- The upshot:
- The government (TSA) requires it.
- Individual flight instructors are defined as a ‘flight school’.
- Not just for ‘aliens’, but applies to U.S. citizens as well.
- When a student switches to a new instructor or flight school they need a new endorsement.
- Applies to all flight and simulator training including recurrent training.
To begin with, under ‘definitions’ in Title 49 Subtitle B Chapter XII Subchapter C Part 1552.1 the government defines a Flight School as “…any pilot school, flight training center, air carrier flight training facility, or flight instructor…” So, now that the regulations have wrapped themselves around the average, independent flight instructor, now what?
Now the ‘flight school’ (a.k.a. the flight instructor) must determine a persons citizenship. This is outlined in § 1552.3 where it applies to “U.S. citizens and nationals and Department of Defense endorsees.” Usually a passport or a birth certificate and government issued photo ID are used before any training begins.
The purpose of this appears to be a way to ensure that some nefarious individual doesn’t just walk off the street with a logbook purchased online with a bunch of random entries and an endorsement that they claim was provided by their ‘other instructor’. It’s a pretty unlikely scenario, however stranger things have happened in this world.
After the determination has been made an endorsement in their logbook must be made and records kept by the flight school/instructor for five (5) years. Refer to Recordkeeping Requirements for that info and for the correct wording of the logbook endorsement refer to endorsement number A.14 in the current version of FAA Advisory Circular AC 61-65.
Non-U.S. resident aliens desiring flight training have to jump through more hoops with the TSA by first applying at the Alien Flight Student Program website and providing more documentation. The AOPA has put together a good resource here for anyone trying to navigate this process.
While reading through Part 1552 there is nothing that makes it simple, obvious or walks through the requirement of flight instructors to make a logbook endorsement and I asked the AOPA for clarification about what they had on their website. They were able to provide me with an “Interpretation of Certain Definitions” letter from the TSA from 2004 which should put this issue to rest – that is, until something changes. You can download a copy of that letter from me here or if you are a member of AOPA they have it linked here.
Both the AOPA site and the TSA letter discuss the requirement for the endorsement for flight training/recurrent training to mean “…only that training that a candidate could use toward a new airman’s certificate or rating…” and “…to not include any flight review, proficiency check, or other check whose purpose is to review rules, maneuvers, or procedures, or to demonstrate a pilot’s existing skills on aircraft…“