I'm curious about the general response on the changes currently proposed.

My primary concern went to §61.129(a)(3)(ii), being able to teach for a single engine commercial certificate without need for a retractable gear aircraft. But, I don't think the requirement should be changed for multiengine aircraft.

My comment submitted:
"I agree with the change for a single engine commercial ticket but have to disagree with the change for multiengine commercial. That's an adapted area to be aware of as part of procedures, both normal and emergency. Where is it more important than for those in multiengine who have increased their workload during emergency procedures by the very nature of the aircraft being multiengine equipped; particularly when headed for a professional career in aviation?

As for those seeking to operate one of the few single-engine retracts, I don't think it would be a bad thing to require a given number of hours over several flights before an endorsement is received. Right now, it's strictly a CFI's judgment call. I'd personally want to see at least five different flights before I signed off, even if everything was perfect from the start.

Yes, I know that means more regulation but it's really just a small change in place of what is currently in place."

I am currently putting together somments on the proposed changes. Personally I disagree with removing the complex airplane requirement for a commercial pilot. I think you have a good point that we should not remove that requirement when applying for a commercial multiengine. I have included your point in the response I am preparing for SAFE. Have you submitted your comment to the FAA?