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ENDORSEMENTS: The Weakest Link for Many Instructors

Posted 9 years 4 days ago ago by Randy Rowles

Throughout the training life cycle of a student pilot, the instructor will be required to provide endorsements in the student’s training record. These endorsements will include confirmation of citizenship, preparedness to take a knowledge exam, and most importantly, the final confirmation that a student is prepared to sit before the FAA for a practical examination toward airman certification. It sounds simple enough, however endorsements remain a weak link among many flight instructors.

When conducting a flight instructor practical test, I will provide the applicant with a scenario at the beginning of the exam. It is designed to include all areas of operation and tasks as outlined within the FAA Flight Instructor Practical Test Standards (PTS). The design of the scenario is simply to capture a day in the life of a flight instructor. Anyone that has held the position of ab initio flight instructor will understand that very few days are the same. With each student comes a set of challenges that are not only training related, but also encompassing regulatory and other issues as well.

Here’s the start of a sample scenario: An Airline Transport Pilot (ATP) applicant with 3,000 hours in airplanes wants to obtain Commercial Pilot Helicopter certification in a Robinson R22. What is required from the first day of training to the day he or she is presented to the FAA examiner?    

Some topics covered in this scenario are SFAR 73, and Federal Aviation Regulations (FAR) that include 61.35, 61.39, 61.63, 61.125, 61.129 … and many others. Of particular interest in this scenario is the FAR that would endorse the pilot to solo a helicopter. In many cases, flight instructor applicants view the pilot as a Student Pilot, when in fact he or she holds an ATP certificate. In reality, once a pilot holds any grade of pilot certificate above Student Pilot, the applicant will no longer be considered a Student Pilot with regard to Part 61 regulations.

To be more specific, let’s refer to the FARs governing a Student Pilot. Contained within FAR Part 61/Subpart C/Student Pilots, the FAA outlines specific regulations regarding student training. This includes endorsement procedures for solo flight (FAR 61.87) and solo cross-country (FAR 61.93), among other topics. As per the title of this subpart, it refers to holders of Student Pilot certificates. If your student holds a pilot certificate other than Student Pilot, this subpart would not apply.

So, how would you endorse a FAA-rated pilot to solo in a different category/class of aircraft? If you refer to FAR 61.31(d)(1-2), the answer will be found. Additionally in the scenario provided above, the applicant is seeking a Commercial Pilot Helicopter certificate. To be eligible for the practical test, ground and flight training must be completed and logged accordingly. However, since the applicant is seeking a grade of certificate other than ATP, you must also endorse the applicant I/A/W FAR 61.63(b) & (c) as well. Each of these endorsements are readily available within FAA Advisory Circular 61.65E.

As you can see, endorsements can be confusing. It is important to remember that an endorsement is your certified statement that you provided the training to the applicant as directed by the applicable FAR. Endorsing a student for a privilege or training event incorrectly during your flight instructor practical exam may earn you a pink slip … but the same mistake as the flight instructor of record may cost you a career!  

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.