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FAA Updated Guidance: Almost Lost in Translation

Posted 8 years 2 days ago ago by Admin


Beginning last year, the Federal Aviation Administration (FAA) released several training-related guidance updates. These releases included advisory circulars, a national policy notice, and most recently, the Flight Instructor Helicopter Practical Test Standards (PTS). In several of my previous training articles, I referred to subject matter affected by the release of this new guidance. I would now like to review a few of the specific documents released by the FAA and provide an overview of how changes may affect you.

The first and most encompassing change was the release of “FAA Advisory Circular (AC) 61.65F.” This AC provides a comprehensive overview of the majority of endorsements required in accordance with “FAR Part 61–Certification of Pilots, Flight Instructors, and Ground Instructors.” The FAA added several key endorsements to include “Special Federal Aviation Regulation (SFAR) 73: Robinson R-22/R-44 Special Training and Experience Requirements.” Additionally, endorsements related to the Transportation Security Administration (TSA), night vision goggles, and the most elusive endorsement of all…the practical test (FAR 61.39)! The intent of this AC is to provide a standardized endorsement that satisfied the FAA legal types, and thus is befitting for use by our industry flight instructor cadre. 

The AC is a great guide, but shouldn’t be utilized with blind faith. Before you endorse any student’s logbook using AC guidance, verify the regulation being endorsed is correct. In many cases, the endorsement within the AC may in fact be reflective of a different category or class of aircraft, or the incorrect regulation altogether. You wouldn’t want to incorrectly endorse a helicopter student for solo and find you actually endorsed them to fly a balloon. (Yes, it could happen.)  

Another document released in August 2015 was “National Policy 8900.320N.” This document provided the guidance to be used for the issuance of the NVG instructor endorsement required under FAR 61.195(k)(7). Additionally, the guidance provided clarity on who is authorized to provide this endorsement. It is important for anyone having received an NVG instructor endorsement prior to August 22, 2015, to be aware that their previous endorsement is no longer valid. In this case, the NVG instructor would need to receive an updated endorsement from an authorized person. 

Per the guidance, an authorized person would either be: (1) a Designated Pilot Examiner (DPE), or (2) a Part 141 chief instructor holding a Letter of Authorization (LOA) for such purpose. It is important to note that a Part 141 chief instructor is limited to endorsing only those students which graduate from the pilot school’s approved NVG instructor course. 

On March 22, 2016, the FAA released the updated “Flight Instructor Practical Test Standards for Rotorcraft.” The primary change—or intent of the change—was the addition of endorsement in lieu of practical test for the power-off landing (touchdown) during either the straight-in or 180-degree autorotation. The change was in response to many years of FAA and industry challenges to identify qualified checking personnel (FAA inspectors and examiners) proficient to conduct this maneuver during a flight instructor practical test. The effort of altering only a single element of the task, the touchdown autorotation, would seem simple. 

The updated PTS states (bold emphasis mine): 
Instructional knowledge must be demonstrated on the practical test in autorotations, either straight-in or 180°, as per Area of Operation X for a helicopter class rating. An examiner may accept, at his or her discretion, a logbook endorsement in lieu of demonstrating these tasks during the practical test. 

It would appear that the maneuvers identified within Area of Operation X would be at the discretion of the examiner. In fact, the intent was ONLY for the touchdown portion of the maneuver to be endorsed in lieu of the practical test. We as an industry must not allow a simple textual error to alter the safety of our industry.

The FAA is currently working to clarify this issue. If you have any questions or comments, please feel free to email me at [email protected].

About Randy:  Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award.  Randy is currently  Director of Training at Epic Helicopters in Ft. Worth, Texas.