The FAA has proposed a rule that would remove the 24-month expiration date on flight instructor certificates and instead establish 24-month recent experience requirements. According to a notice of proposed rulemaking (NPRM) published on Tuesday, the methods of demonstrating recent experience would be the same as the current renewal methods established in 14 CFR § 61.197(a), namely passing a practical test; endorsing at least five students for a practical test with at least 80 percent passing on the first attempt; serving as a company check pilot, chief flight instructor, company check airman or flight instructor in a Part 121 or Part 135 operation; completing an approved flight instructor refresher course; or passing an official U.S. Armed Forces military instructor pilot or pilot examiner proficiency check. The proposed rule would also let instructors establish recent experience by serving as a flight instructor in an FAA-sponsored pilot proficiency program. A similar rule to allow the issuance of flight instructor certificates without expiration dates was proposed in 2007, but was later withdrawn.
“Industry advocates have expressed support for removing the expiration date on a flight instructor certificate and amending the renewal and reinstatement requirements,” the FAA wrote in the NPRM. “These industry advocates asserted that requiring an expiration date on a flight instructor certificate is overly burdensome, costly, and provides no safety benefits.”
In addition, the proposed rule would allow flight instructors “whose recent experience has lapsed by no more than three calendar months to reinstate flight instructor privileges by taking an approved flight instructor refresher course rather than completing a flight instructor certification practical test.” It would also add two new methods by which instructors could qualify to provide training to initial flight instructor applicants. The first proposed method would allow an instructor to train a first-time flight instructor applicant once they have trained and endorsed at least five applicants for a pilot certificate or rating practical test with at least 80 percent passing on their first attempt. The second suggested method requires the instructor to have graduated from an FAA-approved flight instructor enhanced qualification training program (FIEQTP) and have given at least 200 hours of flight training. As described in 14 CFR § 61.195(h), instructors providing training to initial flight instructor applicants are currently required to meet the eligibility requirements of 14 CFR § 61.183, hold the appropriate flight instructor certificate and rating, have held a flight instructor certificate for at least 24 months and have given at least 200 hours of flight training.
The NPRM is open for public comments until June 22, 2023. Further information is available via the Federal Register.
This proposal has a fatal flaw in it: quoting from the NPRM:
“While the flight instructor would not be applying to renew a certificate, the FAA finds it is necessary to maintain Forms 8710–1 and 8710–11 as the collection mechanism because it would allow the FAA to continue to track the number of flight instructors who are eligible to exercise the privileges of their flight instructor certificates in a manner that flight instructors are accustomed. Additionally, utilizing Forms 8710–1 and 8710–11 would allow the FAA to validate that the flight instructor does, in fact, satisfy the recent experience requirements. Should the FAA find that the flight instructor either does not sufficiently show a recent experience requirement has been met, or does not meet the recent experience requirements, the FAA would deny the applicant’s 8710–1, and direct the appropriate Flight Standards District Office (FSDO) to issue a Letter of Disapproval to the flight instructor.”
In other words: the FAA effectively cancels your certificate if you don’t submit the “renewal” paperwork. So the only real change is: the certificate no longer tells you by when you need to renew. How is that an improvement?
When I read the headline, I thought “This is a great rule change!”, but after reading more closely it appears that all this will do is give someone who misses the renewal by less than 3 months a bit of a grace period. Much ado about nothing?
We have two lapsed CFIs who would return to flight instruction in a heartbeat (we need them!), but won’t because of the practical test requirement. They are active and proficient pilots. I don’t see that this rule change helps the numerous former CFIs in the same boat.
I’ll continue using the eFIRC method as before.
Seems like typical government work… much smoke, many words, little action. Maybe I’m missing something here?
An active and proficient pilot does not always make a good instructor. Maybe there’s a reason they don’t want to take the practical. It it’s just cost, you have an easy solution.
That may be true, but based on the CTS training I have to do in my pt135 job, doing checkrides every 6 months, dealing with low time, inexperienced FO’s, I see little difference from that to FIRC I used to attend. My CFI expired 15 years ago due to lack of time in what was my fractional job. This proposed rule does nothing to change what I would have to do to renew my CFI. What little if any flight instruction I would do is not worth the money, time or effort to do a check ride to renew it. I fail to see how this rule change would encourage those with expired CFI’s to go through the trouble of another checkride to renew.
“These industry advocates asserted that requiring an expiration date on a flight instructor certificate is overly burdensome, costly, and provides no safety benefits.”
I have to disagree with the “industry advocates” on this. As others have pointed out, all this proposed change does is remove the expiration date, but you still effectively have to renew it every 2 years as before, except now you don’t have a reminder date on your certificate. That actually seems *more* burdensome, because it’s one more thing instructors have to manually track.
The only real benefit is the 3 month grace period, but why not make it 6 to line up with the IPC grace period?
If the proposed reg allows renewal by taking an approved flight instructor refresher course (like Gleim) what has effectively changed?
All this NPRM does is to take the onus OFF the FAA from having to notify you that your CFI certificate is about to expire. It places that tasking upon the CFI(I) themselves. And if you forget, se la vie.
More properly, Mr. Frank Tino, if You are enough kind to allow me to do so, the final of Your comment should be “c’est la vie” (translation: “that’s life”).
Irony has peaked.
Ah, social commentary through humor.