Q: Can I simply retain a copy of my student pilot’s birth certificate, in lieu of an endorsement, to prove to TSA she is a U.S. citizen? My flight school says the endorsement is mandatory.
A: Absolutely. And the endorsement is not mandatory. If you look in the Interim Final Rule, 49 CFR 1552.3(i)(iv), originally published on September 20, 2004, the only wording in there is to make a copy of, and retain for five years, the student’s birth certificate as proof she is a U.S. citizen. There are five other acceptable documents noted as well, but there is no mention of an endorsement in that rule.
The endorsement came later; it was in the form of an exemption granted by the TSA in October 2004. The flight training provider still had to determine if a student was a U.S. citizen or national. However, in lieu of maintaining a copy of a birth certificate for five years, the provider was now authorized to insert an endorsement into the student’s logbook confirming citizenship, after seeing the birth certificate.
Introductory/discovery flights are exempt from this requirement. The TSA addressed this in a clarification letter after the rule was released. Since few prospective pilots walk into a flight school with a birth certificate, this was a smart move.
AOPA has heard claims of student pilot training time being null and void if a flight training provider forgot to or did not confirm citizenship. While this is certainly a gross oversight on the school’s part, it has no bearing on the logging of flight training time and is simply not true.
Craig Brown is a senior aviation technical specialist in the AOPA Pilot Information Center.
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