Long-sought changes to instructor certification proposed

The FAA rulemaking proposal published May 23 in the Federal Register notes that AOPA petitioned the agency in 1999, and again in 2000, seeking to remove expiration dates from flight instructor certificates, reasoning they impose an unnecessary and costly burden on CFIs. AOPA also asked the FAA to bring flight instructor certificates in line with (all) other pilot certificates that do not expire, with certificate holders required to maintain proficiency and recent experience by various means.

“AOPA asked the FAA to eliminate the expiration date on a flight instructor certificate and add a three-month grace period to allow a flight instructor to reestablish recent experience by completing a [flight instructor refresher course] FIRC within those three months,” the FAA wrote in its rulemaking proposal, which goes on to propose exactly that. “AOPA asserted that these changes would directly benefit the public, encourage many flight instructors with expired certificates to rejoin the instructional community, and eliminate the need for over 9,700 salary hours of unnecessary administrative processing at the Airman Certification Branch of the Civil Aviation Registry Division. AOPA also maintained that these changes would not adversely affect the quality of flight training or flight safety.”

A subsequent rulemaking proposal in 2007 would have allowed the FAA to issue flight instructor certificates that do not expire, but the agency changed course in 2009, opting to “continue issuing flight instructor certificates with expiration dates after determining that revising its application procedures could achieve equivalent results.”

Experience did not bear that out, the agency wrote. Pilots with other types of certificates continued to maintain their medical and recent experience requirements, and flight instructors continued to face a deadline every 24 months that nobody wants to miss:

“Furthermore, the reinstatement requirements continue to provide a disincentive for flight instructors to reinstate their flight instructor certificates shortly after expiration because the only option available to reinstate a flight instructor certificate is to pass a flight instructor practical test,” the agency wrote.

AOPA President Mark Baker said the FAA deserves credit for acting on the request, which was discussed in meetings with FAA staff in recent months, particularly as the shortage of professional pilots (including instructors) grows more acute.

“AOPA appreciates the FAA’s recognition and proposed adoption of AOPA’s recommendations to make it easier for CFIs to remain current, proficient, and knowledgeable,” Baker said. “These steps will create significant savings in both time and money for thousands of CFIs, while maintaining the highest levels of pilot training and safety for the general aviation community.”

The proposed amendments to CFI renewal requirements include the three-month grace period that AOPA sought, allowing CFIs whose currency has lapsed that extra time to restore it without having to take a new CFI practical test, though doing so remains one option among several paths to currency maintenance or restoration in the FAA proposal, including a new one: the FAA Wings program.

The FAA proposes to revise FAR Part 61.197(a) to add a sixth method by which a CFI can renew their certificate (as required under present rules) now; the FAA also proposes to recast existing renewal requirements as recent experience requirements.

“Instead of a flight instructor renewing their flight instructor certificate every 24 calendar months, a flight instructor would need to establish recent experience at least once every 24 calendar months. This proposed change would ensure the quality of flight training is not adversely affected by the removal of the expiration date from the flight instructor certificate and would also align the flight instructor certificate with the majority of airman certificates in part 61, which are recent experience-based.”

The FAA Wings program, which allows pilots to satisfy certain recent experience requirements, will become a sixth option for CFIs to stay current—by teaching:

“Flight instructors are an integral part of the aviation community and play an important role in reducing the number of general aviation accidents by providing training and modeling best practices. Lessons and activities provided to flight instructors by the WINGS curriculum help to ensure flight instructors are familiar with current flight training standards and procedures. For these reasons, the FAA has determined that § 61.197 should include a standalone method that would allow persons to renew their flight instructor certificates or establish recent experience, as proposed, by serving as a flight instructor and participating in the WINGS program.”

The FAA also proposed to revise the requirements for flight instructors to qualify to teach other flight instructors, adding two new qualification methods. While CFIs will continue to have the option to qualify with 200 hours of dual given (for powered aircraft) and 24 calendar months of instructor certification, the agency proposes to offer two additional routes: having trained and endorsed at least five practical test applicants, of whom 80 percent pass on the first attempt, or graduate from an FAA-approved flight instructor enhanced qualification training program.

AOPA is reviewing the proposed changes and will submit comments by the FAA's June 22 deadline.