No Aircraft
Flight Crew Private; Flight Crew Instrument
Flight Crew Last 90 Days 15; Flight Crew Total 1000; Flight Crew Type 40
Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy
General None Reported / Taken
Procedure
I am writing to object to the narrow forbearance provided to instrument pilots under the SFAR. By limiting the modifications of recent flight experience the way that you have; a significant group of IFR pilots are being denied the ability to exercise instrument privileges unless they are willing to fly with a qualified safety pilot or an instructor; any of whom could be carriers of the virus or an unintentional victim of an infected pilot.I do not meet the present requirements for: flight hours accrued in the last 12 months; or number of instrument approaches in the last 3 months; nor do I qualify under the various types of flights the SFAR is restricted to. However; last year; I passed an IPC; a BFR; and was signed off for both a high performance endorsement and complex endorsement. Since that time I have accrued over 30 hours of solo flight time in the airplane; and flown probably 15 or more instrument approaches under VFR conditions. I feel competent to fly the airplane in instrument conditions.The limitations imposed by the SFAR in this respect; while well intended; seem to essentially negate any significant applicability to the population of instrument pilots. More consideration needs to be given to other indexes of competency; with involvement perhaps of the Instructing community to use their judgment of pilot competency in providing a subjective element to the requirements.
Pilot reported concerns with the limitations imposed by the SFAR concerning the ability to exercise instrument privileges.