct.

If you reference the Airplane Flying Handbook (FAA-H-8083-3C) it states: “The objective of the steep spiral is to provide a flight maneuver for rapidly dissipating substantial amounts of altitude while remaining over a selected spot.” And I fully agree with that.

But then it adds the following misleading sentence, “This maneuver may be useful during an emergency landing.” This is where the problem comes in. Many pilots and instructors are confused and think that this means the maneuver is what a pilot would be taught to do if they had an engine failure.

I completely disagree with that logic. If I had an engine failure, unless I was on fire, I wouldn’t be in a rush to get to the ground with maximum descent rate. I would want to get to best glide and stay in the air as long as I could to potentially get an emergency checklist done, which might make it so I didn’t end up landing off-field somewhere. I also wouldn’t be introducing lots of banks and making circles. I would never turn my back fully to an intended landing site. I would zig-zag out in a position where I knew a turn of no more than 90 degrees to the field could let me line up with and make the landing as I descended in the event that my descent path got lower than I thought it might have and I could still make the field. The good news is that when we teach such an engine-out procedure from altitudes such as where we start steep spiraling descents, we have lots of altitude to work with.

But we have some DPEs testing applicants to apply the steep spiraling descent to an actual engine out simulation, trying to combine the maneuvers from the ACS. A few even have been asking applicants to actually conduct this maneuver to a landing at a runway. In the worst examples, I have had reports of students being asked to do this to a grass runway (an actual legal airport one at least) and land the maneuver. If the applicant is unable to do this combination of things, they get a disapproval.

There is a problem here.

The last line of the ACS Skill section of the Task for Steep Spiral specifically reads:
“CA.V.B.S6 Maintain the specified airspeed, ±10 knots and roll out toward an object or specified heading, ±10°, and complete the maneuver no lower than 1,500 feet above ground level (AGL).”

A DPE asking the application to complete the maneuver into another one is not showing that they have completed the maneuver and returned to normal flight from that maneuver.

I Propose:

It’s time we stop teaching the steep spiral as a method to descend quickly to an emergency landing. Teach it just as a method to descend over a point in a stable configuration and return to stable normal flight at the end. It’s time to take that second sentence out of the airplane flying handbook.

If you are reading this and find yourself asked to sequence this maneuver to a landing on your practical test, know that the last line says complete the maneuver. If the DPE presses you to do otherwise, ask for a discontinuance and return to the airport and discuss it on the ground.

Add a New Maneuver: Flying a Grid Pattern

Ok, we haven’t added a maneuver in a long time to the commercial standards. I know not everyone wants to do more, but I honestly think this one is one that is a skill that practically applies to jobs people might get as a low-time, freshly certificated commercial pilot.

One of the jobs that people do other than becoming a CFI is to become an aerial survey pilot. Frequently supplying data for online mapping, agriculture, or survey purposes, pilots get to fly grid patterns back and forth, letting telemetry (photo or other) capture data below them. They do that at various altitudes and varying widths of lanes depending on the equipment being used. Many call it “mowing the grass” because the goal is to have lanes overlap to not have missing data blocks between them.

I think we could add this maneuver to the Commercial ACS (and the Airplane Flying Handbook) and start building a skill, and a testing item, that is practical in today’s commercial pilot job realms.

I Propose:

A grid pattern at 3000 feet AGL be added to the commercial pilot airplane single- and multi-engine ACS (yes, they do this in multi-engine aircraft also) where the pilot would fly five lines, returning to the direction of flight they started of approximately 1 mile in length with approximately ½ mile between the lines, showing they can sequence the lines. The maneuver should be flown perpendicular to the wind to show the pilot can adjust for wind drift. The pilot should maintain airspeed plus or minus 10 knots and altitude plus or minus 100 feet.

It might look like this graphic:

Adjust experience requirements language to fix certification confusion [and incorrectly issued certification].

While I am proposing things, I also REALLY want a couple of changes in the commercial pilot experience requirements regulation. There are a couple of hiccups in there that hang up training all too frequently, either for misapplication or lack of awareness of the nuance.

14 CFR 61.129 requires a pilot for an initial commercial pilot certificate (either in a multi-engine or a single-engine) to have “Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems.”

This is too commonly considered to have been accomplished when a pilot completed their instrument rating. While it is possible that they might have, too frequently, the training in an instrument rating is not logged properly, parsing it out as some toward the instrument rating and some toward future commercial pilot requirements. We are left with the student who already has an instrument rating needing to accomplish another 10 hours of instrument training toward the commercial pilot certificate.

We have had lots of legal interpretations on this, but there still is too much confusion. Some of it can be done in simulators, and the honest truth is that people have had to do too much work around to meet the requirements that are needed here.

This regulation is a holdover from when we had people do commercial pilot certificates before they got instrument ratings. When that was the case, the training was certainly warranted, and it still is in the rare cases that someone gets their commercial pilot certificate before an instrument rating. But that is rare now.

Doing an additional 10 hours of basic instrument skills when someone has an instrument rating, and the fact that none of this is tested on the commercial pilot certificate anyway, is a waste. And it can be easily solved.

I Propose:

We change 14 CFR 61.129 (a)(3) and (b)(3) to simply add the words “or be the holder of an instrument rating” in the training sections that require 10 hours of training for instrument skills. This would make this training not required in addition for those who already hold the certificate.

It would also take the confusion away and, honestly, stop us from mis-certifying or delaying the certification of people who didn’t properly accomplish or document 10 hours of instrument training specifically toward the requirements of 14 CFR 61.129. As it is right now, I know of many CFIs and a few DPEs who are misapplying this. If we did a careful audit in our pilot certification realm, I honestly think we have hundreds, if not thousands, of commercial pilot certificates that have been issued where this requirement was not properly met. We can fix this without changing any quality of training concerns here.

Also in the 14 CFR 61.129 concerns, with regard to this instrument training, it specifically states that the training must be “using a view-limiting device”. This implies an instructor and student must do this not in actual IFR conditions. Why wouldn’t we let a CFI-I and a commercial student accomplish this time in actual instrument conditions? Or in actual instrument conditions during their instrument training?

I Propose:

14 CFR 61.129 (a)(3)(i) and (b)(3)(i) be changed to read “Ten hours of instrument training in actual or simulated IFR conditions…” to remedy this limitation.

And just one more regulation change to propose.

While we are at it, let’s fix the solo/DPIC issue that crops up frequently.

14 CFR 61.129 (a)(4) and (b)(4) says that the ten hours of solo time must be “solo” OR “DPIC”. I get that the intent of this section is for it to be solo flight time and that the DPIC is a carve-out we have for some specific purposes. But it is regularly confused and misapplied. The “OR” making it an all or nothing for the entire 10 hours frequently makes it a mix and match that students, under their unknowing CFIs misapplication of the regulation, mess up and it ends up causing students to fail to meet the requirements properly.

When this happens, they either end up flying more flight time to make up the gap for what was improperly flown, or, in the worst of cases, the CFI and sometimes the examiner miss it, and they end up certificated when they technically did not properly meet all the experience requirements.

The best option for commercial pilot candidates is that they have just flown these requirements “solo” without an instructor onboard.

If we still want to protect the option to have DPIC available, we could clean up the language here to make it clearer to applicants and their CFIs.

I Propose:

We change 14 CFR 61.129 (a)(4) and (b)(4) to read: “ten hours of solo flight in a single- [multi-] engine airplane or 10 hours of flight time performing the duties of pilot in command in a single- [multi-] engine airplane with an authorized instructor on board who is not providing instruction during the flight or any combination thereof (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section, on the areas of operation listed under § 61.127(b)(1) that include…”

This would make the flight a mix-and-match available flight experience activity and more clearly denote that if a CFI is onboard they are not acting in an instructional capacity during this activity. It doesn’t change the actual activity that will take place, it doesn’t ruin the experience process, and it makes it much more likely that applicants won’t have mis-properly tried to meet the particular requirements and end up having to end up flying more flight time due to an administrative challenge or worse, improperly certificated.

These simple changes in regulatory language in the commercial pilot experience requirements would increase the efficiency of commercial pilot training with zero reduction to standards and skills of those applicants. Let’s make these changes happen!

I am sure there are other suggestions out there that might be very well worth considering. Are there other real-world practical things that single-engine commercial pilots do in real jobs that could be considered for maneuvers in training that could make our pilots more prepared to actually be commercial pilots in jobs?

I look forward to your input and discussion!

Oh, and tell me if I am crazy with what I have said here. I can take the critique and welcome points I have not considered if this doesn’t make sense.

Academic Survey On Practical Test Provision / Delays Underway by WMU Student

A student from Western Michigan University (WMU) is working on his thesis discussing current industry concerns of shortage of practical test provision or challenges in this system. The data from this survey will be completely de-identified from submitters and used for academic purposes, but the data results will also be presented in a paper that will, when completed later this year, be shared with industry members.

If you are a DPE, CFI or flight training provider, or an applicant who has sought or completed practical test events in the last couple of years, please help this student gather feedback and information to make the data robust.

DPEs – Click Here to Complete the Survey

CFIs/Flight Training Providers – Click Here to Complete the Survey

Students/Applicants for Practical Tests – Click Here to Complete the Survey

The Difference Between the Fear of Heights and the Fear of Falling: A Pilot’s Perspective

Fear is a natural human response, and pilots must understand and manage their fears in aviation to perform safely and effectively. Two common fears often confused are acrophobia (fear of heights) and basophobia (fear of falling). While these fears may seem similar, they stem from different psychological and physiological mechanisms. Understanding the distinction between the two can help pilots develop strategies to mitigate their effects and improve their comfort and safety in the cockpit.

For many pilots, the fear of edges, ladders, rooftops, and other places a person may fall is common. Yet, they don’t fear being in a plane at higher altitudes because there is a difference between the fear of falling and the fear of heights.

Understanding the Fear of Heights (Acrophobia)

The fear of heights, or acrophobia, is a persistent and irrational fear of being at an elevated position, regardless of the actual risk of falling. People with acrophobia experience intense anxiety when looking down from a height, even when they are in a secure environment, such as inside a glass-walled observation deck or a commercial aircraft.

Acrophobia is believed to be linked to visual and vestibular processing in the brain. When a person is at a significant height, their brain processes a large amount of visual input regarding their distance from the ground. This information is sometimes misinterpreted, triggering a disproportionate fear response.

When someone with acrophobia is exposed to high places, their body may react with:

  • Increased heart rate
  • Dizziness or vertigo
  • Sweaty palms
  • Shortness of breath
  • Panic or the urge to retreat to a lower altitude

Most pilots do not suffer from true acrophobia because flying in an aircraft provides a sense of enclosure and control. However, some pilots experience mild unease when flying in small aircraft with bubble canopies, such as gliders or helicopters, where the sense of exposure is more significant. Additionally, some pilots may feel discomfort during steep climbs, low-altitude maneuvers, or flights over rugged terrain.

Understanding the Fear of Falling (Basophobia)

The fear of falling, or basophobia, is more instinctive and deeply ingrained in human survival mechanisms. Unlike acrophobia, which is linked to perceived height, basophobia is triggered by a sense of instability or loss of control.

Basophobia is rooted in the human brain’s innate response to balance and stability. To maintain equilibrium, the brain continuously monitors sensory input from the vestibular system (inner ear), proprioceptors (muscle and joint sensors), and visual cues. When these inputs signal a potential loss of balance or support, the brain activates a fear response.

This fear is more situational than acrophobia. For example, standing on solid ground at the edge of a cliff might not trigger basophobia, but suddenly feeling unstable or slipping near that edge would.

When someone experiences the fear of falling, they may exhibit:

  • Sudden panic or muscle tension
  • Reflexive grabbing for support
  • An intense urge to stabilize themselves
  • An urge to move away from the perceived place of falling potential
  • Increased adrenaline levels, often leading to a ‘fight-or-flight’ reaction

For pilots, the fear of falling is more relevant than the fear of heights. Many pilots are not afraid of altitude but may experience discomfort in situations where they perceive a loss of control, such as:

  • Severe turbulence – The unpredictable movements of the aircraft can create a sensation of instability.
  • Stalls and spins – Even experienced pilots can feel an instinctive jolt of fear when the aircraft departs from controlled flight.
  • Rapid descents – Sudden drops, whether due to wind shear, thermals, or intentional maneuvering, can trigger an innate fear response.

Some pilots report feeling this more in open cockpit aircraft, aircraft with see-through doors (such as patrol doors with windows), certainly when flying aircraft without a door on, and frequently for pilots and passengers in balloon baskets where the edge is right next to them.

This type of fear is not irrational—it is an evolved survival mechanism. However, excessive fear of falling can interfere with pilot performance, making training and experience essential to overcoming it.

Most pilots, when flying in stable flight, don’t even feel this type of fear, but may have just such a fear when they are at home trying to clean the leaves in their gutters on a ladder, when looking out over an overlook at a scenic cliff, or other similar such places. It’s just a different fear than heights.

Impact on Pilot Training and Flight Proficiency

Both fears—of heights and of falling—can affect pilot training, but in different ways.

Student pilots who experience discomfort in the air may struggle with certain aspects of training, particularly during:

  • Takeoffs and landings – The proximity to the ground and the rapid changes in altitude can be unsettling.
  • Steep turns – A banked aircraft gives a different visual and physical sensation that may trigger unease.
  • Slow flight and stalls – The unnatural sensation of reduced speed and impending loss of lift can provoke a fear response.

As pilots progress in their training, they encounter maneuvers that can intensify the sensation of falling:

  • Spin recovery – Even though pilots are trained to recognize and recover from spins, the initial sensation can be alarming.
  • Aerobatics – Rolls, loops, and hammerheads introduce new gravitational forces that can disorient the body.
  • Instrument flight—The lack of outside visual reference requires pilots to trust their instruments, which can be difficult for those who strongly rely on visual cues for stability. For some, this triggers a lack of feeling stable during flight.

Strategies for Overcoming These Fears

Pilots can take several steps to overcome their fear of heights or fear of falling, whether mild or severe.

The best way to manage fear is through gradual exposure. Flight instructors can help students build confidence by introducing challenging situations in a controlled manner.

 Using Breathing and Relaxation Techniques

Controlling physiological responses to fear can prevent panic. Pilots can practice breathing and relaxation techniques to help. These might include deep breathing to slow their heart rate, progressive muscle relaxation to reduce tension or focused attention on instruments rather than external stimuli to reinforce the factual information showing an aircraft is stable.

Working with a flight instructor, aviation psychologist, or desensitization therapist can be beneficial for pilots with significant fear. Many pilots have successfully overcome their fears through structured training programs.

While the fear of heights and the fear of falling may seem similar, they originate from different psychological and physiological responses. Acrophobia is linked to the visual perception of height, while basophobia is rooted in the fear of instability or loss of control. The fear of falling is far more relevant for pilots, as it can impact performance.

By understanding these fears and implementing structured training strategies, pilots can overcome anxiety and build confidence. Experience, knowledge, and mental discipline allow pilots to master the skies and their fears, rational or irrational.

Interesting Quirky Certification Data Points 2024

I always find a few just, quirky, curious data points every year when I dig through the data on airman certification. Some of these are just data points that I found interesting or ones that I think might illustrate something curious, at least for me.

I hope you find them equally interesting!

Total of 848,770 airmen certifications held. This is the total number of all airmen certificates that are held in the the national airspace system that the FAA believes are for live people. When you think about that, if we think of this of the total population of the United States (not that every airmen certificate holder is from the United States) at 334,900,000 people roughly according to 2023 numbers, this means that the cool kids (in my opinion as holders of an airmen certificate) represent only 0.253% of people!

Our pilot population is trending younger. When we look at the overall breakdown of our airmen certificate holders ages, the largest percentages of our pilots are not overly senior when it comes to age. As we have continued to create new airmen certificate holders actively in the recent years, we are seeing higher percentages of our pilot population fit the under 40-years old age demographic.

In 2024, we issued 3 recreational pilot certificates. A legacy certificate that is in the regulations yet and possible to be issued, it is rarely used. For those CFI candidates ou there, don’t expect to need to use these regulations very often.

Sport pilot issuances were a little larger number, but still a very small number. 2024 saw 226 initial sport pilot issuances. I bring this one up, because it may be a number than changes in upcoming years. With the potential implementation of MOSAIC (a change that will allow larger aircraft to be flown under sport pilot privelges), there is a potential that this certificate may get more utilization in the upcoming years.

Glider only pilots still remain a limited number of people. Only 175 initial glider certificates were issued in 2024. Most glider pilots still seem to be pilots who also fly other categories/classes of aircraft, and additionally fly gliders.

Most CFI certificates issued in the United States, are issued to U.S. citizens. While the U.S. is a training location for many non-U.S. citizens for pilots seeking private and commercial certificates, instrument ratings, and multi-engine privileges, most of the CFI certificate training is focused on U.S. citizens. This is likely due to the fact that is more challenging for non-U.S. citizens to work in the U.S. as CFIs after they would complete such training, but also because most of those that are here for pilot training transition back to home countries for additional training or service specifically as professional pilots in airline and cargo operations. The CFI certificate is not needed in many of these environments for those pilots to continue to gain experience to meet experience requirements as it is in the United States where additional hours are required for ATP pilot certification flight operations.