Can CFI-SP give endorsements

gprellwitz

gprellwitz

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Grant Prellwitz
Can a CFI-SP sign a tailwheel endorsement for a Private Pilot if the training is given in a tailwheel aircraft meeting the LSA definition? The answer appears to be no.

It hinges on the definition of an authorized instructor:
Sec. 61.31
(i) Additional training required for operating tailwheel airplanes.
(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.
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Doesn't seem to be listed in the privileges of the CFI-SP:
Sec. 61.413 [What are the privileges of my flight instructor certificate with a sport pilot rating? ]

[ If you hold a fight flight instructor certificate with a sport pilot rating, you are authorized, within the limits of your certificate and rating, to provide training and logbook endorsements for--
(a) A student pilot seeking a sport pilot certificate;
(b) A sport pilot certificate;
(c) A flight instructor certificate with a sport pilot rating;
(d) A powered parachute or weight-shift-control aircraft rating;
(e) Sport pilot privileges;
(f) A flight review or operating privilege for a sport pilot;
(g) A practical test for a sport pilot certificate, a private pilot certificate with a powered parachute or weight-shift-control aircraft rating or a flight instructor certificate with a sport pilot rating;
(h) A knowledge test for a sport pilot certificate, a private pilot certificate with a powered parachute or weight-shift-control aircraft rating or a flight instructor certificate with a sport pilot rating; and
(i) A proficiency check for an additional category, class, or make and model privilege for a sport pilot certificate or a flight instructor certificate with a sport pilot rating. ]
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but it's not specifically limited, either:
Sec. 61.415 [What are the limits of a flight instructor certificate with a sport pilot rating? ]

[ If you hold a flight instructor certificate with a sport pilot rating, you are subject to the following limits:
(a) You may not provide ground or flight training in any aircraft for which you do not hold:
(1) A sport pilot certificate with applicable category and class privileges and make and model privileges or a pilot certificate with the applicable category and class rating; and
(2) Applicable category and class privileges for your flight instructor certificate with a sport pilot rating.
[...]
(d) You may not endorse a:
(1) Student pilot's certificate or logbook for solo flight privileges, unless you have-
(i) Given that student the flight training required for solo flight privileges required by this part; and
(ii) Determined that the student is prepared to conduct the flight safely under known circumstances, subject to any limitations listed in the student's logbook that you consider necessary for the safety of the flight.
(2) Student pilot's certificate and logbook for a solo cross-country flight, unless you have determined the student's flight preparation, planning, equipment, and proposed procedures are adequate for the proposed flight under the existing conditions and within any limitations listed in the logbook that you consider necessary for the safety of the flight.
(3) Student pilot's certificate and logbook for solo flight in Class B, C and D airspace areas, at an airport within Class B, C, or D airspace and to from, through or on an airport having an operational control tower, unless that you have- (i) Given that student ground and flight training in that airspace or at that airport; and
(ii) Determined that the student is proficient to operate the aircraft safely.
(4) Logbook of a pilot for a flight review, unless you have conducted a review of that pilot in accordance with the requirements of §61.56.
[...]
(h) You must perform all training in an aircraft that complies with the requirements of §91.109 of this chapter.
(i) If you provide flight training for a certificate, rating or privilege, you must provide that flight training in an aircraft that meets the following:
(1) The aircraft must have at least two pilot stations and be of the same category and class appropriate to the certificate, rating or privilege sought.
(2) For single place aircraft, pre-solo flight training must be provided in an aircraft that has two pilot stations and is of the same category and class appropriate to the certificate, rating, or privilege sought. ]
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The way I understand this then, If I hold a PP-ASEL certificate with a third class medical and train in a LSA TW airplane with a CFI-SP, I can only fly that TW airplane under SP rules. And if he does a BFR, I must fly under SP rules as well. So the moral to this story is, unless you want to fly under SP rules, do your training with a regular CFI.
 
Dean said:
So the moral to this story is, unless you want to fly under SP rules, do your training with a regular CFI.
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Unfortunately, W&B means that the CFI-SP and I can fly, but the CFI and I cannot.:mad:
 
Dean said:
And if he does a BFR, I must fly under SP rules as well.
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We've had this discussion on here in the past, and I thought we'd concluded that a flight review was good for all certificates held by that pilot, regardless of what he took it in and what the CFI held, as long as the CFI was authorized to teach in that airplane and the student was appropriately rated for the category and class. I can't put my finger on where we came to that conclusion, though.
 
As I understand it.. A flight review is a flight review.. and it covers all aircraft regardless of what you complete it in.

We (CFI-G) encourage our glider pilots that are still flying power to complete their flight review in the most complex aircraft they are currently flying. A glider CFI could give a flight review in a glider and it allows that pilot to fly hard ifr in a heavy twin.

So why would that be different for a CFI-SP? He can give a flight review in a LSA to a Pvt Pilot (or ATP) and that pilot would be qualified by action of a flight review within the last 24 months to fly anything his pilot certificate says he can, from LSA to ATP.

The reference in 61.415 in the previous post says, don't sign off a flight review unless you cover everything in 61.56. It does not say that you cannot sign off a flight review.

Just because a CFI-SP signed off on 61.56 in an LSA does not limit you to only flying LSA or as a Sport Pilot as long as you have a medical and meet all the other requirements to fly as a Pvt, Commercial or ATP level.
 
To answer the original Question.. TW endorsements.. why shouldn't a CFI-SP be able to do that. Provide TW training IAW all applicable guidelines to meet the requirements of 61.31(i). As long as the CFI-SP is qualified to fly a LSA TW aircraft like a J-3 or Champ and that's what they use.

A Pvt or Comm pilot could get a TW endorsement under 61.31(i) from a CFI-A that is TW qualified and do it in a J-3 and be legal to fly our 250HP Pawnee as long as he already had a HP (high performance) endorsement in something like a C-182.
 
Bill, I certainly want what you say to hold true. I've certainly believed in the past that a CFI-SE can give a tailwheel endorsement to a pilot with an AMEL rating, and that it would authorize him to fly a multi-engine tailwheel (leaving aside the issue of a type rating for now).

However, 61.3(i) specifies "authorized instructor", and I cannot find anything in 61.413 that authorizes a CFI-SP to provide instruction to anything other than a sport pilot. In fact, the closest I can find is "(f) A flight review or operating privilege for a sport pilot;" Note that again it specifies sport pilot.

Contrast that with the applicable portion of the CFI (except Sport Pilot) section:
Sec. 61.193

Flight instructor privileges.

A person who holds a flight instructor certificate is authorized within the limitations of that person's flight instructor certificate and ratings to give training and endorsements that are required for, and relate to:
(a) A student pilot certificate;
(b) A pilot certificate;
(c) A flight instructor certificate;
(d) A ground instructor certificate;
(e) An aircraft rating;
(f) An instrument rating;
(g) A flight review, operating privilege, or recency of experience
requirement of this part;
(h) A practical test; and
(i) A knowledge test.
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Now we have the language "within the limitations of that person's flight instructor certificate and ratings." Reading this again has me questioning my assertion at the top of this post.

On the other hand, the recommended signoff from AC61-65E doesn't reflect any limitations on the instructor's certificate.

61. To act as PIC in a tailwheel airplane: section 61.31(i).
I certify that (First name, MI, Last name), (pilot certificate), (certificate number), has received the required training of section 61.31(i) in a (make and model of tailwheel airplane). I have determined that he/she is proficient in the operation of a tailwheel airplane.
/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05
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I truly want to be wrong here. Help prove me wrong!
 
doesnt every PP and above have sport pilot priveleges?
 
tonycondon said:
doesnt every PP and above have sport pilot priveleges?
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As far as I know, yes.

So you think "If you hold a fight flight instructor certificate with a sport pilot rating, you are authorized, within the limits of your certificate and rating, to provide training and logbook endorsements for (e) Sport pilot privileges" would provide the authorization needed?
 
Grant... you may well be correct.. I had not looked at all the intricacies under 61.413. The Glider CFI follows the standard 61.193

The best thing to do at this time would be to call the local FSDO and ask for an official ruling. That would come out of Washington.
The CFI-SP could very correctly give the Pvt Pilot or higher a TW in a J-3 (LSA), the question is, can that Pvt pilot now be PIC in a C-170?
 
I think I will see about requesting a ruling. Perhaps Ron will tell me how that's done; I haven't done that before. :dunno:

I think the real solution for my needs is to convince the CFI-SP to get his full CFI. He has a PP-ASEL already! :yes:
 
barney said:
More CFI candidates fail the CFI practical test on

Areas of Operation II: Technical Subject Areas,
L Task: Logbook Entries and Certificate Endorsements,

than any other part of the test. If you don't know what you can and can't do with a CFI rating, you haven't earned the right to exercise the privilege and won't be taking one home with you that day.
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probably true, and without a doubt a valid argument.

do you have an answer to the question?
 
barney said:
More CFI candidates fail the CFI practical test on

Areas of Operation II: Technical Subject Areas,
L Task: Logbook Entries and Certificate Endorsements,

than any other part of the test. If you don't know what you can and can't do with a CFI rating, you haven't earned the right to exercise the privilege and won't be taking one home with you that day.
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Interesting, since we've never actually gotten the answer to the Flight Review question.

It is my opinion that a CFI-SP can, in fact, give any pilot their BFR for single engine airplanes, even if the CFI lacks the Instrument rating or Private Certificate.

But the FAA has not yet answered this question. I'm curious how a DPE knows the answer....
 
barney said:
To answer your question, yes I do have the answer.
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Doh! That was useless, but it did in fact answer the question asked, if not the intent of the question that was asked!

Can I exercise my ATP privileges in my personal 747 if my FR is given by a Commercial Pilot (ie CFI) in a Rotorcraft, Helicopter if I am rated in helicopters and the Instructors is "authorized" to instruct only in helicopters?
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If you do the flight review in a helicopter, yes.

Can I legally fly my hot air balloon (that I'm rated in) after a FR in a Cub (under the Sport Pilot (SP) rules because my medical has expired), if I take my FR in a Cub which both the SP instructor and I are "authorized" in?
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Sure.

3). The FAA has answered the question pretty clearly in my opinion. Look at the regulations.
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Obviously, not clearly enough.

Heres one,

What are the cloud clearance and flight visibility requirements to legally fly under Visual Flight Rules (VFR)?
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What class of airspace? What aircraft? What kind of pilot certificate? What altitude?

If you can answer this question correctly, either you don't understand the question, or (hint) I asked an incomplete/vague question.
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That you did! :yes:
 
barney said:
To answer your question, yes I do have the answer.
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You've done a very good job of dancing around it, and I'm still not sure just what the answer is - because it is not spelled out in the regulations either way. In particular, it does not say whether a CFI-SP can give a flight review to a PP-ASEL in an ASEL LSA and have it be effective for more than sport pilot privileges.

As someone who hopes to be a CFI-SP in the not too distant future, this is a question that obviously holds a lot of interest for me, and I'd like to know the real answer, as well as the rationale for it, before I screw up (if my belief that a flight review given by a CFI-SP in an LSA meets the requirements for all pilots and all of their privileges in the same way that any other flight review does is incorrect). The regulations can easily be interpreted either way, as this discussion shows.
 
(i) Additional training required for operating tailwheel airplanes. (1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.
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Note that we can operate "tailwheel airplanes" with an endorsement from a flight instructor in "a tailwheel airplane" declaring us proficient in "a tailwheel airplane". This is not certificate-dependent in any way, shape, or form. (well, other than the fact that you must HAVE a certificate ;)) If it were, would I have to get a separate tailwheel endorsement for operations requiring an ATP certificate, and if so, who would issue that endorsement? A CFI-SP is authorized to give this endorsement in an LSA, and since you as the pilot are exercising Sport Pilot privileges in an LSA (regardless of certificate level actually held), the CFI-SP is authorized to issue the endorsement. You are then 100% legal to go out and teach yourself to fly a Beech 18, provided you hold at least a Private Pilot certificate with a Multi-Engine rating.

Howzat?:D
 
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barney said:
Can I exercise my ATP privileges in my personal 747 if my FR is given by a Commercial Pilot (ie CFI) in a Rotorcraft, Helicopter if I am rated in helicopters and the Instructors is "authorized" to instruct only in helicopters?
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First, why does flying your "personal" 747 require ATP privileges?

Second, if you are, in fact, legal to fly the 747 at ANY certificate level, you wasted your money getting a flight review, since 61.56 says...

(d) A person who has, within the period specified in paragraph (c) of this section, passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege need not accomplish the flight review required by this section.
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And 61.58 requires that you have passed said proficiency check AT LEAST once in the past 24 months...

(a) Except as otherwise provided in this section, to serve as pilot in command of an aircraft that is type certificated for more than one required pilot flight crewmember, a person must—
(1) Within the preceding 12 calendar months, complete a pilot-in-command proficiency check in an aircraft that is type certificated for more than one required pilot flight crewmember; and
(2) Within the preceding 24 calendar months, complete a pilot-in-command proficiency check in the particular type of aircraft in which that person will serve as pilot in command.
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Not that I'm in any way, shape, or form discouraging training that isn't "required", mind you.:smile:
 
barney said:
I was trying to denote a pilot who was not covered under an Air Carrier Approved Training Program. Probably a bad analogy for this exercise as the largest aircraft I oversaw that was able to operate under 91 and not run afoul of 119 (125 with a full deviation) was a 737.

Second, if you are, in fact, legal to fly the 747 at ANY certificate level, you wasted your money getting a flight review, since 61.56 says...
Click to expand...

A Pilot Proficiency Check is only required of the PIC, what about the SIC?

And 61.58 requires that you have passed said proficiency check AT LEAST once in the past 24 months...
Click to expand...

Again, this is for the PIC only. 61.55 has no requirements that circumvent 61.56.

Not that I'm in any way, shape, or form discouraging training that isn't "required", mind you.:smile:
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Although it may fly in the face of another thread relating to CFI's not challenging students, or documenting every statement with reams of reference material to back it up, I find most people want the simplest, fastest, easiest and cheapest means of gratification and to satisfy their desires.

What fun is there in just giving the answer only to be badgered for documentation. Why would you believe some yo-yo on the internet anyway?

The truth is out there for those with the desire to find it. Actually, it is most likely "Google-able" on the internet.:D
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Maybe after this game, you can tell the FAA where you found it too, so that they can listen to you and give an official interpretation.

BTW, I agree with you in that most things are there to be found, but we've hashed this, Barney, there's no "clear" answer to this question.

So please, I beg you, either give up the answer or knock it off, because this is one place where this isn't funny or useful (normally, making people find the answer is better than giving it), its obnoxious.
 
SkyHog said:
Maybe after this game, you can tell the FAA where you found it too, so that they can listen to you and give an official interpretation.

BTW, I agree with you in that most things are there to be found, but we've hashed this, Barney, there's no "clear" answer to this question.

So please, I beg you, either give up the answer or knock it off, because this is one place where this isn't funny or useful (normally, making people find the answer is better than giving it), its obnoxious.
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Ya have to admit though, he is a perfect example of a FAA Inspector. :D
 
Rotor&Wing said:
Ya have to admit though, he is a perfect example of a FAA Inspector. :D
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Because he is. Funny how Barney rhymes with Arney, right Craig?
 
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barney said:
The truth is out there for those with the desire to find it. Actually, it is most likely "Google-able" on the internet.:D
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Well, I found it on the internet, so it must be true.

Tailwheel endorsements. A sport instructor may, for instance, conduct an initial checkout in a tailwheel LSA, such as a Piper J-3 Cub or any of the Luscombe 8 series. However, the pilot who receives the tailwheel endorsement is not limited to a tailwheel LSA. The endorsement crosses over to include tailwheel aircraft that are not LSAs.
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Okay, I want to learn. How do I go about contacting FAA for the "official" clarification? Try the FSDO, with their historically inconsistent answers? Contact AFS-800? Is there a web form for that, or an email address?
 
gprellwitz said:
Okay, I want to learn. How do I go about contacting FAA for the "official" clarification? Try the FSDO, with their historically inconsistent answers? Contact AFS-800? Is there a web form for that, or an email address?
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Search for posts by Ron in the last few months, he posted how to do it in one of the more heated threads... And I think Tim actually did it.
 
Here's an example (still waiting to hear on this one - typically they reply in 4-8 months):

Federal Aviation Administration
Office of the Chief Counsel
800 Independence Avenue SW
Washington, DC 20591

Subject: Request for opinion on FAR 61.217

Dear Sir or Madam,

I am writing you with a question concerning FAR 61.217, which states:
61.217 Recent experience requirements.
The holder of a ground instructor certificate may not perform the duties of a ground instructor unless, within the preceding 12 months:
(a) The person has served for at least 3 months as a ground instructor; or
(b) The person has received an endorsement from an authorized ground or flight instructor certifying that the person has demonstrated satisfactory proficiency in the subject areas prescribed in § 61.213 (a)(3) and (a)(4), as applicable.

It is clear to me that a ground instructor who has held his certificate for more than twelve months must satisfy subparagraph (a) or (b) to perform the duties of a ground instructor.
What is less clear is whether a brand new ground instructor, who has just received his instructor certificate, must obtain the endorsement in subparagraph (b) before beginning to teach. Since the newly-minted ground instructor has just provided the Administrator (via his designated representative) proof of proficiency in the form of his knowledge test results on the Fundamentals of Instruction and the Ground Instructor knowledge areas, it would seem to me that the initial issuance of the Ground Instructor certificate is itself an endorsement from the Administrator that “the person has demonstrated satisfactory proficiency” at the time of the issuance of the original certificate.

So, must a newly-minted ground instructor receive the endorsement specified in 61.217 (b) before beginning to instruct?

Thank you for your consideration.
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TMetzinger said:
Here's an example (still waiting to hear on this one - typically they reply in 4-8 months):
Click to expand...

You might want to query the local FSDO at the same time for their interpretation. That's the one you'd have to comply with until the official response from AFS400 comes through.
 
TMetzinger said:
Here's an example (still waiting to hear on this one - typically they reply in 4-8 months):
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Thanks Tim.
gismo said:
You might want to query the local FSDO at the same time for their interpretation. That's the one you'd have to comply with until the official response from AFS400 comes through.
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Good idea. Thanks.
 
Since the 61.31 TW endorsement is required for SP's in TW aircraft, I agree with those who said it's OK for a CFI-SP with tailwheel privileges (either TW endorsement or grandfathering) to give a 61.31 TW endorsement. Since that endorsement is not specific to LS or "normal" airplanes, it's good in all.

And don't pick on Barney -- Inspectors are forbidden to give "interpretations" other than to pass on those produced by the Chief Counsel's office.
 
Next question - can an ATP/Commercial/Private/recreational pilot complete a flight review in an LSA with a CFI who only has SP privileges?
 
Ron Levy said:
And don't pick on Barney -- Inspectors are forbidden to give "interpretations" other than to pass on those produced by the Chief Counsel's office.
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If he can't give us the answer, then he shouldn't be waving the fact that he has it under our noses. This is a question that's going to directly affect me, there are two competing, equally plausible interpretations, and to tell me that one's obviously right is both incorrect and frustrating.
 
TMetzinger said:
Next question - can an ATP/Commercial/Private/recreational pilot complete a flight review in an LSA with a CFI who only has SP privileges?
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Ron Levy said:
Since the 61.31 TW endorsement is required for SP's in TW aircraft, I agree with those who said it's OK for a CFI-SP with tailwheel privileges (either TW endorsement or grandfathering) to give a 61.31 TW endorsement. Since that endorsement is not specific to LS or "normal" airplanes, it's good in all.
Click to expand...

Basically the same answer applies...Flight reviews are required for all levels, and the endorsement isn't specific to LSA or "normal" airplanes. Or gliders, or helicopters...A flight review is a flight review.
 
TMetzinger said:
Next question - can an ATP/Commercial/Private/recreational pilot complete a flight review in an LSA with a CFI who only has SP privileges?
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Of course.

If you can do your FR in a freakin' balloon (if you're so rated) and have it count to fly a 747, why would you be forbidden from doing it in an airplane just because it's small?
 
Greg Bockelman said:
Well, not exactly. But we get your point. :D
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Well, yeah, you do have to be rated in the balloon AND the 747... ;)

But, the point is that one of the boxes that has to be checked for you to fly the 747 is a flight review, and that box can be checked by doing your flight review in a balloon. Realistically, that's probably not going to happen, but theoretically, it could.
 
Of course, if you're actively flying a 747 as PIC, you must get a 61.58 PIC proficiency check every year, so you'll never need a 61.56 flight review.
 
flyingcheesehead said:
Well, yeah, you do have to be rated in the balloon AND the 747... ;)
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Well, still, not exactly.

Ron Levy said:
Of course, if you're actively flying a 747 as PIC, you must get a 61.58 PIC proficiency check every year, so you'll never need a 61.56 flight review.
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This was my point. A 747 pilot must get the proficiency check in order to exercise his priviledges. A FR in a balloon will not take the place of that. This is one case where it goes one way but not the other.

And it isn't just the PIC that needs the PC. It also applies to the SIC.
 
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