80020 Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 

DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

14 CFR Parts 11, 61, 63, 65, and 141 

[Docket No. FAA–2023–0825; Amdt. Nos. 

11–67, 61–155, 63–47, 65–65, and 141–25] 

RIN 2120–AL25 

Removal of Expiration Date on a Flight 

Instructor Certificate; Additional 

Qualification Requirements To Train 

Initial Flight Instructor Applicants; and 

Other Provisions 

AGENCY: Federal Aviation 

Administration (FAA), Department of 

Transportation (DOT). 

ACTION: Final rule. 

SUMMARY: This action removes the 

expiration date on flight instructor 

certificates to align with other airman 

certificates. Additional amendments 

include updating renewal requirements 

to recent experience requirements, 

introducing a new method for 

establishing recent flight instructor 

experience, and allowing instructors 

with a lapse of no more than three 

months to reinstate privileges via an 

approved flight instructor refresher 

course instead of a practical test. This 

final rule also adds two new methods 

for flight instructors to qualify to train 

initial applicants. Finally, this final rule 

relocates and codifies the requirements 

for relief for U.S. military and civilian 

personnel who seek to renew their 

expired flight instructor certificate. 

DATES: This final rule is effective 

December 1, 2024, except that 

amendatory instruction 10 is effective 

March 1, 2027. 

ADDRESSES: For information on where to 

obtain copies of rulemaking documents 

and other information related to this 

final rule, see ‘‘How to Obtain 

Additional Information’’ in the 

SUPPLEMENTARY INFORMATION section of 

this document. 

FOR FURTHER INFORMATION CONTACT: 

Allan G. Kash, Training and 

Certification Group, Flight Standards 

Service, Federal Aviation 

Administration, 800 Independence 

Avenue SW, Washington, DC 20591; 

telephone (202) 267–1100; email 

allan.g.kash@faa.gov. 

SUPPLEMENTARY INFORMATION: 

List of Abbreviations and Acronyms 

Frequently Used In This Document 

AATD: Advanced Aviation Training Device 

ATD: Aviation Training Device 

BATD: Basic Aviation Training Device 

FFS: Full Flight Simulator 

FIEQTP: Flight Instructor Enhanced 

Qualification Training Program 

FIRC: Flight Instructor Refresher Course 

FSTD: Flight Simulation Training Device 

FTD: Flight Training Device 

NPRM: Notice of Proposed Rulemaking 

WINGS: FAA’s Pilot Proficiency Program 

Table of Contents 

I. Executive Summary 

A. Purpose of the Regulatory Action 

B. Changes Made in This Final Rule 

C. Summary of the Costs and Benefits 

II. Authority for This Rulemaking 

III. Background 

A. Statement of the Problem 

B. Summary of the NPRM 

C. General Overview of Comments 

IV. Discussion of Comments and the Final 

Rule 

A. Removal of Expiration Date on Flight 

Instructor Certificates (§ 61.19) 

B. Changing the Flight Instructor 

Certificate Renewal Requirements to 

Flight Instructor Recent Experience 

Requirements (§ 61.197) 

C. Recent Experience Based on 

Instructional Activity in an FAASponsored Pilot Proficiency Program 

(§ 61.197(b)(2)(v)) 

D. Reinstatement of Flight Instructor 

Privileges by FIRC (§ 61.199) 

E. Instructor Qualifications for Training 

Initial Flight Instructor Applicants 

(§ 61.195(h); § 141.11; Part 141, 

Appendix K) 

F. Conforming Amendments (§§ 61.2, 

61.56, 61.425, 61.427) 

G. SFAR No. 100–2 Codification Under 

§ 61.40 and Associated Amendments 

H. Miscellaneous Comments 

V. Severability 

VI. Regulatory Notices and Analyses 

A. Regulatory Evaluation 

B. Regulatory Flexibility Act 

C. International Trade Impact Assessment 

D. Unfunded Mandates Assessment 

E. Paperwork Reduction Act 

F. International Compatibility 

G. Environmental Analysis 

VII. Executive Order Determinations 

A. Executive Order 13132, Federalism 

B. Executive Order 13175, Consultation 

and Coordination With Indian Tribal 

Governments 

C. Executive Order 13211, Regulations 

That Significantly Affect Energy Supply, 

Distribution, or Use 

D. Executive Order 13609, Promoting 

International Regulatory Cooperation 

VIII. Additional Information 

A. Electronic Access and Filing 

B. Small Business Regulatory Enforcement 

Fairness Act 

I. Executive Summary 

A. Purpose of the Regulatory Action 

This final rule amends part 61 of title 

14 of the Code of Federal Regulations 

(14 CFR) by revising the expiration, 

renewal, and reinstatement 

requirements for flight instructor 

certificates and revising the 

qualifications for flight instructors 

training initial flight instructor 

applicants. 

As explained in section III.A. of the 

preamble, the FAA will remove the 

expiration date on flight instructor 

certificates to align with other airmen 

certificates. The flight instructor 

certificate renewal requirements will 

become recent experience requirements, 

which flight instructors must establish 

at least once every 24 calendar months. 

The final rule also adds a new method 

for flight instructors to establish recent 

experience by serving as a flight 

instructor in an FAA-sponsored pilot 

proficiency program. Additionally, 

while the FAA is not removing any 

existing allowances to renew a flight 

instructor certificate, as is discussed in 

section III.A. of this preamble, this final 

rule amends the reinstatement 

requirements of § 61.199 by allowing 

flight instructors to reinstate their flight 

instructor privileges by taking an 

approved flight instructor refresher 

course (FIRC), provided their recent 

experience has not lapsed for more than 

three calendar months. 

As discussed in section IV.E. of the 

preamble, this final rule also revises the 

qualifications for instructors seeking to 

train initial flight instructor applicants. 

Specifically, the FAA is updating the 

existing qualification method by adding 

two new options. The first new option 

is based on training and endorsing 

successful applicants for practical tests. 

The FAA is also introducing a second 

new option as a method of qualification 

by completion of a new training 

program designed to prepare flight 

instructors to train initial flight 

instructor applicants. 

Finally, the FAA will relocate and 

codify Special Federal Aviation 

Regulation (SFAR) No. 100–2, Relief for 

U.S. Military and Civilian Personnel 

who are Assigned Outside the United 

States in Support of U.S. Armed Forces 

Operations, into parts 61, 63, and 65, 

respectively. The codification of SFAR 

No. 100–2 is further discussed in 

section IV.F. of this preamble. 

B. Changes Made in This Final Rule 

This final rule adopts the 

amendments largely as proposed. The 

FAA notes three revisions to the rule, as 

explained in section IV. of this 

preamble. 

This final rule revises the recent 

experience requirements based on 

instructional activity in an FAAsponsored pilot proficiency program to 

clarify that 15 activities, rather than 15 

hours of flight training, are required 

under the pilot proficiency program. 

Additionally, this final rule revises 

§ 61.197(b)(2)(i) to clarify that the 80 

percent passage rate is based on all 

practical test applicants endorsed by the 


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1Section 820 of Public Law 118–63, 138 Stat. 

1330 (49 U.S.C. 44939 note). 

2Removal of Expiration Date on a Flight 

Instructor Certificate; Additional Qualification 

Requirements to Train Initial Flight Instructor 

Applicants; and Other Provisions NPRM, 88 FR 

32983 (May 23, 2023). 

3Section 61.197(b) prescribes requirements for 

determining the expiration month of a renewed 

flight instructor certificate. 

4See 88 FR at 32985 for additional discussion on 

the 2007 rulemaking action. 

recommending instructor in the 

preceding 24 calendar months. 

The FAA has identified an 

unintended omission in the NPRM 

regarding a reference to flight instructor 

certificate expiration in § 61.51(h)(2)(ii). 

To correct this, the FAA will implement 

a two-phased amendment to this rule. 

The first phase will ensure that flight 

instructors who hold a flight instructor 

certificate with an expiration date and 

flight instructors who hold a flight 

instructor certificate without an 

expiration date will remain compliant 

with the requirements of § 61.51 when 

logging training time in pilot logbooks 

after the effective date of the final rule. 

The second phase will begin 27 months 

after the effective date of the final rule. 

This second amendment will remove 

references to the flight instructor 

certificate expiration date from § 61.51. 

The detailed discussion and rationale 

behind these changes are further 

discussed in section IV.G. of this 

preamble. 

Finally, this final rule more precisely 

describes the timeframe that a person 

may exercise the relief set forth in new 

§ 61.40, currently SFAR 100–2, as (1) 

while the person serves in an operation 

as set forth in § 61.40(b)(1), or (2) six 

calendar months after returning to the 

United States. 

The FAA notes that there is no cost 

impact associated with any of the 

changes adopted in this final rule. 

C. Summary of the Costs and Benefits 

The FAA estimates this rule to result 

in $5.6 million, discounted over five 

years, in cost savings to FAA and 

industry, which includes removing the 

expiration date on the flight instructor 

certificate as well as allowing flight 

instructors whose recent experience has 

lapsed by no more than three calendar 

months to reinstate flight instructor 

privileges by taking a FIRC. These cost 

savings are driven primarily by the cost 

savings to industry of removing the 

expiration date on the flight instructor 

certificate. 

II. Authority for This Rulemaking 

The FAA’s authority to issue rules on 

aviation safety is found in Title 49 of the 

United States Code (49 U.S.C.). Subtitle 

I, section 106, describes the authority of 

the FAA Administrator. Subtitle VII, 

Aviation Programs, describes in more 

detail the scope of the agency’s 

authority. 

The FAA is issuing this final rule 

under the authority described in 49 

U.S.C. 106(f), which establishes the 

authority of the Administrator to 

promulgate regulations and rules; 49 

U.S.C. 44701(a)(5), which requires the 

Administrator to promote safe flight of 

civil aircraft in air commerce by 

prescribing regulations and setting 

minimum standards for other practices, 

methods, and procedures necessary for 

safety in air commerce and national 

security; and 49 U.S.C. 44703(a), which 

requires the Administrator to prescribe 

regulations for the issuance of airman 

certificates when the Administrator 

finds, after investigation, that an 

individual is qualified for and 

physically able to perform the duties 

related to the position authorized by the 

certificate. This rulemaking is within 

the scope of that authority. Finally, the 

FAA has determined that this rule 

satisfies the requirements of section 820 

of the FAA Reauthorization Act of 2024, 

which requires the FAA to promulgate 

this final rule within 18 months after 

the date of enactment of the Act, to at 

a minimum, update part 61, Code of 

Federal Regulations, to remove the 

expiration date on the flight instructor 

certificate, and replace the requirement 

that a flight instructor renews their 

flight instructor certificate with 

appropriate recent experience 

requirements.1

III. Background 

A. Statement of the Problem 

As discussed in the notice of 

proposed rulemaking (NPRM),2 under 

§ 61.19(d), a flight instructor certificate 

expires 24 calendar months from the 

month in which it was issued, renewed, 

or reinstated, as appropriate, except as 

provided in § 61.197(b).3 Therefore, the 

FAA currently issues physical flight 

instructor certificates every time a flight 

instructor renews or reinstates their 

flight instructor certificate, which is at 

least every 24 calendar months, 

resulting in a process that is 

burdensome, inefficient, and costly to 

the FAA. Specifically, this process 

requires the FAA to process, print, and 

mail new certificates to all flight 

instructor certificate holders. Further, 

most airman certificates under part 61 

do not have expiration dates; rather, a 

person may exercise the privileges of an 

airman certificate only if that person 

meets the appropriate recent experience 

requirements of part 61 specific to the 

operation or activity. 

Industry advocates have expressed 

support for removing the expiration date 

on a flight instructor certificate and 

amending the renewal and 

reinstatement requirements, asserting 

that an expiration date on a flight 

instructor certificate is overly 

burdensome, costly, and provides no 

safety benefits. As described in the 

NPRM, on September 14, 1999, and 

again on March 13, 2000, the Aircraft 

Owners and Pilots Association (AOPA) 

petitioned the FAA to remove the 

expiration date on a flight instructor 

certificate. AOPA expressed concern 

that many current and former flight 

instructors perceive the existing FAA 

regulatory requirement for certificate 

expiration and reinstatement as a 

significant disincentive to renewing an 

expired flight instructor certificate. 

AOPA’s petition also asserted that flight 

instructor certificate expirations have 

substantially reduced the number of 

otherwise qualified and experienced 

part-time flight instructors. 

In addition to AOPA’s position on the 

flight instructor expiration, AOPA 

petitioned the FAA to consider adding 

a three-month grace period to allow 

flight instructors to reestablish recent 

experience by completing an FIRC 

within those three months. Under the 

current rules, flight instructors who do 

not renew their certificates before 

expiration must successfully complete a 

full practical test to reinstate their flight 

instructor certificate, a process that can 

be both expensive and time-consuming. 

AOPA asserted that a three-month grace 

period would directly benefit the public 

by encouraging many flight instructors 

with expired certificates to rejoin the 

instructional community and 

eliminating the need for over 9,700 

salary hours of unnecessary 

administrative processing while not 

adversely affecting the quality of flight 

training or flight safety. 

As discussed in the NPRM to this 

final rule, the FAA published an NPRM 

in 2007 after receipt of AOPA’s 

petitions 4 that would have issued flight 

instructor certificates without an 

expiration date; however, the FAA 

decided to withdraw the proposal and 

implemented a simplified application 

process. However, this simplified 

application process did not sufficiently 

address the administrative burden on 

the FAA and flight instructors of 

renewing flight instructor certificates. 

Additionally, retaining the expiration 

dates on flight instructor certificates is 

inconsistent with most airman 

certificates issued under part 61, which 


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5 88 FR at 32992. 

6 88 FR at 32983. 

7 comment from William Edwards, Docket No. 

FAA–2023–0825–0132. 

8The Experimental Aircraft Association’s 

AirVenture Oshkosh Air Show was held from July 

24 through July 30, 2023. 

9Removal of Expiration Date on a Flight 

Instructor Certificate; Additional Qualification 

Requirements to Train Initial Flight Instructor 

Applicants; and Other Provisions Extension of 

Comment Period, 88 FR 74908 (Nov. 1, 2023). 

10www.federalregister.gov/documents/2011/01/ 

21/2011-1385/improving-regulation-and-regulatoryreview. 

11Three of the additional comments received 

were duplicates. Therefore, the total number of 

unique comments received was 166. 

do not have expiration dates. 

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 FAA also recognizes the need for 

more qualified instructors to train new 

flight instructor applicants. Currently, 

flight instructors are required to have a 

minimum of 24 calendar months of 

instructional experience before they are 

eligible to train new flight instructor 

applicants. The flight training industry 

is impacted by the supply of flight 

instructors necessary to support future 

growth in aviation. 

Finally, in Special Federal Aviation 

Regulation (SFAR) No. 100–2, the FAA 

recognizes the unique circumstances of 

certain members of the armed forces 

deployed outside the United States who 

may be unable to renew their certificates 

due to military commitments. An SFAR 

is typically expected to be effective for 

a discrete period of time to address 

temporary circumstances. However, as 

evident from the history of SFAR No. 

100–2, discussed at length in the 

NPRM,5 the FAA finds an ongoing need 

to retain this relief more permanently 

due to ongoing overseas military 

operations. Therefore, the FAA has 

determined that the content of SFAR 

No. 100–2 should be incorporated 

within part 61 in lieu of the SFAR. 

B. Summary of the NPRM

The FAA published an NPRM on May

23, 2023.6 The FAA proposed to remove 

the expiration date from flight instructor 

certificates, revise the renewal 

requirements for flight instructors, 

amend the flight instructor privileges to 

train initial flight instructor applicants, 

and incorporate the provisions of SFAR 

No. 100–2 within part 61. The initial 

comment period closed on June 22, 

2023. 

Commenters were instructed to 

provide comments on or before June 22, 

2023 (i.e., 30 days from the date of 

publication of the NPRM). However, 

during the original comment period, the 

FAA received a request to extend the 

comment period to provide additional 

time to the public to comment on the 

proposed rule.7 Specifically, the 

comment proposed several 

recommendations in lieu of the 

proposed rulemaking. One such 

recommendation urged the FAA to 

convene a working group and consult 

with the flight training industry and, at 

a minimum, an extension of the 

comment period until after AirVenture 

2023.8 The FAA reopened the comment 

period for an additional thirty (30) days, 

from November 1, 2023, through 

December 1, 2023.9 This decision aligns 

with the guidance of Executive Order 

13563,10 which advocates for a 

minimum 60-day comment period to 

ensure the public has a meaningful 

opportunity to comment. With this 

extension, the total comment period was 

60 days. 

C. General Overview of Comments

One hundred sixty commenters

responded to this NPRM during the 

initial 30-day comment period. The 

FAA received nine additional comments 

during the reopened comment period.11

Nineteen comments were from 

organizations, and the remainder were 

from individuals. The organizations 

who commented included industry 

advocacy groups, flight training 

providers, and flight instructor refresher 

course (FIRC) providers. Commenters 

included Air Line Pilots Association, 

International (ALPA); Aircraft Owners 

and Pilots Association (AOPA); AceCFI 

FIRC, American Flyers; Aviation 

Seminars; Eastern Kentucky University; 

Embry-Riddle Aeronautical University; 

Experimental Aircraft Association 

(EAA); Gleim Publications, Inc.; King 

Schools, Inc.; Lake Superior 

Helicopters; LeTourneau University; 

Liberty University School of 

Aeronautics; National Association of 

Flight Instructors (NAFI); Soaring Safety 

Foundation (SSF); Society of Aviation 

Flight Educators (SAFE); University of 

North Dakota; Western Michigan 

University; and Wright Base Flight 

Training. 

The FAA received 34 comments 

generally supporting the rule as 

proposed without recommending 

changes. Fifty-seven commenters 

opposed some portion of the proposed 

rule, although several of these 

commenters also supported portions of 

the proposed rule. Ninety commenters 

requested clarifications, changes, or 

additional provisions. A discussion of 

comments requesting specific 

clarifications, changes, or revisions to 

the NPRM and the FAA’s responses to 

these requests is in section IV. of this 

preamble. 

IV. Discussion of Comments and the

Final Rule

A. Removal of Expiration Date on Flight

Instructor Certificates (§ 61.19)

The NPRM proposed to remove the 

expiration date from flight instructor 

certificates, as most airman certificates 

issued under part 61 do not have 

expiration dates. Instead, a person could 

exercise the privileges of an airman 

certificate without an expiration date 

only if that person meets the 

appropriate recent experience 

requirements of part 61 specific to the 

operation or activity. Therefore, the 

FAA proposed to revise § 61.19(d) by 

creating two paragraphs under 

§ 61.19(d). As proposed, § 61.19(d)(1)

would remove the expiration date for

flight instructor certificates issued on or

after the final rule’s effective date.

Section 61.19(d)(2) would retain the

current requirement and state that flight

instructor certificates issued before the

final rule’s effective date would expire

24 calendar months from the month in

which they were issued, renewed, or

reinstated, as appropriate. Additionally,

the FAA proposed to revise § 61.19(a)(2)

to reflect that all certificates, not only

pilot certificates, except those issued

with an expiration date, are considered

valid unless surrendered, suspended, or

revoked. The FAA further proposed to

revise § 61.19(d) to remove the reference

to § 61.197(b) since the exception no

longer applied due to amendments to

§ 61.197(b). While the FAA received

many comments on these amendments,

the FAA adopts the amendments as

proposed. The subsequent discussion

responds to comments received.

Many commenters supported the 

proposed removal of the expiration date 

from flight instructor certificates, citing 

consistency with other airman 

certificates, which do not have an 

expiration date. Supporters agreed that 

not printing and mailing new 

certificates every 24 calendar months 

would result in a cost savings to the 

FAA. However, six commenters 

opposed the proposal because they 

believed removing the expiration date 

would not provide enough relief in 

these areas. 

One commenter supported the 

removal of the expiration date, provided 

that flight instructors are required to 

maintain instructional proficiency. The 


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12The SSF referred specifically to the FAA’s Pilot 

Records Database (PRD) and sought information on 

how updates to the PRD will accommodate FIRC 

providers in continuing to notify flight instructors 

about relevant FIRCs. It is important to note that the 

PRD is managed by the FAA and is accessible only 

to Part 119 certificate holders and fractional 

ownerships, not the general public. For publicly 

accessible information on airman certificates, 

including pertinent flight instructor certificate 

expiration dates, one can refer to the FAA’s Airmen 

Certification website at www.faa.gov/licenses_

certificates/airmen_certification. 

FAA acknowledges this requirement 

remains and notes that the proposed 

requirement to meet flight instructor 

recent experience in accordance with 

§ 61.197 ensures instructional 

proficiency. 

Three commenters contended that the 

only cost savings from removing the 

expiration date from flight instructor 

certificates is to the FAA in the 

production and mailing of new 

certificates. 

As explained in Section III.A.1. of the 

NPRM preamble, the FAA’s intent is to 

address industry requests to align the 

flight instructor certificate with other 

pilot certificates by removing the 

expiration date from the certificate. This 

final rule achieves this goal in addition 

to reducing the FAA’s administrative 

burden and industry expense to 

reinstate flight instructor privileges. The 

economic impact analysis in section 

V.A. further details the cost savings to 

the FAA and industry. 

Comments Concerning the Impact of the 

Expiration Date Removal on Flight 

Instructors 

Five commenters opined that the 

expiration date removal does not reduce 

the administrative burden to instructors, 

who must still meet recent experience 

requirements that are akin to the 

previous renewal requirements. The 

FAA maintains that the previous flight 

instructor renewal requirements are 

retained as recent experience options to 

ensure the quality of flight training 

remains unaffected by the removal of 

the expiration date on the flight 

instructor certificate. The recent 

experience options provide instructors 

flexibility to select from several options 

to maintain recent experience according 

to their individual needs and 

circumstances. Further consideration of 

comments specific to the proposed 

recent experience requirements is 

discussed separately. 

Three commenters noted that a failure 

to comply with recent experience 

requirements would require a flight 

instructor to reinstate their flight 

instructor privileges before providing 

flight instruction again, resulting in no 

practical change from a certificate with 

an expiration date. 

The FAA acknowledges that flight 

instructors may not provide flight 

instruction if their recent experience has 

lapsed and must reinstate their flight 

instructor privileges before exercising 

those privileges. To mitigate the impact 

of these requirements, the FAA 

proposed an additional option that 

allows a flight instructor to reinstate 

their privileges by completing an FIRC 

within the first three calendar months 

following a lapse of recent experience, 

as opposed to completing a practical 

test. Further consideration of comments 

specific to the proposed reinstatement 

requirements is discussed separately. 

Commenters also provided mixed 

assessments on the effect of removing 

the expiration date, with some 

supporting the proposal for its potential 

to encourage flight instructors to remain 

active or encourage new flight 

instructors to pursue certification due to 

the decreased burden. Others expressed 

concerns that it might drive longtime 

instructors to quit due to the challenges 

of meeting new recent experience 

requirements or adapting to changes 

introduced in this rulemaking. One 

other opposing commenter believed the 

recent experience requirements would 

present new burdens to maintaining 

privileges. 

The FAA reiterates that all existing 

renewal options will remain available as 

recent experience options. Flight 

instructors may complete a recent 

experience option of their choice and 

then submit an Airman Certificate and/ 

or Rating Application (FAA Form 8710– 

1 or 8710–11, as applicable) to validate 

and record their recent experience. 

Comments Concerning Comparison to 

Other Professional Certification 

Several commenters opposed the 

removal of the expiration date on a 

flight instructor’s certificate, noting that 

expiration dates are common in other 

professional licenses and certifications 

and do not typically constitute a 

burden. Some commenters 

misunderstood the proposal, 

erroneously believing it would relax 

standards for flight instructors. 

In response, the FAA acknowledges 

that while some flight instructors do not 

perceive the expiration date as 

burdensome, the decision to remove the 

expiration date came as a result of 

requests from several industry pilot 

organizations, including AOPA. The 

FAA reiterates that the removal of the 

expiration date does not relax the 

standards for flight instructors who 

must continue to complete recent 

experience requirements in lieu of the 

former renewal requirements, ensuring 

that only proficient flight instructors are 

qualified to provide flight instruction. 

Comments Concerning the Verification 

of Flight Instructor Privileges 

Numerous commenters made 

recommendations or highlighted 

concerns regarding the proposal’s 

impact on the ability to verify a flight 

instructor certificate and recent 

experience validity. Four commenters, 

including AOPA and the National 

Association of Flight Instructors (NAFI), 

supported the proposal but 

recommended that the FAA should 

provide access to a public database to 

verify a flight instructor certificate and 

the instructor’s recent experience. 

Another supporting commenter 

recommended that the FAA should 

notify instructors prior to the end of 

their recent experience period. The 

Soaring Safety Foundation (SSF) 

requested information on what flight 

instructor data the FAA will make 

public to identify flight instructors who 

could use their FIRC to renew their 

certificate.12 They expressed concern 

that without an expiration date, FIRC 

providers will not be able to contact and 

remind instructors that their instructor 

privileges are about to expire. 

Several opposing commenters 

expressed similar concerns. Eleven 

commenters, including two national 

FIRC providers, expressed concern that 

removing the expiration date could lead 

to instructors forgetting when their 

recent experience period ends. Six other 

commenters were concerned that 

without an expiration date on the flight 

instructor certificate, it would be more 

difficult for clients, flight schools, and 

the flight instructor themselves to 

determine if a flight instructor’s 

privileges are valid. 

The FAA notes that a flight instructor 

can verify the status of their flight 

instructor certificate online at the FAA’s 

online Airmen Certificate Information 

website or by contacting the FAA 

Airman Certification Branch. This 

publicly available database will 

continue to serve as a resource for flight 

instructors to confirm when their 

current recent experience will end, and 

it will allow the public to verify the 

status of a flight instructor’s credentials. 

Four commenters expressed concern 

that a flight instructor may 

inadvertently provide instruction after 

their privileges lapse if they lose track 

of the end date of their current recent 

experience. These commenters believe 

that this could result in potential 

liability or financial consequences to 

both the instructor and their students if 

invalid instruction is provided or 

received, respectively. 


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The FAA notes that the removal of the 

expiration date from flight instructor 

certificates does not increase the risk of 

this scenario. Even with an expiration 

date on the certificate, a flight instructor 

could inadvertently provide flight 

instruction after this date. The FAA 

considers flight instructors professionals 

capable of tracking and timely 

completing their recent experience 

requirements. An instructor’s 

credentials can be verified using the 

publicly available Airmen Certificate 

Information website. 

Comments Concerning the Effect on 

Flight Instructor Privileges 

The Air Line Pilots Association, 

International (ALPA) supported the 

proposal yet expressed concerns that 

some flight instructors might not 

comprehend the ongoing requirement to 

maintain recent experience or face the 

need for reinstatement. Additionally, 

several commenters seemed to 

misinterpret the removal of the 

expiration date from flight instructor 

certificates as implying that flight 

instructors would no longer need to 

maintain proficiency or might not 

receive updated information. Other 

commenters seemed to believe the 

proposal would change the 

requirements to maintain flight 

instructor privileges and currency. One 

commenter seemed to believe the rule 

would automatically reinstate expired 

flight instructor certificates. 

The FAA clarifies that the removal of 

the expiration date from flight instructor 

certificates does not alter flight 

instructor eligibility, aeronautical 

knowledge, or flight proficiency 

requirements. Initial flight instructor 

applicants will continue to be evaluated 

to the same standard as before the 

removal of the expiration date on the 

flight instructor certificate. As 

previously discussed, renewal 

requirements are retained as recent 

experience requirements to ensure flight 

instructors continue to maintain 

instructional knowledge and 

experience. The new requirements 

provide one additional option to meet 

recent experience, but no other new 

requirements to maintain flight 

instructor privileges were introduced as 

part of this rule. Finally, the FAA notes 

that the final rule will not automatically 

reinstate an expired flight instructor 

certificate. A flight instructor with an 

expired flight instructor certificate must 

meet one of the reinstatement 

requirements specified in § 61.199 to 

reinstate their privileges. 

B. Changing the Flight Instructor 

Certificate Renewal Requirements to 

Flight Instructor Recent Experience 

Requirements (§ 61.197) 

This final rule retains the current 

methods for flight instructor certificate 

renewal, as specified in § 61.197(a), but 

refers to them as flight instructor recent 

experience requirements. Instead of 

renewing their flight instructor 

certificate every 24 calendar months, a 

flight instructor will now need to 

establish recent experience at least once 

every 24 calendar months. This change 

ensures the quality of flight training is 

not adversely affected by retaining the 

existing standard despite the removal of 

the expiration date from the flight 

instructor certificate. This change also 

aligns the flight instructor certificate 

with the other airman certificates in part 

61 that are based on recent experience. 

The FAA notes these changes do not 

impose new requirements on flight 

instructors, as they may continue to 

select from one of the five existing 

methods to satisfy the recent experience 

requirements. Additionally, the final 

rule adds another option to satisfy 

recent experience, which is further 

explained in the FAA-sponsored pilot 

proficiency program discussion of this 

preamble. 

Section 61.197 will continue to 

require flight instructors to submit an 

Airman Certificate and/or Rating 

Application along with associated 

documentation to the FAA upon 

completing the recent experience 

requirements. The submission of FAA 

Form 8710–1 or 8710–11, as applicable, 

remains the only acceptable method for 

a flight instructor to submit their data to 

the FAA to identify, validate, and track 

the flight instructor’s recent experience. 

Retaining this process allows the FAA 

to continue tracking and recording the 

status of flight instructor certificates by 

capturing the events in which an 

applicant satisfies the recent experience 

requirements of § 61.197 as revised in 

this final rule. While the flight 

instructor will not be applying to renew 

a certificate, using FAA Forms 8710–1 

and 8710–11 to collect data is necessary 

to maintain an accurate record of flight 

instructors who are eligible to exercise 

their privileges. This process also 

supports the FAA’s ability to provide 

necessary data to governmental offices 

and industry upon request. 

Seventy-two commenters responded 

to the proposed recent experience 

requirements, of which thirteen 

supported and twenty-nine opposed the 

proposal. Thirty commenters made 

suggestions or comments without 

clearly supporting or opposing this 

proposal. 

Comments Concerning Extension of the 

Recent Experience Period 

Four commenters recommended 

extending the 24-calendar month recent 

experience period for establishing 

recent experience to reduce the 

frequency with which flight instructors 

must meet these requirements. 

Comments ranged from extending it to 

36–48 calendar months, with one 

comment recommending up to 5 years, 

and another suggesting that flight 

instructors who have held a flight 

instructor certificate for over 10 years 

should be exempt from recent 

experience requirements. A fifth 

commenter simply opposed the 24- 

calendar month recent experience 

period because that person believes it is 

an undue burden. 

However, the FAA finds the 24- 

calendar month period appropriate, as 

the knowledge and skills pertinent to 

flight instruction can diminish over 

time. This duration ensures the time 

between recent experience events is 

suitable for a flight instructor to best 

retain these instructional abilities. 

Additionally, the FAA notes that the 

duration of the 24-calendar month 

period is consistent with other common 

pilot recent experience periods, 

including the § 61.56 flight review. The 

FAA declines to adopt the 

recommendations to extend the recent 

experience period and will retain the 

24-calendar month period to ensure 

flight instructors remain proficient. 

Comments Concerning Differences 

Between Flight Instructor Recent 

Experience and Pilot Recent Experience 

Three commenters opposed the 

proposed changes because they believed 

the requirements do not align flight 

instructor requirements with those for 

other pilot certificates, particularly 

noting that the requirement to reinstate 

flight instructor privileges, if recent 

experience requirements are not met, is 

unique to flight instructor certificates. 

Because the consequences remain the 

same as the previous renewal 

requirements, these commenters 

contended that the proposed recent 

experience requirements provide no 

practical relief. 

The FAA notes that a flight instructor 

certificate is different than a pilot 

certificate, and both certificates afford 

different privileges. The flight instructor 

certificate pertains to instructional 

ability rather than pilot skill. The 

instructional role of flight instructors 

requires specific, stringent measures to 

ensure safety and the quality of training 


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provided. This is analyzed in greater 

detail in the discussion addressing 

comments regarding reinstatement 

requirements. 

Three commenters recommended that 

both teaching and flying skills should be 

assessed as part of meeting recent 

experience requirements. Two of these 

commenters recommended that flight 

instructors undergo an evaluation 

similar to the flight review required by 

§ 61.56 and receive an endorsement 

from the instructor who conducted the 

evaluation. One commenter asserted 

that this review should be limited to 

instructors who did not provide any 

flight instruction in the preceding 24 

calendar months. 

As noted earlier, the flight instructor 

certificate pertains to instructional 

ability rather than pilot skill. 

Furthermore, requiring all instructors to 

complete a ground and/or flight 

evaluation conducted by another flight 

instructor to meet recent experience 

would pose an unnecessary burden to 

instructors. The existing flight review 

requirement in § 61.56 ensures that a 

flight instructor must maintain 

necessary piloting skills to act as pilot 

in command during flight instruction. 

Comments Concerning Determination of 

the Recent Experience Period 

The SSF requested clarification on the 

use of the term ‘‘month’’ within the 

proposed § 61.197(a)(1) through (3), 

which defines the start of the 24- 

calendar month recent experience 

period. The FAA notes that ‘‘month’’ is 

intended to identify a specific calendar 

month as referenced in § 61.197(a), 

ensuring consistency with the method 

previously used in § 61.197(b) for 

determining the flight instructor’s 

expiration month. 

One commenter recommended that all 

recent experience activities should be 

accomplished within the three calendar 

months preceding the documenting of 

that recent experience in accordance 

with § 61.197(b). The FAA finds that 

this recommendation would be 

unsuitable for forms of recent 

experience under § 61.197, other than 

completion of a FIRC. For instance, the 

§ 61.197(b)(2)(i) recent experience 

option of recommending five applicants 

for a practical test with an 80 percent 

pass rate on the applicants’ first attempt 

considers all instructional activity in the 

preceding 24 calendar months to 

determine that instructor’s pass rate. If 

this was limited to the three calendar 

months preceding the recent experience 

validation (i.e., submission of FAA 

Form 8710–1 or 8710–11 to a certifying 

official), it is likely very few instructors 

would qualify for this option. 

Furthermore, the FAA notes that even 

an FIRC may be started and taken over 

more than three calendar months as 

long as the flight instructor begins the 

course within their current recent 

experience period. Although 

§ 61.197(b)(2)(iii) requires that the FIRC 

must be completed within the preceding 

three calendar months of recent 

experience validation, a flight instructor 

is not precluded from taking the course 

gradually over a prolonged period 

throughout their current 24-calendar 

month recent experience period. 

One commenter recommended that 

the FAA develop a system to 

automatically notify a flight instructor 

that they are nearing the end of their 24- 

calendar month recent experience 

period, such as by sending an email. 

Recognizing the utility of such 

notifications, the FAA will make the 

end date of a flight instructor’s recent 

experience period publicly available 

through the FAA’s online ‘‘Airmen 

Inquiry Search Page’’ and by contacting 

the FAA Airman Certification Branch 

directly. This is similar to the 

information previously provided 

regarding flight instructor certificate 

expiration dates. The FAA will continue 

to use this method. 

Additionally, the FAA notes that it 

does not currently have a system 

capable of all necessary functions to 

identify flight instructor certificate 

expiration dates or recent experience 

end dates and then send an email 

reminder or other appropriate 

notification to that airman. However, 

the FAA is considering developing an 

automated email notification system for 

flight instructors, like the commenter 

recommended, and will provide further 

information in the future. 

Comments Concerning Recent 

Experience by Recommending 

Applicants for Practical Tests 

(§ 61.197(b)(2)(i)) 

One commenter opposed the 

§ 61.197(b)(2)(i) recent experience 

option of recommending at least five 

applicants for a practical test within the 

preceding 24 calendar months, with at 

least 80 percent of those applicants 

passing the test on their first attempt. 

This commenter stated that experience 

does not guarantee competency and 

believed many flight instructors 

produce poor pilot applicants. 

The FAA recognizes that while 

experience alone does not guarantee 

competency, the requirement to 

recommend a minimum of five 

applicants for a practical test with 80 

percent passing on their first attempt is 

intended to provide a verifiable 

measurement of a flight instructor’s 

performance. Under this requirement, 

flight instructors must have 

demonstrated success as evidenced by 

the applicants’ pass rate on their first 

attempt. This provides additional 

assurance of the flight instructor’s 

competency through the objective 

evaluation of the applicants by the FAA 

or designated examiner. Therefore, the 

FAA retains this recent experience 

option. 

National FIRC provider Aviation 

Seminars asked several questions 

regarding recent experience based on 

instructional activity, in accordance 

with § 61.197(b)(2)(i). Specifically, they 

asked if this recent experience option 

would recognize instructors who 

conduct § 61.56 flight reviews or the 

instrument proficiency checks of 

§ 61.57(d). They also asked how flight 

instructors maintaining recent 

experience using this option would 

remain up to date on new information. 

They additionally asked how a flight 

instructor’s activity and pass rate are 

verified during recent experience 

validation. Finally, they asked if the 

FAA’s Integrated Airman Certification 

and Rating Application (IACRA) system 

would automatically prevent a flight 

instructor who does not meet recent 

experience requirements from signing 

other pilots’ FAA Form 8710–1 or 8710– 

11, as applicable, as a recommending 

instructor. 

The FAA notes that flight reviews and 

instrument proficiency checks do not 

satisfy the recent experience option of 

§ 61.197(b)(2)(i) because they do not 

provide the demonstrated record of 

success necessary to validate 

competency under this specific 

provision. This recent experience 

requirement measures a flight 

instructor’s competency based on the 

number of practical test endorsements 

the recommending instructor has given 

during the preceding 24 calendar 

months and the resulting first-time pass 

rate. The FAA finds that when an 

instructor validates their recent 

experience using § 61.197(b)(2)(i), they 

would provide the certifying official the 

records that the flight instructor is 

required by § 61.189 to maintain. 

Additionally, FAA records track and 

record the flight instructor’s 

recommendations and pass rate through 

data submitted on the applicable 

Airman Certificate and/or Rating 

Application, FAA Form 8710–1 or 

8710–11. 

Regarding the functionality of IACRA, 

if a flight instructor does not reestablish 

recent experience prior to the end of 

their recent experience period, IACRA 

will prevent their ability to process 

applications as the recommending 


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13Legal Interpretation to Crowe-Palm Beach 

Helicopters (August 28, 2015). drs.faa.gov/browse/ 

excelExternalWindow/FAA000000000LEGALINTPR

2015017PDF.0001. 

14Currently, FAA Order 8900.1, Vol 5, Ch 2, Sec 

11, paragraph 5–504B1, list the documentation that 

an applicant should provide to the certifying 

official to renew their flight instructor certificate 

under § 61.197(a)(2)(ii). This includes a company 

manual and a letter with a company letterhead from 

management office. The employment 

documentation should clearly show that the 

applicant is in a position involving the regular 

evaluation of pilots; the applicant has satisfactory 

knowledge of current FAA pilot training policies 

and standards; and the applicant has satisfactory 

knowledge of the FAA certification processes. 

Paragraph 5–504B1 concludes with examples of 

positions in which applicants may qualify for flight 

instructor certificate renewal under 

§ 61.197(a)(2)(ii). 

instructor. However, a brief 

administrative period is allowed postrecent experience period to account for 

any possible delays in processing 

documentation to establish recent 

experience. This is identical to the 

IACRA system functionality previously 

used when a flight instructor’s 

certificate expired. 

Eighteen commenters, including 

national FIRC provider Gleim 

Publications, recommended expanding 

the types of instructional activities that 

qualify under the § 61.197(b)(2)(i) recent 

experience option. They proposed 

recognizing activities that do not 

necessarily result in an endorsement for 

a practical test. One commenter 

expressed concern that not recognizing 

this type of instructional activity could 

lead to a loss of experienced instructors 

who do not meet the requirements for 

this recent experience option. 

The FAA acknowledges that many 

important instructional activities do not 

result in an endorsement for a practical 

test; however, these activities do not 

result in a demonstrated record of 

success to validate the flight instructor’s 

competency. As a result, the FAA 

cannot adopt this recommendation. 

Additionally, it is important for flight 

instructors to understand that the recent 

experience option based on 

instructional activity is just one of 

several options available. If an 

instructor does not meet the criteria to 

establish recent experience through 

their instructional activity, they may 

establish recent experience through one 

of five other options in § 61.197(b). 

Therefore, the FAA declines to expand 

this recent experience option to include 

activities that do not lead to a practical 

test endorsement. 

Two commenters, including 

LeTourneau University, recommended 

changing the criteria to meet recent 

experience through instructional 

activity to provide additional tolerance 

for simple applicant errors and 

instructors whose performance has 

improved over time. One commenter 

recommended allowing the 80 percent 

pass rate criterion to be met if the 

applicants pass on their second attempt 

to prevent simple applicant errors from 

negatively impacting the instructor. 

Another commenter recommended 

evaluating the first-time pass rate based 

either on the performance of the five 

most recent applicants or all applicants 

in the preceding 24 calendar months the 

flight instructor recommended, 

whichever produces a more favorable 

pass rate. The commenter believed this 

would recognize instructors who 

improved their performance over the 24- 

month period. 

The FAA acknowledges that simple 

errors can occur during a practical test 

which is not a direct consequence of the 

instructor’s preparation of that 

applicant. However, the FAA notes that 

a failure on a practical test may be an 

indication of a flight instructor’s 

insufficient preparation or ineffective 

instruction of the applicant. If 80 

percent of a flight instructor’s applicants 

needed only to pass a practical test on 

their second attempt, this would not 

ensure an acceptable level of 

instructional competency to meet recent 

experience requirements. Similarly, 

considering only the most favorable data 

over a 24-month period could obscure 

ongoing deficiencies in the instructor’s 

competency. Therefore, the FAA finds it 

necessary to consider the instructor’s 

performance over the preceding 24- 

calendar months to ensure that 

significant deficiencies are not 

overlooked. The FAA has also included 

a minor change in § 61.197(b)(2)(i) to 

clarifying that the 80 percent pass rate 

criterion applies to all applicants that 

the flight instructor endorsed for a 

practical test in the preceding 24 

calendar months. As a result, the FAA 

will not adopt these recommendations. 

One commenter, a chief flight 

instructor at a part 141 pilot school with 

examining authority, inquired whether 

flight instructors who instruct in an 

approved part 141 training course for 

which that pilot school holds examining 

authority would be allowed to count 

applicants who complete an end of 

course test towards meeting the 

§ 61.197(b)(2)(i) instructional activitybased recent experience option. 

An end-of-course test administered 

under part 141 by a school with 

examining authority is considered 

equivalent to a practical test for the 

purposes of meeting the § 61.197(b)(2)(i) 

recent experience requirement.13

Therefore, flight instructors who 

provide end-of-course training are 

engaged in activities that meet the 

criteria for recent experience, provided 

the instructor must personally provide 

an endorsement for the end-of-course 

test for each applicant. The instructor’s 

records, maintained in accordance with 

§ 61.189(b)(2), must document that the 

instructor met all criteria of 

§ 61.197(b)(2)(i). The FAA suggests that 

the instructor also sign the applicant’s 

Airman Certificate and/or Rating 

Application as the recommending 

instructor for each applicant the 

instructor recommends for an end-ofcourse test. The instructor’s 

endorsement and recommendation 

would be additional to the separately 

required air agency recommendation on 

the application. 

Two commenters expressed concern 

that the recent experience options of 

§ 61.197(b)(2)(i), based on instructional 

activity, or § 61.197(b)(2)(ii), by serving 

in a position involving the regular 

evaluation of pilots, may not adequately 

ensure that flight instructors stay 

informed about the latest developments 

in teaching techniques necessary to 

remain proficient as a flight instructor. 

The FAA notes that both options 

existed under previous renewal 

requirements and have a longstanding 

precedent of being an acceptable means 

to retain flight instructor privileges. As 

discussed, the instructional activity 

under the criteria of § 61.197(b)(2)(i) 

requires a demonstrated record of 

success that attests to the flight 

instructor’s instructional competency. 

To achieve this high level of 

demonstrated success, an instructor 

would need to keep up to date on recent 

developments and techniques. After 

satisfactorily completing a recent 

experience requirement, a flight 

instructor must submit documentation 

of such in a form and manner acceptable 

to the Administrator, in accordance 

with § 61.197(b)(2). FAA policy 

expresses the form and manner that is 

acceptable to the Administrator. This 

policy ensures that a flight instructor 

has knowledge of current pilot training 

standards and FAA certification 

standards by requiring supporting 

documentation appropriate to the 

position. This policy is expressed in 

Advisory Circular (AC) 61–65 and FAA 

guidance directing the activities of 

aviation safety inspectors (ASI).14 By 

ensuring a flight instructor has 

knowledge of current pilot training 

standards and FAA certification 

standards, the FAA verifies they have 

remained up to date on recent 

developments in pilot certification. As a 

result, the FAA finds that these two 

recent experience options provide an 


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15 Ibid. 

16 Ibid. 

equivalent level of safety and 

instructional skill compared to other 

recent experience options. 

Comments Concerning Recent 

Experience by Serving in a Position 

Involving the Regular Evaluation of 

Pilots (§ 61.197(b)(2)(ii)) 

Several commenters, including NAFI, 

recommended that the FAA recognize 

additional positions qualifying for the 

§ 61.197(b)(2)(ii) recent experience 

option. The positions recommended 

include designated pilot examiners 

(DPEs); part 142 training center 

instructors; qualification as a part 121, 

125 or 135 pilot in command; positions 

within a training organization under 

part 121, 125, 129, 135, 141, or 142; or 

any flight instructor determined to be 

qualified by an FAA aviation safety 

inspector. 

The phrase ‘‘in a position involving 

the regular evaluation of pilots’’ as 

specified in § 61.197(b)(2)(ii) and FAA 

policy,15 is intended to cover a variety 

of activities that directly involve the 

evaluation of pilot performance and not 

the routine instructional duties typically 

associated with a flight instructor. A 

flight instructor eligible under the 

§ 61.197(b)(2)(ii) recent experience 

option should be employed in a position 

for the primary purpose of conducting 

evaluations of other pilots, such as 

company check pilots or instructors in 

part 121 or 135 operations. 

The FAA further notes that several 

positions recommended by commenters 

are already recognized for establishing 

flight instructor recent experience, such 

as designated pilot examiner or a pilot 

in command of a multiple-pilot 

flightcrew under part 121, 125 or 135. 

These positions are identified in 

Advisory Circular 61–65, as amended, 

and the FAA intends to continue to 

accept these positions under the new 

requirements. Additionally, other 

positions involving the regular 

evaluation of pilots, such as chief flight 

instructors, may also utilize this recent 

experience option. Furthermore, the 

FAA requires that the instructor 

provides documentation to support their 

engagement in such roles, to verify they 

possess satisfactory knowledge of 

current FAA pilot training policies and 

standards and satisfactory knowledge of 

the FAA certification processes.16 Thus, 

the FAA has decided not to amend 

§ 61.197(b)(2)(ii) in response to these 

recommendations. 

One commenter recommended that 

the FAA include in the regulations the 

specific positions recognized as 

involving the regular evaluation of 

pilots, as per § 61.197(b)(2)(ii). The 

commenter also recommended that the 

FAA not require documentation 

validating a flight instructor’s eligibility 

to establish recent experience on this 

basis. 

In response, the FAA finds that 

specifying a list of eligible positions 

under § 61.197(b)(2)(ii) could restrict the 

flexibility needed to accommodate 

various and potentially new roles that 

involve regular pilot evaluation. This 

approach avoids the need for additional 

rulemaking to expand or modify the list 

as new roles emerge. Regardless, 

documentation of a flight instructor’s 

position and their knowledge of FAA 

training and certification policies and 

processes remains essential to ensure 

the instructor is qualified and prepared 

to provide effective flight instruction. 

One commenter recommended that 

the FAA establish and require a 

minimum amount of time that a flight 

instructor must hold a position 

involving the regular evaluation of 

pilots to establish recent experience 

based on holding that position in 

accordance with § 61.197(b)(2)(ii). 

The positions that are accepted per 

§ 61.197(b)(ii) are higher level roles with 

the primary purpose of evaluating other 

pilots, such as check pilots, chief flight 

instructors, flight instructors in a part 

121 or part 135 operation, and 

designated pilot examiners. 

Additionally, the FAA finds the 

requirement to hold the position within 

the preceding 24 calendar months is 

consistent with the other recent 

experience options. For these reasons, 

the FAA will not adopt this 

recommendation. 

Comments Concerning Recent 

Experience by Successfully Completing 

a FIRC (§ 61.197(b)(2)(iii)) 

AOPA requested clarification 

regarding the meaning of ‘‘within the 

preceding three calendar months’’ for 

satisfying recent experience 

requirements by completion of a FIRC in 

accordance with § 61.197(b)(2)(iii). 

AOPA expressed concern that the FAA 

intends instructors to complete a FIRC 

every three calendar months to maintain 

recent experience. 

A flight instructor is required to 

complete a FIRC once within their 24- 

calendar month recent experience 

period, receive a graduation certificate 

within the three calendar months, and 

document this recent experience by 

submitting FAA Form 8710–1 or 8710– 

11, as appropriate, to a certifying 

official. 

National FIRC provider Gleim 

Publications recommended maintaining 

the FIRC as a valid option for recent 

experience due to the value of training 

it provides in keeping instructors 

knowledgeable. 

The FAA has long supported the 

completion of an approved FIRC as an 

option to meet the former renewal 

requirements and will continue to do so 

as a recent experience option under the 

new § 61.197(b)(2)(iii). 

Two commenters expressed concern 

for the continued acceptance of 

completion of a FIRC to satisfy recent 

experience requirements. One 

commenter stated that FIRCs often test 

rote knowledge and trivia, rather than 

promoting or evaluating higher-order 

learning. This commenter also stated 

that the information provided in FIRCs 

is often outdated and doesn’t address 

important issues or types of instruction 

beyond primary flight training. 

Furthermore, this commenter noted that 

a flight instructor who doesn’t provide 

dual instruction or log any pilot-incommand time during a 24-month 

period can still renew a flight instructor 

certificate solely by completing a FIRC, 

a situation they believe contradicts the 

emphasis on currency as proposed in 

the NPRM to this final rule. The other 

commenter believed that a flight review 

is a more rigorous way to assess an 

instructor’s presentation and 

airmanship skills and suggested that 

practical instructional and flying skills 

should be prioritized over logging hours 

in front of a computer screen. 

The FAA finds that FIRCs keep flight 

instructors informed of the changing 

world of flight training and enhance 

aviation safety through continued up-todate refresher training of the flight 

instructor cadre. Additionally, the 

recurrent training provided by a FIRC is 

essential because many attendees may 

not otherwise be aware of recent 

changes affecting pilot training. For 

these reasons, the FAA considers 

completion of an approved FIRC a 

valuable option to maintain flight 

instructor recent experience. 

However, the FAA acknowledges the 

need to find a balance in response to 

comments received. While some 

commenters have suggested making 

FIRCs more demanding, others have 

proposed reducing the total hours 

required or restructuring the FIRC 

program. In considering these differing 

comments, the FAA notes it retains the 

ability to modify training course outline 

(TCO) guidance to achieve the 

appropriate training outcome. This 

approach allows for balancing the FIRC 

content to ensure it effectively meets the 

training needs of flight instructors. 

Eight commenters, including SAFE 

and NAFI, recommended adopting a 


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continuing education model for FIRCs. 

These commenters suggested this model 

would allow an instructor to complete 

refresher modules on an ongoing basis, 

rather than within the typically brief 

period in which a FIRC is completed. 

Several commenters also supported this 

belief that a continuing education model 

would allow the course to provide more 

relevant information. 

The FAA notes that flight instructors 

can start an internet-based FIRC at any 

time during their recent experience 

period and progress through the course 

modules at their own pace, as long as 

they complete and receive the FIRC 

graduation certificate before they submit 

their recent experience documentation 

to a certifying official prior to the end 

of their recent experience period. It is 

important to note that although 

providers that present conventional inperson FIRCs typically conduct their 

courses in two days, internet-based 

FIRCs allow their attendees to complete 

course modules at their own pace. 

While all FIRCs allow instructors to 

complete their FIRC at any time during 

their current recent experience period, 

some online FIRCs may allow ongoing 

training throughout the attendee’s 

current recent experience period. 

However, the following requirements 

still apply in all cases: (1) The attendee 

must complete the FIRC within the 

three calendar months preceding 

submitting their documentation. (2) To 

retain their current recent experience 

end date, the flight instructor attendee 

must complete the FIRC and submit 

their documentation within three 

calendar months preceding the last 

month of their current recent experience 

period. Flight instructors seeking to 

begin a FIRC to receive ongoing training 

during their recent experience period 

should contact the provider before 

enrollment to ensure that the provider’s 

FIRC meets the instructor’s individual 

training plan. 

Furthermore, FIRCs currently provide 

regularly updated training using the 

most relevant information. For instance, 

the FAA expects FIRC providers to 

quickly update their presentation 

materials to reflect relevant changes in 

FAA regulations, policies, and safetyrelated publications, such as FAA Acs 

and handbooks, to stay completely up to 

date at all times. Moreover, a FIRC 

provider may update their course as 

needed provided they include all course 

content that the Administrator has 

determined necessary. AC 61–83, 

Nationally Scheduled, FAA-Approved, 

Industry-Conducted Flight Instructor 

Refresher Course, provides advisory 

guidance and recommendations for the 

preparation and approval of TCOs for 

FAA-approved, industry-conducted 

FIRCs, Furthermore, AC 61–83, 

paragraph 14.1, explains that the FAA 

approves all proposed substantive 

changes to the TCO before the provider 

presents them in a FIRC. These 

processes ensure that FIRCs provide 

timely content and more relevant 

training to course attendees. For these 

reasons, the FAA finds it unnecessary to 

restructure the FIRC program by 

adopting a continuing education model 

as recommended by these eight 

commenters. 

One commenter suggested that the 

overall FIRC hour requirement should 

be reduced to 8 hours, in addition to 

adopting a continuing education model. 

The FAA believes that reducing the 

minimum hours required for a FIRC 

presentation from 16 to 8 hours would 

not allow for the effective delivery of all 

required training content and attendees 

would receive less information during 

the course. As previously noted, two 

other commenters suggested even more 

rigorous standards for approved FIRCs. 

The FAA finds that the current policy 

requiring no fewer than 16 hours of 

ground and/or flight instruction 

maintains a sufficient standard for a 

flight instructor to remain updated and 

establish recent experience. 

One commenter suggested that the 

completion of a FIRC at any time within 

a flight instructor’s 24-calendar month 

recent experience period should retain 

the same end month of the instructor’s 

current recent experience period and 

extend the recent experience period for 

an additional 24 calendar months. 

This recommendation, if applied, 

could effectively result in nearly 48- 

months of continued recent experience 

before the flight instructor is required to 

reestablish recent experience again. 

However, the recent experience 

requirements are intended to ensure a 

flight instructor retains instructional 

knowledge and proficiency, which 

degrades over time. As a result, the FAA 

finds it necessary to limit the provision 

of § 61.197(a)(3) to ensure a flight 

instructor establishes recent experience 

without an excessively long interval 

between recent experience events. 

Two commenters recommended that 

the FAA develop and directly 

administer FIRC rather than rely on 

approved FIRC providers to offer these 

courses. 

The FAA considers a FIRC provider as 

a professional educator with skill in 

training the trainers. Although the 

FAA’s responsibility for the 

presentation of FIRCs was transferred to 

certain qualified industry organizations, 

the FAA maintains oversight of the FIRC 

program to include specifying the 

course content and structural guidelines 

as provided in AC 61–83. Before a FIRC 

can serve as a basis for flight instructor 

recent experience, the FAA must 

approve the TCO and issue a letter of 

authorization. This process allows the 

FAA to ensure FIRC providers offer 

courses which meet FIRC TCO 

development, training, and testing 

standards. Notably, the FAA finds that 

the history of flight instructor renewals 

demonstrates that FAA-approved, 

industry-conducted FIRCs have been 

successful for more than four decades. 

Therefore, the FAA declines to adopt 

this recommendation and will continue 

to authorize FIRC providers to offer 

these courses. 

Comments Concerning Recent 

Experience by Passing a U.S. Armed 

Forces Military Instructor Pilot or Pilot 

Examiner Proficiency Check 

(§ 61.197(b)(2)(iv)) 

Two commenters, including AOPA, 

recommended that the FAA amend the 

proposed § 61.197(a)(2)(iv), which 

allows a flight instructor to meet recent 

experience based on completion of a 

U.S. Armed Forces military instructor 

pilot or pilot examiner proficiency 

check, to include civilian contractor 

pilots engaged in military instruction. 

The FAA clarifies that the term 

‘‘military instructor,’’ as used in 

§ 61.197(a)(2)(iv), encompasses both 

military and civilian flight instructors 

who provide flight training within the 

U.S. Armed Forces. If a civilian who 

acts as a military flight instructor (e.g., 

as a contractor) for the U.S. Armed 

Forces receives a military instructor 

pilot or pilot examiner proficiency 

check, they are indeed eligible to 

exercise this recent experience option. 

Flight instructors must present an 

official military record documenting 

that they passed such proficiency 

checks within the preceding 24 calendar 

months to be eligible for this recent 

experience option. 

Comments Recommending Additional 

Recent Experience Options 

Four commenters, including NAFI 

and SAFE, recommended that 

accreditation as a master flight 

instructor by NAFI or through SAFE’s 

Master Instructor Continuing Education 

Program should count to establish 

recent experience under the final rule. 

The FAA notes that regulations 

cannot show preference toward any 

specific industry group or organization 

by codifying their name or program into 

regulations. Nevertheless, any industry 

group or organization wishing such 

approval may submit a request to the 

FAA for consideration of its program as 


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18Current section 61.197(b)(2) allows flight 

instructors to renew their flight instructor certificate 

within the three calendar month preceding the 

expiration month of the current flight instructor 

certificate. Flight instructors exercising this option 

would receive a new flight certificate within an 

expiration date 24 calendar months from their 

previous month of expiration. 

a qualifying means to satisfy members’ 

flight instructor recent experience. The 

FAA would then review the request and 

documentation to ensure that their 

program meets the applicable 

requirement of § 61.197 and, if so, 

subsequently continues to meet 

authorization requirements during each 

reauthorization cycle. 

However, master instructors 

accredited by these organizations may 

still qualify to establish recent 

experience under existing options, such 

as § 61.197(b)(2)(i) by recommending at 

least five applicants for a practical test 

for a certificate or rating with at least 80 

percent passing on their first attempt. 

Alternatively, if they hold a higher-level 

position with the primary purpose of 

evaluating pilots, such as a designated 

pilot examiner or a check pilot under 

part 121 or 135, they may qualify under 

§ 61.197(b)(2)(ii). 

Several commenters recommended 

additional methods of recent 

experience. Two commenters suggested 

allowing the flight instructor enhanced 

qualification training program (FIEQTP) 

to satisfy recent experience 

requirements for flight instructors. 

The FAA notes that although the 

FIEQTP is a comprehensive course 

designed to prepare a flight instructor to 

teach initial flight instructor applicants, 

its purpose is distinct from that of a 

FIRC. Unlike a FIRC, the FIEQTP does 

not expose flight instructors to the latest 

in-flight training techniques, the newest 

technologies, the latest operational 

safety procedures, or the latest 

regulatory and policy changes. By 

preparing flight instructors to teach 

initial flight instructor applicants, the 

FIEQTP serves a different purpose than 

the proposed recent experience options. 

Therefore, the FAA does not consider 

the FIEQTP appropriate for satisfying 

the recent experience requirements and, 

therefore, declines to adopt this 

recommendation. 

One commenter suggested allowing 

the annual instructor currency training 

under part 142 to count toward the 

recent experience requirements. 

Although a part 142 training center 

instructor must complete training every 

12 calendar months in accordance with 

§ 142.53, the specific training content 

required annually does not ensure the 

broad level of knowledge intended for 

recent experience. The FAA expects 

flight instructors to also have knowledge 

of part 61 pilot certification 

requirements and the associated Airman 

Certification Standards or Practical Test 

Standards. Thus, the FAA declines to 

adopt this recommendation. 

One commenter recommended 

allowing aviation educators to develop 

a new ‘‘teaching proficiency’’ course 

that includes three hours of ground 

training and three hours of flight 

training to improve instructional 

abilities and qualify as recent 

experience. 

The FAA welcomes industry 

initiatives that lead pilots to seek 

additional training and greater 

proficiency. However, this 

recommendation appears to overlap 

with the intent of approved FIRCs. 

Currently, FAA policy in AC 61–83, 

paragraph 10.10, allows for 

consideration of FIRCs with a flight 

component when coordinated with and 

approved by the FAA. The FAA will 

consider approval of FIRCs with a flight 

component on a case-by-case basis. As 

a result, the FAA will not adopt this 

recommendation. 

One commenter recommended that a 

flight instructor who holds a current 

§ 61.56 flight review and has endorsed 

another pilot for a certificate or rating, 

or conducted a § 61.56 flight review for 

another pilot, should be eligible to 

satisfy the recent experience 

requirement. 

The FAA notes that a flight review 

refreshes pilot knowledge and skill, not 

instructional proficiency. Additionally, 

the recommendation to endorse only 

one pilot for a certificate or rating is 

significantly less than the five required 

to qualify for the proposed recent 

experience option based on 

instructional activity in § 61.197(b)(2)(i). 

Furthermore, conducting a flight review 

does not result in a demonstrated record 

of success validating the flight 

instructor’s competency because it is 

not objectively evaluated by the FAA or 

an examiner. The FAA cannot adopt 

this recommendation since it does not 

ensure the flight instructor’s proficiency 

nor produce a demonstrated record of 

success. 

LeTourneau University recommended 

an option to establish recent experience 

for flight instructors who provide 100 

hours of training within the preceding 

12 months in training courses under 

part 61, 141, or 142. They believed this 

would recognize active flight instruction 

as a method of recent experience. 

The FAA notes that the recent 

experience option of § 61.197(b)(2)(i) 

recognizes active flight instruction and 

requires a demonstrated record of 

success based on applicants 

recommended for practical tests and the 

resulting rate of applicants who pass on 

their first attempt. The suggested 

approach does not produce the same 

demonstrated success attesting to the 

instructor’s competency. As a result, the 

FAA will not adopt the recommended 

amendment. 

Comment Concerning Removal of 

Reference to Flight Instructor Certificate 

Expiration From § 61.51(h)(2)(ii) 

In their comment, Western Michigan 

University identified an additional 

section in part 61 which would require 

amendment to accommodate the 

proposed removal of flight instructor 

certificate expiration dates. Currently, 

§ 61.51(h)(2)(ii) requires that the 

training time a person receives must be 

logged in a logbook and must include 

‘‘. . . the authorized instructor’s 

signature, certificate number, and 

certificate expiration date.’’ The 

commenter requested amending this 

section to allow logbook training time 

descriptions endorsed by authorized 

flight instructors who hold a flight 

instructor certificate without an 

expiration date. 

The FAA agrees with this commenter 

in that the identified section requires 

amendment to accommodate flight 

instructor certificates without expiration 

dates. As a result, § 61.51(h)(2)(ii) will 

be amended in two phases. In the first 

phase, the rule will be amended to 

require a logbook entry with a 

description of the training given that 

includes either the flight instructor’s 

certificate expiration date or the flight 

instructor’s recent experience end date, 

consistent with the requirements of 

§ 61.197. The first phase will commence 

on the effective date of the final rule. In 

the second phase, 27 calendar months 

after the effective date of the final rule, 

§ 61.51(h)(2)(ii) will be further amended 

to require a logbook entry with a 

description of the training given that 

includes only the flight instructor’s 

recent experience end date with the 

authorized instructor’s signature, and 

certificate number. This two-phased 

approach will ensure that flight 

instructors who hold a flight instructor 

certificate with an expiration date 

within the 27 calendar months after the 

effective date of the final rule will 

remain compliant with the requirements 

of § 61.51 until those flight instructors 

are required to meet the renewal 

requirements of this final rule. This 27- 

calendar month period after the 

effective date of the final rule will 

accommodate flight instructors who 

choose to renew their flight instructor 

certificate early, in accordance with 

current § 61.197(b)(2).17 This approach 


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ensures a smooth transition and 

maintains compliance throughout the 

amendment process. 

Comments Concerning the Requirement 

To Validate Recent Experience by 

Submitting FAA Form 8710–1 or 8710– 

11 to the Administrator 

Several commenters, including AOPA 

and SSF, requested clarification 

regarding how recent experience will be 

documented under the proposed rule. 

Other commenters misunderstood who 

would review supporting 

documentation and validate an 

application to establish recent 

experience. 

The process for validating and 

establishing recent experience under 

§ 61.197(b)(2) mirrors the procedural 

steps previously required to renew a 

flight instructor certificate. Flight 

instructors are required to submit an 

Airman Certificate and/or Rating 

Application (FAA Form 8710–1 or 

8710–11, as applicable) to the FAA 

along with associated documentation 

that shows the flight instructor 

satisfactorily completed one of the 

recent experience requirements. These 

forms are submitted through the IACRA 

or via a printed paper application and 

must be reviewed and validated by a 

certifying official. Certifying officials 

may include an FAA ASI or an FAA 

designee, such as an appropriately 

authorized designated pilot examiner or 

airman certification representative 

(ACR). Once the application and any 

supporting documentation is reviewed 

and approved, that certifying official 

signs the application and submits it to 

the Airman Certification Branch for 

review, final approval, and record 

retention. Submission of FAA Forms 

8710–1 or 8710–11, as applicable, 

remains the exclusive form and manner 

acceptable to the Administrator to 

submit flight instructor data to identify, 

validate, and track the flight instructor’s 

recent experience period. 

One commenter asked how 

instructors will document recent 

experience. Specifically, the commenter 

asked whether recent experience would 

be documented in the flight instructor’s 

personal records such as their pilot 

logbook or retention of a FIRC 

graduation certificate. 

The FAA maintains that the use of 

FAA Forms 8710–1 and 8710–11 is 

necessary. These forms allow the FAA 

to track flight instructors who are 

eligible to exercise the privileges of their 

flight instructor certificates and allow 

the FAA to validate that flight 

instructors meet the recent experience 

requirements. This information will be 

accessible online via the Airmen 

Certificate Information website, 

enabling verification of recent 

experience by flight instructors, their 

clients, and other interested parties. 

Two commenters, LeTourneau 

University and SSF, requested 

clarification on who will sign the Form 

8710 validating recent experience. SSF 

also asked if another flight instructor 

would be considered qualified to 

approve the form, similar to a flight 

instructor signing an application for a 

student pilot certificate. 

The FAA reiterates that certifying 

officials, such as an FAA ASI, DPE, or 

ACR, will continue to review and sign 

Form 8710–1 or 8710–11 to validate a 

flight instructor’s recent experience. The 

FAA finds these personnel are properly 

trained and authorized to review a flight 

instructor’s recent experience and sign 

Form 8710–1 or 8710–11. Unlike the 

role of flight instructors in verifying 

student pilot certificate applications, 

which primarily involves confirming 

identity and basic eligibility, validating 

recent experience for flight instructors 

requires a greater responsibility and 

procedural knowledge than reviewing 

an application for a student pilot 

certificate. 

AOPA asked if flight instructors who 

use the FAA WINGS pilot proficiency 

program to establish recent experience 

in accordance with § 61.197(b)(2)(v) will 

need to submit FAA Form 8710–1 or 

8710–11, as applicable, or whether 

WINGS would automate the process. 

Additionally, they asked if flight 

instructors would have to validate 

recent experience by submitting Form 

8710–1 or 8710–11 after every 

qualifying activity. 

The FAA notes that the WINGS pilot 

proficiency program will not 

automatically submit recent experience 

documentation for participating 

instructors. Instructors must submit 

FAA Form 8710–1 or 8710–11 to a 

certifying official upon satisfactorily 

completing all § 61.197(b)(2)(v) 

requirements including conducting at 

least 15 activities recognized under the 

FAA-sponsored pilot proficiency 

program to at least 5 pilots. 

Three commenters opposed the 

requirement to submit an 8710–1 or 

8710–11 to document recent experience 

in accordance with § 61.197(b)(2) 

because they believed a Notice of 

Disapproval could be issued to flight 

instructors who submitted an 

application to validate recent 

experience. These commenters 

expressed concerns about the perceived 

consequences of a flight instructor 

providing training after the time of 

application and before receiving the 

Notice of Disapproval. 

In the NPRM for this rule, the FAA 

stated that if a flight instructor 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 application and issue a 

Letter of Disapproval. The FAA 

determined that the NPRM did not 

clearly describe the actions FAA would 

take if an instructor does not validate 

recent experience requirements. 

Additionally, the FAA notes that it 

inadvertently used the term Letter of 

Disapproval but intended to state Notice 

of Disapproval. 

To clarify this process, if a flight 

instructor chooses to meet recent 

experience requirements by completing 

a practical test in accordance with 

§ 61.197(b)(1) and the evaluator 

determines the instructor did not meet 

the required standards for required 

task(s) for that test, the evaluator would 

issue FAA Form 8060–5, Notice of 

Disapproval, to that flight instructor. 

The flight instructor would then have 60 

days to successfully pass the remainder 

of the practical test in accordance with 

§ 61.43(f). 

Furthermore, a flight instructor 

documenting recent experience for any 

option under § 61.197(b)(2) not 

involving a practical test would not 

receive a Notice of Disapproval. Instead, 

if the flight instructor did not meet one 

of the eligibility requirements, the 

certifying official would inform the 

flight instructor of the reasons they are 

ineligible and return the application to 

the instructor. The flight instructor 

could resubmit documentation once 

they fully meet eligibility for their 

chosen recent experience option of 

§ 61.197(b)(2). This notification would 

occur at the time the flight instructor 

first submitted the application to the 

certifying official. 

Finally, if the flight instructor did not 

meet their eligibility to reestablish 

recent experience but is still within 

their previous 24 calendar month recent 

experience period, they could continue 

to provide instruction until the end of 

the recent experience period. After 

correcting the eligibility issue and 

establishing their new recent experience 

period, the instructor could continue 

providing instruction throughout the 

new period. 

Twenty-one commenters opposed the 

requirement to document recent 

experience by submitting an 8710–1 or 

8710–11 application. These commenters 

included national FIRC providers King 

Schools and AceCFI, and one 

designated pilot examiner. These 

commenters believed that this 

requirement did not relieve the 


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18The FAA requires documentation to be 

submitted in accordance with Section 61.197(b). 

The documentation must be submitted in a form 

and manner acceptable to the Administrator, which 

means Form 8710–1 or 8710–11. Therefore, any 

required documentation must be attached to either 

Form 8710–1 or 8710–11, as applicable. 

19drs.faa.gov/browse/excelExternalWindow/

DRSDOCID173242699920230309222925.0001?

modalOpened=true. 

administrative burden to the instructor 

or the FAA as compared to the previous 

renewal requirements. Of these 

commenters, ten additionally opposed 

the requirement because they believed it 

is inconsistent with other forms of pilot 

recent experience. Six commenters 

recommended that recent experience 

should be documented solely in the 

flight instructor’s logbook or by 

retaining their FIRC graduation 

certificate, as applicable, with no 

requirement to submit Form 8710–1 or 

8710–11. 

For the reasons previously stated, the 

FAA has determined that the 

requirement to submit Forms 8710–1 

and 8710–11 must be retained. 

Requiring flight instructors to submit 

these forms allows for validation of 

recent experience and the data collected 

ensures the public can verify the 

instructor’s privileges. Furthermore, 

many other sources, such as 

governmental offices and industry, 

frequently ask the FAA to provide this 

data. 

One commenter recommended that 

FIRC providers interface directly with 

the FAA to transmit a flight instructor’s 

graduation certificate, bypassing the 

requirement for that instructor to 

document recent experience by 

submitting an application. 

The holder of a flight instructor 

certificate bears the responsibility to 

establish recent experience and submit 

documentation in accordance with 

§ 61.197. To help reduce the burden of 

document submission to flight 

instructors, the FAA authorizes FIRCs to 

use an ACR to help process their recent 

experience documentation.18 ACRs 

previously performed this function for 

the renewal of flight instructor 

certificates and will continue to perform 

a comparable role in documenting 

recent experience under the new 

requirements. The FAA declines to 

adopt this recommendation. 

One commenter recommended that 

the FAA Forms 8710–1 and 8710–11 

Aviation Safety Inspector or Technician 

Report blocks should be repurposed to 

allow the certifying official to document 

any recent experience activity type and 

the date the activity was completed. 

The FAA notes that other recent 

experience options would not have a 

single date of completion comparable to 

a FIRC, nor would such a date have a 

meaningful use for other options. Since 

only the completion of a FIRC would 

necessitate data entered in the FIRCspecific blocks, the FAA finds it 

unnecessary to modify Forms 8710–1 

and 8710–11 based on this 

recommendation. 

C. Recent Experience Based on 

Instructional Activity in an FAASponsored Pilot Proficiency Program 

(§ 61.197(b)(2)(v)) 

The NPRM proposed to codify the use 

of the FAA’s WINGS-Pilot Proficiency 

Program as an approved program that 

flight instructors can use to satisfy flight 

instructor certificate renewal 

requirements under § 61.197(b)(2)(v). 

Historically, the WINGS Program is 

accepted as a certificate renewal method 

for flight instructors under FAA policy, 

as outlined in FAA Order 8900.1, 

Volume 5, Chapter 2, Section 11, due to 

its familiarity and emphasis on the 

current flight training standards and 

procedures.19

Rather than codifying the WINGS 

Program by name, the FAA will adopt 

language in § 61.197(b)(2)(v) that allows 

a flight instructor to satisfy recent 

experience by serving as a flight 

instructor in an FAA-sponsored pilot 

proficiency program, provided certain 

requirements are met. The phrase 

‘‘FAA-sponsored pilot proficiency 

program’’ is intended to provide 

flexibility for the incorporation of 

comparable FAA-sponsored programs 

that may be developed in the future. 

Ten commenters, including AOPA, 

the Experimental Aircraft Association 

(EAA), and SAFE, generally supported 

the proposed recent experience option. 

EAA stated that this change is long 

overdue. AOPA expressed support and 

suggested that a future pilot proficiency 

program or an extensive update to the 

WINGS program would improve the 

user experience and further benefit 

program participants. 

As discussed in the NPRM, the FAA’s 

intent is to formalize the use of an FAAsponsored pilot proficiency program as 

a method to establish flight instructor 

recent experience. The FAA appreciates 

the AOPA’s feedback on the WINGS 

user experience. There is currently an 

ongoing effort unrelated to this 

rulemaking to modernize the 

FAASTeam FAASafety.gov website 

thereby improving user experience. 

In the NPRM, the FAA included a 

requirement for a flight instructor to 

provide at least 15 hours of flight 

training under the FAA-sponsored pilot 

proficiency program to at least five 

pilots. In response to comments, the 

FAA acknowledges an error in the 

initial proposal that mistakenly required 

‘‘15 hours’’ of flight training instead of 

‘‘15 activities.’’ The final rule will revise 

the proposed regulatory text in 

§ 61.197(b)(2)(v)(C) from ‘‘Has given at 

least 15 hours of flight training under 

the FAA-sponsored pilot proficiency 

program’’ to ‘‘Has conducted at least 15 

flight activities recognized under the 

FAA-sponsored pilot proficiency 

program, during which the flight 

instructor evaluated at least five 

different pilots and has made the 

necessary endorsements in the logbooks 

of each pilot for each activity.’’ 

Three commenters, including Gleim 

Publications, recommended reducing or 

eliminating the requirement to evaluate 

15 flight activities for at least five pilots. 

They noted that a flight instructor may 

complete more than one level of the 

WINGS Program with the same pilot. 

Two commenters stated that some 

instructors may not have a broad 

enough client base to provide training to 

five different pilots but nevertheless 

provide the same amount of flight 

training to fewer individual pilots. 

The FAA maintains that providing the 

specified flight training to at least five 

different pilots has long been an 

established part of FAA policy and is 

consistent with the recent experience 

option of proposed § 61.197(b)(2)(i), 

which is based on successful 

instructional activity. This requirement 

ensures a flight instructor provides 

flight training to various individuals 

under the WINGS Program. By training 

and evaluating at least five different 

pilots, the flight instructor encounters 

different instructional experiences. 

Although a flight instructor may provide 

more than one WINGS flight activity to 

the same pilot, that instructor would not 

be exercising or improving their ability 

to diversify their teaching techniques. 

For this reason, the FAA finds it 

necessary to retain the requirement as 

proposed. 

Two commenters discussed the use of 

the term ‘‘FAA-sponsored pilot 

proficiency program’’ within proposed 

§ 61.197(b)(2)(v). These commenters 

questioned whether the FAA would 

recognize a flight instructor’s 

participation in an industry 

organization’s pilot proficiency program 

as qualifying toward this recent 

experience option. One commenter 

recommended that the FAA add 

language to the proposed regulation to 

allow acceptance of industry pilot 

proficiency programs. Another 

commenter asked if the FAA intends to 

acknowledge industry programs as 

‘‘equivalent to the current WINGS 


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20Comment from Bruce Williams, Docket No. 

FAA–2023–0825–0090. 

21 § 61.199(a)(1) and (2). 

22 § 61.199(a)(3). Specifically, the military 

instructor pilot must provide a record showing that, 

within the preceding 6 calendar months from the 

date of application for reinstatement, the person 

either (1) passed a U.S. Armed Forces instructor 

pilot or pilot examiner proficiency check or (2) 

completed a U.S. Armed Forces’ instructor pilot or 

pilot examiner training course and received an 

additional aircraft rating qualification as a military 

instructor pilot or pilot examiner that is appropriate 

to the flight instructor rating sought. 23See 14 CFR 61.56. 

system for purposes of establishing 

instructional currency.’’ 20

While industry-sponsored pilot 

proficiency programs are valuable 

resources to pilots and instructors, the 

FAA does not intend to accept a flight 

instructor’s participation in an industry 

program as satisfying this recent 

experience option. The FAA’s 

involvement is a critical component of 

the WINGS Program and would be 

equally critical in any program that may 

be recognized under § 61.197(b)(2)(v) in 

the future. Therefore, the FAA will not 

expand this recent experience option to 

Include industry programs at this time. 

One commenter opposed this recent 

experience option because they believed 

it may not be a viable option for most 

instructors. The commenter stated that 

both the requirement to provide 15 

hours of instruction and the 

requirement for the instructor to 

complete a phase of the WINGS Program 

may be difficult for a flight instructor 

not associated with a flight school or 

without access to an aircraft. Another 

commenter opposed the proposal, 

believing the WINGS Program is overly 

complicated and ineffective and that it 

should not serve as a basis for flight 

instructor recent experience. 

The FAA finds that the WINGS 

Program structure and requirements are 

a valid means of renewing a flight 

instructor certificate. Through this final 

rule, the FAA codifies and retains a 

flight instructor’s WINGS Program 

participation as a recent experience 

option. It is important to note that flight 

instructors are not obligated to 

participate in the WINGS Program 

under this amendment. All other 

previous renewal options are retained as 

recent experience options allowing 

flight instructors to maintain their 

privileges without WINGS Program 

participation if they so choose. 

Furthermore, changes to the WINGS 

Program are beyond the scope or intent 

of this rulemaking. The FAA, along with 

many commenters, finds the WINGS 

Program a valuable recent experience 

options for participating instructors. 

Accordingly, the FAA will retain this 

proposed option. 

D. Reinstatement of Flight Instructor 

Privileges by FIRC (§ 61.199) 

Currently, § 61.199 prescribes the 

requirements for those who wish to 

reinstate their expired flight instructor 

certificates. These include (1) 

satisfactory completion of a flight 

instructor certification practical test as 

per § 61.183 for one of the ratings on the 

expired flight instructor certificate, or 

(2) satisfactory completion of a flight 

instructor certification practical test for 

an additional rating.21 In addition, a 

military instructor pilot may reinstate 

an expired flight instructor certificate by 

meeting certain U.S. Armed Forces 

instructor pilot or pilot examiner 

qualifications.22

This final rule revises the 

requirements for reinstating flight 

instructor privileges due to the removal 

of the expiration date from a flight 

instructor certificate. As discussed in 

the NPRM, this change necessitates 

revising the reinstatement requirements 

set forth by § 61.199, removing 

expiration terminology and replacing it 

with recent experience terminology as 

adopted in § 61.197. This final rule 

retains all former reinstatement options, 

now relocated in § 61.199(a)(2) and (3), 

for flight instructors seeking to reinstate 

their privileges when they have not 

reestablished recent experience prior to 

the last month of their flight instructor 

recent experience period. 

Additionally, this final rule adds a 

new reinstatement option in 

§ 61.199(a)(1). This option creates a 

three-calendar-month reinstatement 

period immediately after lapse of the 

flight instructor’s recent experience 

period during which flight instructors 

can reinstate their privileges by 

completing an FAA-approved FIRC as 

opposed to completing a practical test. 

Flight instructors are not authorized 

to exercise the privileges of their flight 

instructor certificate when their recent 

experience has lapsed. For example, if 

an instructor’s 24-calendar month 

period ended on June 30, 2026, the 

flight instructor’s recent experience 

would lapse on July 1, 2026. The flight 

instructor would have until September 

30, 2026, to complete an FAA-approved 

FIRC and submit an application for 

reinstatement. They are not permitted to 

exercise the privileges of the flight 

instructor certificate during this lapsed 

period. Successful completion of the 

FIRC and timely submission of the 

reinstatement application by September 

30, 2026, will result in the reinstatement 

of their privileges. If reinstatement is 

not achieved by this deadline, the 

instructor must then satisfy the 

requirements of § 61.199(a)(2) or (a)(3) 

based on their circumstances. 

The FAA received 37 comments 

pertaining to reinstatement of flight 

instructor privileges. Fifteen 

commenters supported the proposal, 

including AOPA, EAA, Liberty 

University School of Aeronautics, SSF, 

and LeTourneau University. Ten 

commenters opposed this proposal, 

including national FIRC provider 

AceCFI. Twelve commenters, including 

NAFI, made further suggestions or 

comments without clear support for, or 

opposition to, the proposal. 

Comments Concerning Reinstating 

Flight Instructor Privileges by FIRC 

Within Three Calendar Months or Less 

Fifteen commenters, including AOPA, 

EAA, and SSF, supported the proposal 

to add a three-calendar-month 

reinstatement period. AOPA stated the 

proposal would save time and provide 

incentive to instructors holding 

recently-expired certificates or 

privileges that have lapsed to rejoin the 

flight instruction community. EAA 

emphasized that this relief would aid 

instructors whose certificates 

inadvertently lapse simply because 

there is no longer an expiration date to 

reference on the certificate. 

Comments Concerning the Duration of 

Reinstating Flight Instructor Privileges 

by FIRC 

Some commenters questioned the 

selection of a three-calendar-month 

period for the proposed option to 

reinstate flight instructor privileges by 

completing a FIRC as being arbitrary. 

Three of these commenters asserted that 

the FAA did not provide data 

supporting why this option should be 

limited to a three-month period. They 

also maintained that the FAA did not 

provide data showing that a flight 

instructor’s knowledge and skills do in 

fact decline over time when unused. 

Many commenters recommended 

extensions to six-calendar-months, 24- 

calendar-months, or even allowing 

indefinite reinstatement via FIRC 

completion. Several of these 

commenters stated that an extended 

period would provide additional 

flexibility and further incentive for 

instructors to retain their privileges. 

Additionally, some commenters likened 

an indefinite option to reinstate by FIRC 

to the process of a long-inactive pilot 

becoming current through a flight 

review.23 Three commenters suggested 

extending the option to reinstate by 

FIRC beyond three months when 

exercised in conjunction with an 


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Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 80033 

24See www.easa.europa.eu/community/system/ 

files/2021-08/Safety%20Issue%20Report%20- 

%20%20Skills%20and%20Knowledge%20

Degradation_REV2%20Clean_0.pdf. 

additional requirement to receive flight 

and/or ground training. For instance, 

one commenter recommended logging 

three hours of ground and flight training 

with another flight instructor to refresh 

instructional skills. Another commenter 

addressing this topic recommended 

changing the three-month period to a 

12-month period when the flight 

instructor has provided instruction 

within the past 120 days and then 

require a practical test after 12 months 

of lapsed privileges. The third 

commenter recommended that, in lieu 

of reinstating privileges by completing a 

practical test, the flight instructor 

complete a FIRC at any time, and then 

complete suitable flight training with 

another qualified flight instructor and 

receive an endorsement. 

The FAA does not agree with 

extending this proposed reinstatement 

option beyond three calendar months 

because doing so would compromise 

safety. Furthermore, the FAA notes that 

these commenters did not provide any 

supporting evidence to show that their 

recommendations would provide an 

equivalent level of safety without 

requiring a practical test conducted by 

an impartial examiner after three 

calendar months. 

As discussed in the NPRM, AOPA 

initially recommended a three-month 

period to allow a flight instructor to 

reestablish recent experience by 

completing a FIRC. The FAA also 

considered this option after concluding 

that requiring a flight instructor to take 

a practical test shortly after their flight 

instructor certificate expires or recent 

experience ends imposes undue 

personal and financial burdens on that 

flight instructor. Thus, the FAA 

determined that there is a need for an 

alternative reinstatement option and 

proposed a three-calendar-month 

reinstatement period because flight 

instructor knowledge and skills do not 

necessarily degrade the day after their 

certificate expires or, as adopted by this 

final rule, their recent experience ends. 

The FAA notes that skill degradation 

is a documented phenomenon that has 

long been a source of concern for many 

industries including the aviation 

industry. Industry concerns include 

serious safety issues that arise due to the 

degradation of skills that occur after a 

period of nonuse. Consequently, many 

leading industry organizations have 

conducted studies and published 

reports to understand and mitigate skill 

degradation for industry professionals to 

maintain proficiency. For example, the 

European Union Aviation Safety 

Agency’s (EASA’s) Safety Issue Report 

regarding skill and knowledge 

degradation during the COVID–19 

pandemic explains that skill 

degradation poses serious challenges to 

pilots and flight instructors. In this 

report citing numerous references and 

studies, EASA states, ‘‘Despite the 

initial recovery over the summer of 

2021, flying activities are still not taking 

place at the pace required to keep all 

aviation professionals current. While 

organizations are making the effort to 

ramp up their training activity, they 

have faced a multitude of challenges 

such as the closure of training centers, 

lack of simulators, and lack of available 

instructors and trainers whose 

instructional knowledge may have also 

eroded during this period. Furthermore, 

new or updated operational procedures 

have been developed to cope with the 

changes in operations. With the 

aforementioned training constraints, 

aviation professionals may not be 

effectively trained in the updated 

systems and procedures upon their 

return to work.’’ 24

The FAA chose a three-calendarmonth period because it is a brief 

enough period to reinstate flight 

instructor privileges before any 

significant proficiency degradation 

occurs. This period aligns with other 

similar currency requirements within 

part 61 and reflects an established 

understanding that instructional skills, 

while durable, do require periodic 

confirmation through structured 

training or assessment to ensure safety 

standards are maintained. This 

approach applies a safety standard 

consistent with other three-month pilot 

and flight instructor currency periods 

that have proven effective over time. 

Further, the three-calendar-month 

period to reinstate a flight instructor’s 

privilege by FIRC intends to 

accommodate persons who have 

encountered unforeseen circumstances 

that may have prevented them from 

renewing their certificates before the 

expiration date. A three-calendar-month 

period is sufficient to address various 

situations that might prevent an 

instructor from meeting their recent 

experience requirements. The rationale 

behind this specific timeframe is to 

provide instructors with a reasonable 

window to resolve personal matters, 

emergencies, or minor oversights that 

may have led to the lapse of their recent 

experience. For this reason, the FAA 

maintains that extending the 

reinstatement period by completing a 

FIRC is not appropriate in cases of 

lapses Beyond three calendar months of 

meeting recent experience or certificate 

renewal requirements. 

Comments Concerning Alternative 

Reinstatement Options 

Five commenters recommended 

additional options to reinstate flight 

instructor privileges. Of these five, one 

commenter recommended that any 

§ 61.197 recent experience option 

should qualify an instructor to reinstate 

privileges during the proposed threecalendar-month period following the 

lapse of flight instructor privileges. 

LeTourneau University recommended 

an option to reinstate by receiving one 

hour of ground training, one hour of 

flight training and an endorsement from 

another flight instructor during the 

proposed three-calendar-month period. 

Two commenters recommended 

additional reinstatement options 

without specifying that the options 

should be limited to the proposed threecalendar-month period. One of these 

two recommendations was to allow the 

FIEQTP course to be used as a basis for 

reinstatement. The other 

recommendation was to allow a pilot 

proficiency or competency check, such 

as those required for pilots operating 

under part 121 or 135, to qualify a flight 

instructor for reinstatement. Finally, one 

commenter recommended that check 

pilot observations under § 135.339(a)(2) 

should qualify as a method to reinstate 

flight instructor privileges, equating this 

with the military pilot examiner 

reinstatement process outlined in 

§ 61.199(a)(3)(i). 

Upon review, the FAA has decided to 

retain the reinstatement method of 

completing a practical test conducted by 

the FAA or a designated pilot examiner 

and using an FAA-approved FIRC 

within the first three calendar months 

after a lapse of recent experience. The 

FAA based this decision on the 

recognition that a FIRC is an FAAapproved recurrent training program. 

The FIRC updates flight instructors on 

significant developments and changes 

in general aviation flight training that 

occurred since the instructor’s last 

recent experience period. Additionally, 

a FIRC provides flight instructors with 

the necessary refresher training that 

exposes flight instructors to the latest 

in-flight training techniques, the newest 

technologies, and the latest operational 

safety procedures. FIRCs also emphasize 

the development and improvement of 

the instructor skills necessary to 

effectively convey information to pilotsin-training and build a foundational 

culture of safety within them. 

An approved FIRC is unique among 

the recent experience options in that it 

provides this refresher training, making 


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80034 Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 

25Airman Certification Standards and Practical 

Test Standards for Airmen; Incorporation by 

Reference, Docket No. FAA–2022–1463. 

26Relief for Participants in Operation Enduring 

Freedom 67 FR 30524 (May 6, 2002). 

27Relief for U.S. Military and Civilian Personnel 

Who Are Assigned Outside the United States in 

Support of U.S. Armed Forces Operations final rule; 

request for comments 68 FR 36902 (Jun. 20, 2003). 

28Relief for U.S. Military and Civilian Personnel 

Who Are Assigned Outside the United States in 

Support of U.S. Armed Forces Operations final rule, 

70 FR 37946 (Jun. 30, 2005). 

it suitable for this relieving option. 

Instructors who choose one of the other 

recent experience options do not receive 

this training. Therefore, the FAA 

considers it necessary for an instructor 

who has experienced a brief lapse in 

recent experience of up to three 

calendar months to receive, at a 

minimum, the training provided by an 

approved FIRC. Consequently, in the 

final rule, the FAA has decided not to 

include other methods of recent 

experience to qualify a flight instructor 

certificate for reinstatement during the 

three-month period. 

Furthermore, the FAA finds the 

additional reinstatement options 

recommended by commenters as 

unsuitable. Historically, a flight 

instructor has not held the authority to 

endorse another instructor for renewal 

or reinstatement. The authority to 

reinstate a flight instructor certificate is 

reserved for the FAA or its designees. 

Therefore, the FAA finds that the 

recommendation for a flight instructor 

to have the authority to evaluate and 

provide an endorsement to reinstate 

another flight instructor whose recent 

experience has lapsed would not be 

appropriate. 

Similarly, the FAA finds that an 

FIEQTP would be unsuitable to reinstate 

a flight instructor certificate. The 

FIEQTP is designed to train relatively 

inexperienced flight instructors how to 

teach new flight instructors and is not 

designed to meet the needs of 

reinstatement. Further, a flight 

instructor with lapsed privileges would 

not be the appropriate audience for such 

a course, since it is intended for 

individuals who actively provide 

instruction and have held a flight 

instructor certificate for less than 24 

calendar months. 

The recommendation to allow pilot 

proficiency and competency checks 

completed under part 121, 135, or the 

proficiency check of § 61.58 would also 

be inappropriate to reinstate a flight 

instructor certificate. The FAA notes 

that these checks focus on piloting skills 

rather than instructional abilities, thus 

not adequately assessing a flight 

instructor’s educational competencies. 

Similarly, the recommendation to allow 

check pilot observations to reinstate 

flight instructor privileges would be 

unsuitable. These observations 

conducted under parts 121 and 135 

require assessment of the check pilot’s 

abilities as an evaluator; however, they 

do not assess the check pilot’s 

instructional knowledge and skills. 

Although the FAA has long recognized 

that passing a U.S. Armed Forces 

instructor pilot or pilot examiner 

proficiency check provides the 

necessary standards for reinstating a 

flight instructor’s privilege, the FAA 

does not find observations conducted 

under parts 121 and 135, or the 

proficiency check of § 61.58, acceptable 

options to reinstate flight instructor 

privileges. Consequently, the FAA 

declines to adopt the recommendations 

for additional reinstatement options. 

Comments Concerning General 

Opposition to Any Reinstatement Relief 

Two commenters opposed the 

proposal because they believed 

instructors should be held to higher 

standards and the additional relief 

granted to reinstatement by FIRC is 

contrary to this standard. The FAA 

agrees that instructors should be held to 

a high standard and the FAA believes 

the proposed reinstatement option 

retains such a standard. The FAA finds 

that the limited relief offered by 

completing a FIRC, during the initial 

three-calendar-month period in which 

their privileges have lapsed, does not 

compromise the long-held standard for 

instructional proficiency. Instead, this 

new relief encourages experienced 

instructors to reinstate their privileges 

and remain active in flight instruction if 

circumstances prevent them from reestablishing their recent experience 

prior to the end of their recent 

experience period. As previously noted, 

the FAA has retained the requirement to 

complete a practical test to reinstate 

flight instructor privileges after the 

initial three-calendar-month period, due 

to the need to ensure that instructional 

knowledge and skills have not degraded 

over prolonged periods of inactivity. 

Comments Concerning Opposition To 

Reinstatement by Practical Test 

Five commenters opposed the 

requirement to reinstate a flight 

instructor’s privileges or certificate by 

practical test after the three-calendarmonth period to reinstate privileges by 

completing a FIRC. Of these 

commenters, two recommended 

replacing the flight instructor 

reinstatement practical test with a 

proficiency check, similar to the 

instrument proficiency check specified 

under § 61.57. Another opposing 

commenter stated that requiring a test to 

reinstate flight instructor privileges does 

not align with the other pilot recent 

experience requirements. 

The fundamental role an instructor 

plays in training pilots directly impacts 

aviation safety. The effectiveness of the 

instruction provides the foundation of 

the knowledge and skill of the pilot 

receiving the training. For this reason, 

the FAA finds it necessary to require a 

practical test to reinstate flight 

instructor privileges after the threecalendar-month period allowing 

reinstatement by completing a FIRC. 

Although other forms of pilot recent 

experience do not require the equivalent 

of a reinstatement practical test for those 

who fail to maintain currency, it is the 

critical importance of the instructor role 

in aviation safety that necessitates a 

practical test in the case of an instructor 

who is more than three-calendar-months 

past the end of their last recent 

experience period. 

Comments Concerning a 

Recommendation To Incorporate by 

Reference the Flight Instructor Airman 

Certification Standards for 

Reinstatement 

One commenter recommended 

§ 61.199(a)(2)(i) incorporate by reference 

the proposed Flight Instructor for 

Airplane Category Airman Certification 

Standards reinstatement requirements, 

which were published in an NPRM 

docket for a separate rule.25 The FAA 

notes that the Airman Certification 

Standards or Practical Test Standards 

appropriate for the category rating 

sought would apply to a reinstatement 

practical test, regardless of reference to 

a specific document. 

Comments Concerning the Difference 

Between the Three Calendar Month 

Period for Reinstatement by FIRC to the 

Relief Provided by SFAR No. 100–2 

One commenter opposed the proposal 

because they believed it does not align 

with SFAR No. 100–2, which provides 

relief to certain military service 

personnel that could extend comparable 

relief up to six months after returning 

from overseas deployment. The 

commenter questioned why these 

personnel receive additional relief as 

opposed to the three-calendar-month 

period to reinstate by FIRC. 

The relief provided by SFAR No. 100– 

2 has existed since the FAA issued 

SFAR No. 96 on May 6, 2002.26 Since 

then, the relief was expanded to include 

all personnel serving abroad in support 

of U.S. military operations.27 28 SFAR 

No. 100–2 is effective until further 


khammond on DSKJM1Z7X2PROD with RULES2
Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 80035 

29Relief for U.S. Military and Civilian Personnel 

Who Are Assigned Outside the United States in 

Support of U.S. Armed Forces Operations direct 

final rule, 75 FR 9763 (Mar. 4, 2010). Relief for U.S. 

Military and Civilian Personnel Who Are Assigned 

Outside the United States in Support of U.S. Armed 

Forces Operations confirmation of effective date, 75 

FR 19877 (Apr. 16, 2010). 

notice.29 This relief continues to be 

necessary to avoid penalizing U.S. 

personnel who are unable to meet the 

regulatory time limits of their privileges 

because they served outside the United 

States in support of U.S. Armed Forces 

operations. Consequently, the FAA 

proposed to codify this relief in new 

§ 61.40 without any substantive 

changes. This relief allows a flight 

instructor with an expired certificate, or 

whose recent experience has lapsed, to 

reestablish their flight instructor 

privileges when they satisfy the 

appropriate requirements. 

The initial three-calendar-month 

period allowing reinstatement by FIRC 

is intended to address limited unique 

circumstances that may prevent a flight 

instructor from establishing recent 

experience prior to the end of their 

recent experience period. Conversely, a 

military deployment has longer-term 

impact than addressed by the threemonth period provided by 

§ 61.199(a)(1). The FAA notes that the 

relief provided by § 61.40 and § 61.199 

respond to two distinctly different 

circumstances that necessitate separate 

solutions. As a result, the FAA finds it 

inappropriate to extend the threecalendar-month period to align with the 

relief available to U.S. military and 

civilian personnel assigned outside the 

United States in support of U.S. Armed 

Forces operations. 

Comments Concerning the Relief 

Provided by the Proposed Reinstatement 

Requirements 

One commenter, a national FIRC 

provider, opposed the proposal 

believing that the new requirements will 

only shift dates but result in the same 

consequences after the three-calendarmonth period allowing reinstatement by 

FIRC. The commenter contended that 

this is not a burden reduction to 

instructors. 

The FAA maintains that the threecalendar-month period will provide 

relief in many situations. Examples 

range from minor personal challenges to 

larger issues such as a natural disaster 

that could prevent a flight instructor 

from completing recent experience 

requirements prior to the end of their 

recent experience period. The FAA 

intends this relief to address these 

limited circumstances. As previously 

noted, numerous commenters supported 

the proposal and provided rationale 

which agrees with this intent. In its 

supporting comment, EAA stated that 

this option provides ‘‘a reasonable 

pathway for instructors who have 

inadvertently allowed a lapse in their 

flight instructor recent experience.’’ SSF 

said flight instructors would benefit 

from the additional method of 

reinstatement. 

E. Instructor Qualifications for Training 

Initial Flight Instructor Applicants 

(§ 61.195(h); § 141.11; Part 141, 

Appendix K) 

This final rule revises the 

qualification requirements for flight 

instructors seeking to train initial flight 

instructor applicants by adding two 

additional methods. 

Section 61.195(h) contains the 

qualification requirements for flight 

instructors seeking to instruct initial 

flight instructor applicants. The NPRM 

proposed to restructure § 61.195(h)(2) to 

contain general qualifications for all 

flight instructors providing flight 

training to initial applicants for a flight 

instructor certificate, including flight 

instructors providing training under 

FAA-approved courses. This final rule 

retains these general requirements, 

which include the requirement for the 

flight instructor to meet the eligibility 

requirements of § 61.183 and hold the 

appropriate flight instructor certificate 

and rating. The FAA also proposed to 

require the flight instructor to meet the 

requirements of the part under which 

the flight training was conducted. In 

addition to these general requirements, 

the final rule provides three different 

qualification options. 

The first option retains the existing 

requirements of current 

§ 61.195(h)(2)(iii), (iv) and (v), which 

include the requirements for the flight 

instructor to have held the flight 

instructor certificate for at least 24 

calendar months and to have given at 

least 200 hours of flight training as a 

flight instructor for training in 

preparation for an airplane, rotorcraft, or 

powered-lift rating (or 80 hours of flight 

training if training in preparation for a 

glider rating). This option is retained as 

§ 61.195(h)(2)(i)(A) and (B). 

The second qualification option 

modifies the previous § 61.195(h)(3). 

Previously, § 61.195(h)(3) allowed a 

person to serve as a flight instructor in 

an FAA-approved course for initial 

flight instructor applicants if that person 

has trained and endorsed at least five 

applicants for a practical test, at least 80 

percent of those applicants passed the 

practical test on their first attempt, and 

the flight instructor has given at least 

400 hours of flight training for training 

in an airplane, rotorcraft, or powered-lift 

rating (or 100 hours of flight training for 

training in a glider rating). This final 

rule modifies these requirements in the 

new § 61.195(h)(2)(ii) by removing the 

minimum flight training hour 

requirement and removing the 

requirement for the flight instructor to 

be serving in an FAA-approved course. 

Section 61.195(h)(2)(ii) now requires a 

flight instructor to have trained and 

endorsed, in the preceding 24 calendar 

months, at least five applicants for a 

practical test for a pilot certificate or 

rating, and at least 80 percent of those 

applicants must have passed that test on 

their first attempt. This will allow more 

flight instructors to exercise this 

qualification option as compared to the 

similar option previously available 

under § 61.195(h)(3). 

For the third qualification, this final 

rule adds a new qualification method in 

§ 61.195(h)(2)(iii). This option requires a 

flight instructor to have graduated from 

an FAA-approved flight instructor 

enhanced qualification training program 

(FIEQTP). Additionally, they must have 

given at least 200 hours of flight training 

as a flight instructor for training in 

preparation for an airplane, rotorcraft, or 

powered-lift rating (or 80 hours of flight 

training if in preparation for a glider 

rating) before being eligible to complete 

the FIEQTP. 

The modified § 61.195(h)(2)(ii) and 

the new § 61.195(h)(2)(iii) are intended 

to expand the qualification options to 

instruct initial flight instructor 

applicants to include those serving 

under part 61 as well as those serving 

under an FAA-approved course under 

part 141 or 142. 

Additionally, to allow part 141 pilot 

schools to provide the FIEQTP, the FAA 

proposed to revise § 141.11 by adding 

the training program to the list of 

special preparation courses in 

§ 141.11(b)(2). The FAA also proposed 

to add the new training program to 

appendix K of part 141, which 

prescribes the minimum curriculum for 

the special preparation courses listed in 

§ 141.11. 

Due to the specific nature of each 

provision, the FAA discusses each 

amendment separately. 

Comments Concerning the Qualification 

Option of Holding a Flight Instructor 

Certificate for at Least 24 Calendar 

Months With Minimum Hours of 

Instruction (§ 61.195(h)(2)(i)) 

Currently under § 61.195(h)(2), a 

flight instructor must, in addition to 

other requirements, have held a flight 

instructor certificate for at least 24 

months and have given at least 200 

hours of flight training as a flight 


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30Comment from Lawrence Spinetta, Docket No. 

FAA–2023–0825–0013. 

31 Miscellaneous Amendments 38 FR 3156 (Feb. 

1, 1973). 

32FAA Order 8900.1, Volume 5, Chapter 2, 

Section 13. 

instructor for an airplane, rotorcraft, or 

powered-lift rating (or 80 hours of flight 

training if in preparation for a glider 

instruction rating) to provide flight 

training to an initial flight instructor 

applicant under part 61. The FAA 

proposed to retain this qualification 

method under paragraph (h)(2)(i). The 

FAA received an array of comments 

supporting and opposing the retention 

of this qualification method. 

Two commenters recommended 

lowering the eligibility requirements to 

qualify under this option. One of these 

commenters stated that the 24-calendarmonth requirement presents an 

unnecessary obstacle to training initial 

flight instructor applicants and should 

be removed. Another commenter 

recommended reducing the minimum 

time to qualify to train an initial flight 

instructor in gliders from 80 to 20 hours 

of flight training, stating that the ‘‘80 

hours of glider instruction’’ requirement 

is excessive, given the seasonal nature 

of soaring operations and the short 

duration of pattern tows and aerotows.30

Several commenters expressed the 

opinion that this qualification option 

may not be restrictive enough. Three 

commenters opposed this option due to 

doubts about whether these criteria 

assure sufficient instructional 

experience. Another commenter said 

that flight instructor experience differs 

from pilot experience and noted that 

200 hours of instructional experience 

may not guarantee the flight instructor 

has the necessary qualifications to train 

an initial flight instructor applicant 

effectively. One commenter proposed 

increasing the hours of instructional 

experience from 200 to 500 hours. 

While the FAA considered all the 

commenters’ concerns and 

recommendations, the FAA does not 

agree that retaining this qualification 

requirement as it currently exists is 

either too restrictive or not restrictive 

enough. The FAA notes that over the 

years this existing requirement has 

proven to be an appropriate and 

effective standard. Adopted in a 1973 

final rule, the flight instructor 

requirement has remained unchanged, 

which has allowed 50 years for both the 

FAA and industry to assess its 

effectiveness in achieving the intended 

safety standard.31 Given that proposed 

§ 61.195(h)(2) retains this standard 

established in 1973 and has proven to 

provide a sufficient level of experience, 

the FAA believes that requiring more 

experience would impose an undue 

burden on the flight training industry as 

the FAA does not have data to 

demonstrate such a change would have 

a corresponding increase in safety. 

Conversely, reducing this qualification 

standard could lead to a decrease in the 

level of instructional skills, which in 

turn would diminish safety. As a result, 

the final rule retains the existing 

standard without modification. 

To provide additional relief while 

maintaining the existing standard, the 

FAA addresses the flight training 

industry’s need for qualified instructors 

by introducing two alternative 

qualification methods that allow a flight 

instructor to train an initial flight 

instructor applicant in less than 24 

months or with fewer than 200 hours of 

flight instruction (or 80 hours in the 

case of glider instruction) while 

retaining equivalent instructor 

experience to this existing qualification 

option. 

One commenter proposed that the 

FAA should codify the issuance of gold 

seal flight instructor certificates in the 

regulations and allow only instructors 

with such certificates to be permitted to 

train initial flight instructor applicants. 

The gold seal flight instructor 

certificate, under current practice, is 

issued to instructors who exceed the 

standard regulatory requirements 

required for a flight instructor certificate 

and demonstrate high personal 

qualifications and exemplary records as 

active flight instructors. While this gold 

seal denotes a level of distinction to 

recognize instructors who have high 

personal qualifications and good records 

as active flight instructors, it does not 

confer additional flight instructor 

privileges. 

Currently, the issuance of gold seal 

flight instructor certificates is based on 

FAA policy rather than regulatory 

authority.32 Thus, adopting the 

commenter’s recommendation would 

require additional rulemaking to codify 

gold seal flight instructor certificates 

into regulation. The FAA concludes that 

the commenter’s recommendation 

would reduce the number of flight 

instructors that would be eligible to 

train initial flight instructor applicants. 

There are a relatively small number of 

instructors who qualify or hold a gold 

seal on their flight instructor certificate, 

which would result in an insufficient 

number of available flight instructors 

qualified to provide training to an initial 

flight instructor applicant. For these 

reasons, the FAA will not adopt this 

recommendation. 

Comments Concerning Qualification By 

Successfully Endorsing Applicants for 

Practical Tests (§ 61.195(h)(2)(ii)) 

Under this final rule, the FAA 

provides a modified § 61.195(h)(3) 

qualification option for flight instructors 

who wish to provide training to initial 

flight instructor applicants. As per the 

§ 61.195(h)(2)(ii), a flight instructor may 

qualify to instruct an initial flight 

instructor applicant if that flight 

instructor has trained and endorsed at 

least five applicants for a practical test 

during the preceding 24 calendar 

months, and at least 80 percent of those 

applicants passed that test on their first 

attempt. 

Several commenters, including 

Liberty University and Eastern 

Kentucky University, expressed support 

for this new qualification option. 

Liberty University stated the 

qualification option based on applicants 

endorsed for practical tests is ‘‘very 

encouraging as it rewards excellent 

instruction and student success.’’ 

Eastern Kentucky University said that 

both new options ‘‘provide much 

needed relief for the flight training 

industry.’’ 

AOPA commented that the current 

400-hour requirement for part 141/142 

flight instructors is excessively 

burdensome. They recommended that 

the parts 141 and 142 requirement be 

lowered to 200 hours to align with the 

part 61 requirement. 

In response, the FAA clarifies that 

under the new § 61.195(h)(2)(ii), the 

requirement to provide a specific 

number of flight training hours has been 

removed, addressing AOPA’s concern. 

Furthermore, all qualification options 

available under § 61.195(h) apply 

equally to any instructor, regardless of 

whether the instruction is provided 

within an FAA-approved course. 

Five commenters, including ALPA, 

opposed this qualification option, as 

they perceived this option would lower 

experience requirements, possibly 

resulting in reduced proficiency of 

initial flight instructor applicants. 

In response, the FAA notes that an 

eligible flight instructor is required to 

have a record of demonstrated success 

training applicants under this 

qualification option. When a flight 

instructor recommends an applicant for 

a practical test, the applicant is 

independently evaluated by the FAA or 

designated examiner. This applicant 

assessment provides a performance 

measure that attests to the endorsing 

flight instructor’s experience and 

instructional ability. At the end of each 

practical test, the FAA or examiner 

submits the applicant’s paperwork and 


khammond on DSKJM1Z7X2PROD with RULES2
Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 80037 

33See Legal Interpretation to Crowe-Palm Beach 

Helicopters (August 28, 2015). drs.faa.gov/browse/ 

excelExternalWindow/FAA000000000LEGALINTPR

2015017PDF.0001. 

other relevant documentation to the 

Airmen Certification Branch. Here, it 

undergoes a final review, is officially 

accepted, and retained as part of the 

airman’s FAA record. This process 

results in a reliable method to measure 

the instructor’s competency through the 

rate of applicants who pass on their first 

attempt. For these reasons, the FAA 

finds that the § 61.195(h)(2)(ii) 

qualification option provides an 

equivalent level of experience to the 

existing standard of holding a flight 

instructor certificate for 24 calendar 

months and providing 200 hours of 

flight instruction. 

Six commenters, including AOPA, 

NAFI, and SAFE, expressed concerns 

regarding instructors obtaining 

sufficient experience under the 

proposed option. These commenters 

provided examples such as a flight 

instructor endorsing applicants they 

trained only in the later stages of the 

applicants’ training or flight instructors 

endorsing applicants they trained in an 

accelerated course of training, such as a 

course to add an additional class rating 

to an existing pilot certificate. 

Several commenters expressed 

concern about an instructor qualifying 

under this option with limited 

experience and recommended adding 

additional requirements to address this 

concern. Recommendations included 

increasing the minimum number of 

applicants an instructor must endorse 

for a practical test from five to ten, 

extending the period an instructor must 

have held their flight instructor 

certificate to at least 24 months, 

specifying a minimum number of hours 

of flight training provided, or requiring 

the instructor to complete the entire 

course of training for each applicant 

they endorse. 

In addressing these concerns, the FAA 

notes that the efficacy of a flight 

instructor is not solely dependent on the 

cumulative hours of flight instruction 

provided but is also significantly 

influenced by the quality of instruction 

and the resultant success of their 

students. An essential aspect of an 

instructor’s role is their ability to 

prepare and assess whether the 

applicant is competent. To recommend 

an applicant for a practical test, an 

instructor must assess the applicant’s 

competence in the appropriate 

aeronautical knowledge areas and 

proficiency in the appropriate areas of 

operation. The flight instructor must 

then attest to the adequacy of their 

assessment in their endorsement when 

recommending the applicant for the test. 

The successful evaluation of the 

applicants endorsed by the instructor 

and then validated by the FAA or 

designated examiner further confirms 

the instructor’s record of success in 

training initial applicants. For these 

reasons, the FAA finds that this 

qualification option provides an 

equivalent level of experience to the 

existing standard of holding a flight 

instructor certificate for 24 calendar 

months and providing 200 hours of 

flight instruction. 

One commenter expressed concern 

regarding their understanding of the 

§ 61.195(h)(2)(ii) qualification option, 

specifically regarding the requirement 

for flight instructors to demonstrate 

their experience ‘‘during the preceding 

24 calendar months.’’ The commenter 

interpreted this as a perpetually ongoing 

requirement and expressed concern that 

this would pose a burden to flight 

instructors. 

The FAA agrees that if an instructor 

utilizes this qualification option, they 

must meet the required experience 

within the 24 calendar months 

preceding the training or endorsement 

they wish to provide to an initial flight 

instructor applicant. However, this 

requirement is not intended to be an 

ongoing mandate to requalify. Once that 

instructor meets an alternate 

qualification method, they would no 

longer need to meet the activity level 

required by § 61.195(h)(2)(ii) within the 

preceding 24 calendar months to 

continue to train initial flight instructor 

applicants. 

For instance, an instructor who has 

held their flight instructor certificate for 

at least 24 calendar months and has 

given 200 hours of flight instruction (or 

80 hours in the case of glider) is then 

qualified to train an initial flight 

instructor under § 61.195(h)(2)(i). In this 

example, the activity level required 

under § 61.195(h)(2)(ii) would no longer 

apply. For this reason, the FAA does not 

anticipate the § 61.195(h)(2)(ii) option to 

qualify to train an initial flight 

instructor to be prohibitive to the flight 

instructor community. 

Four commenters including the 

University of North Dakota, EmbryRiddle Aeronautical University, and 

Western Michigan University, sought 

clarification on whether flight 

instructors who instruct in an approved 

part 141 training course for which the 

pilot school holds examining authority 

could utilize the qualification option 

under § 61.195(h)(2)(ii). Specifically, 

they recommended clarifying whether 

the end-of-course test in a course with 

examining authority is considered a 

practical test. 

The FAA has established that an endof-course test under part 141 

administered by a school with 

examining authority is a practical test 

and may be considered for the purposes 

of § 61.195(h)(2)(ii).33 Therefore, a flight 

instructor in part 141 courses with 

examining authority may qualify to train 

an initial flight instructor applicant in 

accordance with § 61.195(h)(2)(ii). 

Comments Concerning Qualification 

Based on an FAA-Approved FIEQTP 

(§ 61.195(h)(2)(iii) and (h)(3)) 

The third qualification option, 

§ 61.195(h)(2)(iii), provides another 

alternative to the 24 calendar month 

experience requirement. This 

qualification option permits a flight 

instructor to qualify to instruct initial 

flight instructor applicants if the flight 

instructor has given at least 200 hours 

of flight training (or 80 hours of flight 

training if in preparation for a glider 

rating) and has graduated from an FAAapproved FIEQTP conducted under part 

141 or 142. This training program must 

satisfy the requirements in 

§ 61.195(h)(3) and is intended to 

develop a flight instructor’s ability to 

instruct initial flight instructor 

applicants. 

ALPA expressed concerns regarding 

the FIEQTP, questioning whether the 

program provides equivalent experience 

to the current requirements. 

In addressing ALPA’s concern, the 

FAA notes that the FIEQTP replaces the 

requirement to hold a flight instructor 

certificate for 24 months. Instructors are 

still required to have provided 200 

hours of flight training (or 80 hours of 

flight training if in preparation for a 

glider rating). These hour requirements 

have long been the standard flight 

instructor experience to train initial 

flight instructor applicants and have 

proven effective. Therefore, before 

taking the FIEQTP, the new flight 

instructor will acquire hands-on 

experience as a flight instructor in the 

aircraft. This experience, combined with 

the knowledge and skills acquired from 

completing the FIEQTP would prepare 

and qualify the flight instructor to 

instruct initial flight instructor 

applicants. 

Embry-Riddle Aeronautical 

University and Liberty University 

commented on the required FIEQTP 

training content, expressing similar 

opinions that the course appears to be 

flight instructor remedial training. One 

commenter also presented a series of 

questions about the FIEQTP training 

content and testing standards. This 

commenter specifically questioned how 

much of the FIEQTP would repeat 


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34For additional guidance and recommendations 

on the preparation and approval of an FIEQTP 

required under § 61.195(h)(3), refer to Advisory 

Circular 61–145. 

testing and training the flight instructor 

received during their own commercial 

pilot and initial flight instructor 

training. Another commenter 

recommended that the FIEQTP should 

be limited to only ground instruction 

and available as an online course to 

increase access to flight instructors. 

The FAA notes that FIEQTP course 

content, as detailed in § 61.195(h)(3), is 

not intended to be remedial or simply 

a review of what attendees have 

previously learned. The FIEQTP 

provides specialized training to develop 

the attendee’s ability to instruct initial 

flight instructor applicants. 

Furthermore, the recommendation to 

eliminate the flight training component 

from the course has been carefully 

evaluated. The FAA believes that 

excluding this aspect would undermine 

the training program’s effectiveness, as 

flight training is integral in preparing 

attendees to competently provide 

practical flight training to initial flight 

instructor applicants. Therefore, the 

FAA will not limit this course to only 

ground instruction.34

One commenter recommended that 

the required content of the FIEQTP 

found in § 61.195(h)(3) should be less 

prescriptive and instead focus on course 

outcomes. 

The FAA notes that specific ground 

subjects and flight tasks outlined in 

§ 61.195(h)(3)(i) and (ii) are required to 

be included in the FIEQTP to ensure 

clarity and consistency across various 

course providers. The FAA finds that 

defining the specific content aids both 

the course providers and the approving 

FAA officials in determining what is 

required for the FIEQTP. 

Embry-Riddle Aeronautical 

University recommended a reduction in 

the required hours for both ground and 

flight training in the FIEQTP because 

the flight instructors enrolled in the 

course would have received similar 

training during their own initial flight 

instructor training. Additionally, 

another commenter raised concerns 

about the time commitment required in 

the FIEQTP, suggesting it could limit 

the availability of qualified instructors. 

As discussed in the NPRM, the FAA 

expects that the requirement of 25 hours 

of ground training and 10 hours of flight 

training would promote standardization 

among the training programs. The FAA 

believes that reducing minimum course 

hours would potentially compromise 

the depth and breadth of the knowledge, 

skills, and abilities that attendees are 

expected to acquire. Therefore, the FAA 

declines to adopt these 

recommendations. 

AOPA and Liberty University 

questioned the anticipated utilization of 

completing an FIEQTP to qualify to 

train an initial flight instructor due to 

the associated cost and complexity of 

qualifying to train a limited segment of 

the pilot population. Another 

commenter expressed similar sentiment 

about limited access to the course for 

instructors outside the part 141 or 142 

certificate holder offering the course and 

suggested allowing other entities to seek 

FIEQTP course approval under part 61. 

The FAA acknowledges these 

concerns but emphasizes that the 

FIEQTP is designed as an option to 

qualify to train initial flight instructor 

applicants. While the FIEQTP might 

appeal to the course provider’s own 

instructors, it is important to note that 

the FIEQTP is open to all flight 

instructors, irrespective of their current 

affiliations. The intent is to provide an 

additional qualification option to all 

flight instructors to maximize flexibility. 

The decision to limit approval to parts 

141 and 142 certificate holders is based 

on the specific capabilities inherent to 

these entities, which are equipped with 

the necessary organizational structure, 

systems, and qualified management 

personnel. Furthermore, by limiting 

approval to parts 141 and 142 certificate 

holders, the FAA has oversight and can 

mandate changes to ensure that 

programs meet the intended course 

objectives. 

The University of North Dakota and 

Embry-Riddle Aeronautical University 

recommended that a part 141 chief 

instructor should be authorized to 

designate who may teach in an 

approved FIEQTP to provide a greater 

pool of instructors for these courses. 

Another commenter similarly expressed 

concerns about the difficulty in finding 

qualified instructors for the FIEQTP due 

to the significant time commitment 

involved in the course. 

Given the specialized nature of the 

FIEQTP, the FAA finds that a higher 

level of expertise and experience is 

required. The designated groups—chief 

and assistant chief instructors at part 

141 pilot schools and program managers 

and assistant training center program 

managers at part 142 training centers— 

are deemed to have the requisite 

experience and expertise for this 

advanced training role. Additionally, 

those instructors who fulfill the 

qualifications of a chief instructor or 

assistant chief instructor pursuant to 

§ 141.36(d) are also eligible to instruct 

the FIEQTP. The FAA recognizes that 

these instructors possess the necessary 

qualifications to be a chief instructor or 

assistant chief instructor, even if they do 

not currently hold these titles due to 

reasons unrelated to their instructional 

abilities. 

Considering the specialized nature of 

the FIEQTP, the FAA does not support 

the recommendation to allow a part 141 

chief instructor to designate personnel 

with potentially less experience or 

knowledge than those specified in the 

approved groups to teach within an 

FIEQTP. Therefore, the FAA declines to 

reduce FIEQTP instructor requirements. 

Use of Flight Simulation Training 

Devices in FIEQTPs 

Appendix K of part 141 contains 

limitations for special preparation 

courses utilizing full flight simulators 

(FFSs) and flight training devices (FTDs) 

that are more restrictive than 

§ 61.195(h)(3)(iv) and (v) permit. 

Specifically, paragraph 4.(b) of 

appendix K provides that an FFS may 

only be credited for a maximum of 10% 

of the total flight training hour 

requirements of the approved course, 

and paragraph 4.(c) provides that an 

FTD may be credited for a maximum of 

5 percent of the total flight training hour 

requirements of the approved course. 

However, § 61.195(h)(3)(iv) and (v) 

proposed to permit all flight training 

hours to occur in an FFS or FTD and 5 

hours of flight training to occur in an 

advanced aviation training device. 

Therefore, to eliminate the conflict 

between the provisions, the NPRM 

proposed to revise paragraph 4.(b) to 

except the FIEQTP from the FFS credit 

limitations of appendix K, and proposed 

to revise paragraph 4.(c) to except the 

FIEQTP from the FTD credit limitations 

of appendix K. The FAA did not receive 

any comments specific to the use of 

flight simulation training devices in 

FIEQTPs and is therefore adopting these 

provisions. 

Additionally, part 141 prescribes the 

circumstances under which aviation 

training devices (ATDs) may be utilized 

for flight training credit. However, 

appendix K of part 141 only 

contemplates the use of an FFS and an 

FTD for special preparation flight 

training, not an ATD. Because an 

advanced aviation training device 

(AATD) may be used in flight training 

for FIEQTPs, the FAA proposed to 

revise appendix K, paragraph 4. 

Specifically, paragraph 4.(a) would 

include a provision that only permits an 

FIEQTP to utilize AATDs in accordance 

with appendix K, paragraph 14, and 

§ 61.195(h)(3)(v). The FAA did not 

receive any comments regarding these 

provisions and is adopting them as 

final. 


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35 14 CFR 61.56(c). 

F. Conforming Amendments (§§ 61.2, 

61.56, 61.425, 61.427) 

The FAA proposed to make 

conforming amendments to §§ 61.2, 

61.56, 61.425, 61.427, and Special 

Federal Aviation Regulation (SFAR) No. 

100–2 to ensure consistency with the 

FAA’s proposal to amend §§ 61.197 and 

61.199. 

Section 61.2(b) requires persons to 

meet the appropriate airman and 

medical recent experience requirements 

to exercise privileges of an airman 

certificate, rating, endorsement, 

authorization, or foreign pilot license. 

Currently, § 61.2(b) refers to the recent 

experience requirements of part 61 as 

‘‘recency’’ requirements rather than 

‘‘recent experience’’ requirements. The 

FAA recognizes that it uses the terms 

‘‘recency,’’ ‘‘recent flight experience,’’ 

and ‘‘recent experience’’ requirements 

interchangeably in the regulations. 

However, the terms ‘‘recent flight 

experience’’ and ‘‘recent experience’’ 

are used more frequently than 

‘‘recency.’’ The FAA proposed to revise 

§ 61.2(b) to use the term ‘‘recent 

experience’’ requirements to create 

consistency within part 61 and conform 

to the proposed changes to § 61.197. The 

FAA did not receive any comments on 

this proposed revision and is adopting 

it as final. 

Section 61.56 prescribes the 

requirements for a flight review, which 

must consist of a minimum of 1 hour of 

flight training and 1 hour of ground 

training. Except as specified in 

§ 61.56(d), (e), and (g), a person may not 

act as pilot-in-command (PIC) of an 

aircraft unless that person has 

accomplished a flight review in the 24 

calendar months preceding the month 

in which the pilot acts as PIC.35

Therefore, § 61.56(d) contains certain 

exceptions to the flight review 

requirements. Under § 61.56(d)(2), a 

person need not accomplish a flight 

review if the person has passed a 

practical test conducted by an examiner 

for one of the following: the issuance of 

a flight instructor certificate, an 

additional rating on a flight instructor 

certificate, renewal of a flight instructor 

certificate, or the reinstatement of a 

flight instructor certificate. Therefore, 

the FAA proposed to revise the language 

of § 61.56(d)(2) to conform to the 

changes proposed in §§ 61.197 and 

61.199. The FAA did not receive any 

comments on this conforming 

amendment and is adopting it as final. 

Additionally, the FAA proposed a 

minor editorial change to § 61.56(e) to 

remove the word ‘‘award’’ in the 

description of the FAA-sponsored pilot 

proficiency program. The FAA did not 

receive any comments on this editorial 

change and is adopting it as final. 

Section 61.56(f) provides an exception 

to the ground training portion of the 

flight review requirement. Under 

current § 61.56(f), a person who has 

satisfactorily renewed their flight 

instructor certificate under current 

§ 61.197 is not required to accomplish 

the one hour of ground training required 

for a flight review. Because proposed 

§ 61.197 would contain recent 

experience requirements for a flight 

instructor certificate rather than renewal 

requirements, the FAA proposed to 

make conforming amendments to 

§ 61.56(f). Therefore, § 61.56(f) would 

except a flight instructor from the 

ground training requirements of a flight 

review if that flight instructor has met 

the recent experience requirements for a 

flight instructor certificate under 

§ 61.197. Further, the FAA proposed to 

revise § 61.56(f) to except any persons 

who reinstate their flight instructor 

privileges from the ground training 

portion of the flight review by 

completing an approved FIRC within 

the three-calendar-month reinstatement 

period proposed in § 61.199(a)(1). The 

FAA did not receive comments on these 

provisions and is adopting them as 

proposed. 

Currently, §§ 61.425 and 61.427 

prescribe renewal and reinstatement 

requirements for persons who hold a 

flight instructor certificate with a sport 

pilot rating. Under § 61.425, a person 

who holds a flight instructor certificate 

with a sport pilot rating may renew that 

certificate in accordance with § 61.197. 

Section 61.427 allows a person to 

exchange their expired flight instructor 

certificate with a sport pilot rating for a 

new certificate with a sport pilot rating 

and any rating on that certificate by 

passing a practical test as prescribed in 

§ 61.405(b) or § 61.183(h) for one of the 

ratings listed on their expired flight 

instructor certificate. 

To ensure consistency with the 

proposed amendments to §§ 61.197 and 

61.199, the FAA proposed to make 

conforming amendments to §§ 61.425 

and 61.427. The FAA proposed to 

bifurcate § 61.425 into two paragraphs. 

Section 61.425(a) would govern flight 

instructor certificates issued without 

expiration dates. Section 61.425(b) 

would govern flight instructor 

certificates issued prior to the final rule 

becoming effective, which would 

contain expiration dates. Thus, 

§ 61.425(a) would require a person who 

holds a flight instructor certificate with 

a sport pilot rating issued after the final 

rule’s effective date to establish recent 

experience in accordance with § 61.197 

(i.e., within the 24 preceding months, 

the person has satisfied one of the 

recent experience requirements in 

§ 61.197(b)). For persons who hold 

unexpired flight instructor certificates 

with a sport pilot rating issued before 

the final rule becomes effective, 

§ 61.425(b) would allow those persons 

to renew their certificate by establishing 

recent experience in accordance with 

§ 61.197 prior to the expiration month 

listed on their flight instructor 

certificate. 

In addition, the FAA proposed to 

revise § 61.427 to align with the 

proposed amendments to § 61.199. 

Therefore, proposed § 61.427 would 

address how to reinstate flight instructor 

privileges if a person fails to establish 

recent experience for a flight instructor 

certificate with a sport pilot rating. 

Consistent with proposed § 61.199, a 

person who holds a flight instructor 

certificate with a sport pilot rating must 

reinstate their flight instructor privileges 

by successfully completing an approved 

FIRC if three calendar months or less 

have passed since the last month of 

their recent experience period. Section 

61.427(a) would contain this proposed 

requirement. If more than three calendar 

months have passed since the last 

month of the flight instructor’s recent 

experience period, the flight instructor 

with a sport pilot rating would be 

required to pass a practical test in 

accordance with proposed § 61.427(b) to 

reinstate their flight instructor 

privileges. 

The FAA did not receive comments 

specific to these provisions as they 

relate to sport pilots, as differentiated 

from other pilots. Therefore, the FAA is 

adopting these provisions as discussed 

previously. 

G. SFAR No. 100–2 Codification Under 

§ 61.40 and Associated Amendments 

Currently, SFAR No. 100–2 provides 

relief to U.S. military and civilian 

personnel who have served outside the 

United States in support of U.S. Armed 

Forces operations during some time 

beginning on or after September 11, 

2001. SFAR No. 100–2 allows these 

persons to present an expired flight 

instructor certificate to show eligibility 

for renewal of a flight instructor 

certificate under § 61.197; an expired 

written test report to show eligibility to 

take a practical test under parts 61, 63, 

and 65; and an expired inspection 

authorization to show eligibility for 

renewal under § 65.93. To exercise the 

relief provided by SFAR No. 100–2, the 

person must renew their flight 

instructor certificate or inspection 

authorization, as appropriate, or pass 


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36The final rule for SFAR No. 96 stated, ‘‘if an 

inspection authorization expires while a person is 

assigned to Operation Enduring Freedom . . .’’ (67 

FR at 30525). 

37The final rule for SFAR No. 100 stated, 

‘‘[b]ecause of the expected duration of these 

assignments, the FAA determined that the flight 

instructor certificates, inspection authorizations, 

and airman written test reports held by some U.S. 

military and civilian personnel may expire before 

they return to the United States.’’ (68 FR at 36903). 

38Additionally, the FAA proposed to revise 

§ 63.35(c) to remove a gender reference and clarify 

that the 24 month period is calendar months. 

39The FAA also proposed to revise § 65.71(a)(4) 

to remove a gender reference and clarify that the 24 

month period is calendar months. 

40See Legal Interpretation to James McHenry 

(May 21, 2015). drs.faa.gov/browse/excelExternal

Window/FAA000000000LEGALINTPR2015044

PDF.0001. 

the appropriate practical test within six 

calendar months after returning to the 

United States. The FAA proposed to 

codify the general contents of SFAR No. 

100–2 as new § 61.40. 

The initial intent of SFAR No. 100–2, 

as documented in the preambles of 

earlier SFARs such as SFAR No. 96 36

and SFAR No. 100,37 was to alleviate 

the challenges faced by military and 

civilian personnel whose certificates 

expired while they were deployed. 

However, ambiguities in the language of 

SFAR No. 100–2 have led to confusion 

about the exact timing of when certain 

documents must have expired to qualify 

for this relief. As written in SFAR No. 

100–2 currently, and proposed in 

§ 61.40(b)(2), the regulation broadly 

requires that the documents expire 

‘‘some time’’ between September 11, 

2001, and no later than 6 calendar 

months after returning to the U.S., 

which the FAA finds could introduce 

confusion as to whether the expiration 

must have occurred during the person’s 

service outside the U.S or immediately 

following the person’s return. 

In response to these ambiguities, the 

FAA revises § 61.40(b)(2) in this final 

rule to clarify the expiration period of 

the relevant certificates as (1) while the 

person serves in an operation as set 

forth in § 61.40(b)(1), or (2) six calendar 

months after returning to the United 

States. 

One commenter responded with an 

opposing comment. The commenter 

opposed the underlying inspection 

authorization renewal options of 

§ 65.93(a)(1) and (2). The commenter 

recommended that these options should 

be combined to allow an inspection 

authorization to be renewed based on a 

combination of annual inspections and 

major repairs or alterations. However, 

this commenter’s recommendation 

exceeds the scope of this rulemaking, 

which focuses solely on relocating and 

codifying the existing content of SFAR 

No. 100–2 into the regulations. This 

rulemaking did not contemplate nor 

intend changing the underlying 

inspection authorization renewal 

requirements. Therefore, the FAA 

declines to adopt this recommendation. 

The FAA proposed to revise certain 

sections of parts 61, 63, and 65 to enable 

persons to exercise the relief provided 

by proposed § 61.40. More specifically, 

the FAA proposed to revise § 61.39, 

which contains the prerequisites for 

practical tests under part 61, by adding 

new § 61.39(e) to allow applicants for an 

airman certificate or rating under part 

61 to take a practical test with an 

expired knowledge test if that applicant 

meets the requirements of proposed 

§ 61.40. The FAA also proposed to 

include exception language referencing 

new § 61.39(e) in § 61.39(a), (b), and (c), 

which would implement the relief 

provided by proposed § 61.40. With 

respect to part 63, the FAA proposed to 

revise §§ 63.35(d) and 63.53 to allow 

applicants for flight engineer certificates 

or ratings and applicants for flight 

navigator certificates to take their 

practical tests under part 63 with 

expired written test reports in 

accordance with § 61.40.38 With respect 

to part 65, the FAA proposed to revise 

§§ 65.55 and 65.71 39 to allow applicants 

for aircraft dispatcher certificates and 

mechanic certificates or ratings to take 

their practical tests under part 65 with 

expired written test reports in 

accordance with § 61.40. Section 

65.55(b) and (c) was proposed to add an 

exception to allow eligible persons to 

take a practical test for an aircraft 

dispatcher certificate under part 65 with 

an expired written test report in 

accordance with § 61.40. Section 

65.75(d) was proposed to except eligible 

persons from the requirement that a 

certificated mechanic must pass the 

required tests within a period of 24 

months. These revisions would ensure 

the relief currently provided by SFAR 

No. 100–2 would remain unchanged 

under the FAA’s proposal to relocate 

and codify the relief in the regulations. 

Lastly, in § 61.40(a)(6) the FAA 

proposed to allow persons to renew an 

expired inspection authorization under 

§ 65.93. Because § 65.93 does not 

currently allow for this relief, the FAA 

proposed to add new paragraph (d) and 

to include exception language in current 

§ 65.93(a) to expressly allow an eligible 

person to renew an expired inspection 

authorization under part 65 in 

accordance with § 61.40. 

The FAA did not receive comments 

directly related to these provisions and 

is adopting them as final. 

H. Miscellaneous Comments 

LeTourneau University requested 

changes to Advisory Circular (AC) 61– 

65, particularly to reassess the sample 

endorsements for student solo (A.4, A.6, 

and A.7), which they believed do not 

align with the interpretation letter from 

the FAA’s Office of the Chief Counsel to 

James McHenry dated May 21, 2015.40

This legal interpretation stated that 

§ 61.87(n) and (p) apply only to the solo 

logbook endorsement. 

The FAA understands the 

University’s comment to mean that they 

believe the sample endorsements in AC 

61–65 do not align with the McHenry 

(2015) legal interpretation. However, the 

University did not provide a detailed 

explanation for this belief. 

The FAA notes that the McHenry 

(2015) legal interpretation characterizes 

daytime solo endorsements as one type 

of endorsement, while the nighttime 

solo endorsement is characterized as a 

separate endorsement. The FAA 

believes that retaining each solo 

endorsement recommended in AC 61– 

65 ensures that the flight instructor who 

provided the required training certifies 

that the training was indeed provided. 

As a result, the FAA declines to change 

these suggested endorsements. 

One commenter asked if the standards 

to receive and retain a gold seal flight 

instructor certificate would change 

because of this rulemaking. Another 

commenter recommended that the FAA 

revise the eligibility criteria for gold seal 

flight instructor certificates and take 

into consideration more than just 

recommendations for a practical test to 

determine eligibility. 

As discussed in section IV.D. of this 

preamble, gold seal flight instructor 

certificates are not issued under 

regulatory authority, but instead issued 

under FAA policy. The FAA did not 

contemplate changing this policy as part 

of this rulemaking. Adopting the 

commenter’s recommendation to change 

the existing standard would require 

additional rulemaking to codify gold 

seal flight instructor certificates. 

Additionally, the FAA policy for the 

issuance of a gold seal flight instructor 

certificate relies on a flight instructor’s 

recommendations for practical tests 

because these recommendations result 

in a demonstrated record of success 

training pilots, as assessed by the FAA 

or designated examiner. This 

assessment provides a performance 

measure that attests to the endorsing 

flight instructor’s proficiency and 

instructional ability. Eligibility criteria 

not relying on this performance measure 

would not ensure the flight instructor 

meets the intended standards. For these 


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41Comment from Timothy Heron, Docket No. 

FAA–2023–0825–0133. 

42See FAA Order 8900.1, Volume 6, Chapter 1, 

Section 5. drs.faa.gov/browse/excelExternal

Window/DRSDOCID1843706828202305311

44311.0001. 

reasons, the FAA will not adopt this 

recommendation and will retain 

existing gold seal flight instructor 

certificate policy. 

One commenter suggested that the 

FAA address the personal liability 

associated with flight instruction, which 

the commenter believes has resulted in 

flight instructors quitting active flight 

instruction. 

Although the FAA understands this 

commenter’s concern and interest in 

retaining experienced flight instructors, 

addressing personal liability is not 

within the scope of this rulemaking nor 

the FAA’s authority and role. The FAA 

regulates U.S. civil aviation to promote 

safety in air commerce. 

One commenter recommended that 

the FAA increase the requirements for a 

flight instructor to qualify to endorse a 

student pilot for solo flight. 

Currently, a flight instructor with a 

valid flight instructor certificate may 

endorse a student pilot for solo flight 

when the student has met the 

aeronautical knowledge and pre-solo 

flight training requirements of § 61.87. 

The FAA did not intend to change these 

limitations or establish new 

requirements for a flight instructor to 

endorse a student pilot for solo flight as 

part of this rulemaking. The FAA 

believes that the requirements of 

§ 61.87, along with the eligibility 

requirements to obtain a flight instructor 

certificate, establish an acceptable 

standard. The FAA will not adopt this 

recommendation. 

One commenter proposed three 

recommendations to improve a flight 

instructor’s ‘‘ability to teach safety and 

safely.’’ 41 The suggestions included 

restructuring the Aviation Instructor’s 

Handbook, conducting regular reviews 

of flight instructors offering flight 

instruction under part 61, and 

addressing the issue of designated pilot 

examiners who conduct a high number 

of practical tests per year at ‘‘$900 to 

$1,000 per ride-with what appears to be 

profit-driven motive.’’ 

The FAA appreciates the feedback on 

the Aviation Instructor’s Handbook. 

However, this document is not within 

the purview of this rulemaking and will 

not be restructured as a result of it. The 

commenter’s recommendation to 

‘‘review’’ flight instructors providing 

instruction under part 61 seems to 

comment on the FAA’s flight instructor 

surveillance policy.42 The existing part 

61 flight instruction oversight policy 

cannot be revised through this 

rulemaking. Finally, this rulemaking did 

not intend changes to designated pilot 

examiner authorization or oversight, nor 

can it address the commenter’s specific 

concerns about the cost of practical tests 

conducted by DPEs. Current FAA policy 

addresses DPE activities and oversight. 

Therefore, the FAA will not adopt these 

recommendations as they fall outside 

the scope of this rulemaking. 

One commenter requested that the 

FAA reevaluate DPE eligibility 

standards to address a shortage of DPEs. 

As discussed, this rulemaking did not 

intend to change or address DPE policy, 

and this policy is beyond the scope of 

this rulemaking. 

Two commenters, including SAFE 

and one individual, recommended the 

FAA update the WINGS Program’s 

FAASafety.gov website. The FAA 

appreciates this feedback, however 

changes to the FAASafety.gov website is 

beyond the scope of this rulemaking. 

One commenter recommended 

expansion of ground instructor 

privileges by allowing them to act as a 

certifying official on student pilot 

certificate applications. Additionally, 

the commenter recommended allowing 

ground instructors to verify identity and 

citizenship requirements for pilots 

seeking flight training in accordance 

with Transportation Security 

Administration (TSA) requirements. 

Section 61.85(b) establishes the 

certifying officials who may accept an 

application for a student pilot 

certificate. Notably, ground instructors 

are not included. The FAA did not 

intend to change ground instructor 

privileges as part of this rulemaking and 

believes the existing certifying officials 

are sufficient to process student pilot 

certificate applications. The FAA 

declines to adopt this recommendation. 

This commenter’s additional 

recommendation to allow ground 

instructors to verify citizenship to meet 

TSA requirements found in 49 U.S.C. 

part 1552 is beyond the scope of this 

rulemaking. 

One commenter recommended that 

flight instructor eligibility requirements 

should not require a practical test to 

obtain a flight instructor certificate. The 

commenter recommended that only the 

currently required knowledge tests 

should be required for the issuance of a 

flight instructor certificate. The 

commenter believed that this 

recommendation would address the 

perceived difficulty and expense of 

flight instructor certification. 

The FAA notes that the flight 

instructor practical test ensures that the 

instructor applicant has the 

instructional knowledge and skill to 

meet standards. Removing the practical 

test requirement would have an adverse 

impact on safety because it would no 

longer ensure a flight instructor meets 

the flight instructor instructional 

knowledge and skill standards. 

Additionally, this rulemaking did not 

contemplate a change to flight instructor 

eligibility requirements, currently found 

in § 61.183, or § 61.405 for flight 

instructors with a sport pilot rating. The 

FAA will not adopt this 

recommendation. 

One commenter supported proposed 

rulemaking but recommended ‘‘a 24- 

month recovery opportunity for 

instructors who were sidelined due to 

COVID-related issues.’’ The FAA finds 

that the proposed reinstatement options 

would allow flight instructors impacted 

by COVID–19 to reinstate their flight 

instructor privileges by practical test. 

The FAA declines to adopt the 

recommendation for additional relief. 

In their comment, AOPA asked how 

the proposed rule would affect part 141 

chief and assistant chief instructors, 

who are currently required to complete 

a FIRC every 12 months. The FAA notes 

that this rulemaking does not change 

part 141 chief flight instructor or 

assistant chief flight instructor 

requirements. In accordance with 

§ 141.79(c), those instructors would 

need to complete an approved syllabus 

of training consisting of ground or flight 

training, or both, or an approved FIRC 

every 12 months. These instructors may 

also choose to reestablish recent 

experience based on completion of this 

approved FIRC. 


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43See www.federalregister.gov/documents/2011/ 

01/21/2011-1385/improving-regulation-andregulatory-review. 

44 49 U.S.C. Subtitle VII, Subpart i of part A, 

Section 40113, Administrative, and Subpart iii, 

Section 44701, General Requirements; Section 

44702, Issuance of Certificates; Section 44703, 

Airman Certificates; Section 44704, Type 

Certificates, Production Certificates, Airworthiness 

Certificates, and Design and Production 

Organization Certificates; Section 44705, Air Carrier 

Operating Certificates; and Section 44707, 

Examination and Rating of Air Agencies. 

One commenter believed that an 

industry group received an opportunity 

to comment on the draft proposal prior 

to publication of the NPRM and other 

industry groups were excluded. The 

FAA affirms that no industry groups or 

individuals were given advance 

opportunity to review and comment on 

this rulemaking prior to publication of 

the NPRM. 

One individual recommended 

extending the comment period. In this 

case, the commenter recommended that 

the FAA withdraw this proposal, 

convene a working group, and consult 

with the flight training industry to get 

their input; or at least extend the 

comment period until after July 2023. 

To respond to this commenter’s request 

to extend the comment period, the FAA 

reopened the comment period for an 

additional thirty (30) days, from 

November 1, 2023, through December 1, 

2023. Under the guidance of Executive 

Order 13563,43 which provides that the 

public must be afforded a meaningful 

opportunity to comment with a 

comment period that should generally 

be at least 60 days, the FAA finds that 

the additional 30 day comment period 

provided sufficient opportunity for the 

public to comment (i.e., a total period of 

60 days). Additionally, the FAA found 

that the APA process of notice and 

comment was sufficient to gather 

relevant perspectives and continue the 

rulemaking process. Therefore, the FAA 

will neither convene an Aviation 

Rulemaking Committee nor a working 

group as part of this rulemaking action. 

V. Severability 

As discussed in section II. Of this 

preamble, Congress authorized the FAA 

by statute to promote safe flight of civil 

aircraft in air commerce by prescribing, 

among other things, regulations and 

minimum standards for practices, 

methods, and procedures the 

Administrator finds necessary for safety 

in air commerce.44 Consistent with that 

mandate, the FAA promulgates the 

regulations described herein to remove 

the flight instructor certificate 

expiration date and to substitute the 

renewal requirement with a recency 

requirement. However, the FAA 

recognizes that certain provisions of this 

final rule make additional unrelated 

changes to the regulations. Therefore, 

the FAA finds that the various 

provisions of this final rule are 

severable and able to operate 

functionally if severed from each other. 

In the event a court were to invalidate 

one or more of this final rule’s unique 

provisions, the remaining provisions 

should stand, thus allowing the FAA to 

proceed with revising flight instructor 

certificates within its Congressionally 

authorized role of promoting safe flight 

of civil aircraft in air commerce. 

VI. Regulatory Notices and Analyses 

Federal agencies consider impacts of 

regulatory actions under a variety of 

executive orders and other 

requirements. First, Executive Order 

12866, Executive Order 13563, and 

Executive Order 14094 (‘‘Modernizing 

Regulatory Review’’), direct that each 

Federal agency shall propose or adopt a 

regulation only upon a reasoned 

determination that the benefits of the 

intended regulation justify the costs. 

Second, the Regulatory Flexibility Act 

of 1980 (Pub. L. 96–354) requires 

agencies to analyze the economic 

impact of regulatory changes on small 

entities. Third, the Trade Agreements 

Act (Pub. L. 96–39) prohibits agencies 

from setting standards that create 

unnecessary obstacles to the foreign 

commerce of the United States. Fourth, 

the Unfunded Mandates Reform Act of 

1995 (Pub. L. 104–4) requires agencies 

to prepare a written assessment of the 

costs, benefits, and other effects of 

proposed or final rules that include a 

Federal mandate that may result in the 

expenditure by State, local, and Tribal 

governments, in the aggregate, or by the 

private sector, of $100,000,000 or more 

(adjusted annually for inflation) in any 

one year. The current threshold after 

adjustment for inflation is $183,000,000, 

using the most current (2023) Implicit 

Price Deflator for the Gross Domestic 

Product. This portion of the preamble 

summarizes the FAA’s analysis of the 

economic impacts of this rule. 

In conducting these analyses, the FAA 

has determined that this rule: will result 

in benefits that justify costs; is not a 

significant regulatory action as defined 

under section 3(f)(1) of Executive Order 

12866; will not have a significant 

economic impact on a substantial 

number of small entities; will not create 

unnecessary obstacles to the foreign 

commerce of the United States; and will 

not impose an unfunded mandate on 

State, local, or Tribal governments, or 

on the private sector. 

A. Regulatory Evaluation 

The FAA will amend part 61 of title 

14 of the Code of Federal Regulations by 

(1) removing the expiration date on the 

flight instructor certificate; (2) allowing 

flight instructors whose recent 

experience has lapsed by no more than 

three calendar months to reinstate their 

flight instructor privileges by taking a 

FIRC; (3) identifying an FAA-sponsored 

pilot proficiency program (e.g., WINGS– 

FAA Pilot Proficiency Program) as an 

additional method for a flight instructor 

to meet recent experience requirements; 

(4) revising the qualifications for flight 

instructors seeking to train initial flight 

instructor applicants under 14 CFR 

61.195(h)(2); and (5) codifying SFAR 

No. 100–2, with clarifying revisions. 

The FAA estimates this rule to result 

in $5.6 million, discounted over five 

years, in cost savings to FAA and 

industry, which includes removing the 

expiration date on the flight instructor 

certificate as well as allowing flight 

instructors whose recent experience has 

lapsed by no more than three calendar 

months to reinstate flight instructor 

privileges by taking a FIRC. These cost 

savings are driven primarily by the cost 

savings to industry of removing the 

expiration date on the flight instructor 

certificate. 

This final rule includes two changes 

not originally proposed. The first 

change corrects § 61.197(b)(2)(v) by 

replacing a requirement for ‘‘15 hours’’ 

to ‘‘15 activities.’’ The second change 

corrects § 61.51(h)(2)(ii) by aligning 

pilot logbook training time descriptions 

with the removal of the flight instructor 

certificate expiration date. The FAA 

notes that there is no cost impact 

associated with either of these changes. 

None of the comments received 

resulted in any changes to the FAA 

assessment of cost savings or costs. For 

instance, one commenter claimed that 

the FIEQTP may not be a popular 

program with parts 141 and 142 flight 

training centers or CFIs due to the cost 

and complexity associated with it. 

According to the commenter, the FAA 

estimated that it would cost a school an 

average of over $5,000 in the first year 

to establish the course. In subsequent 

years, it would then cost slightly over 

$2,000 per year in course revisions, 

approvals, and record keeping expenses. 

Although the FAA estimated costs for 

this new training program, the FAA also 

pointed out that participation in 

FIEQTP will not be mandatory; instead, 

it will be one option to become qualified 

to instruct initial flight instructor 

applicants. Three commenters 

contended that the only cost savings 

from removing the expiration date from 


khammond on DSKJM1Z7X2PROD with RULES2
Federal Register / Vol. 89, No. 190 / Tuesday, October 1, 2024 / Rules and Regulations 80043 

45Source: FAA Airman Certification Branch. 46 Ibid. 47This includes FAA Form 8710–1, Airman 

Certificate and/or Rating Application and Form 

FAA 8710–11, Airman Certificate and/or Rating 

application—Sport Pilot. 

48The NAICS code is the standard used by 

Federal statistical agencies in classifying business 

establishments for the purpose of collecting, 

analyzing, and publishing statistical data related to 

the U.S. business economy. 

49U.S. Bureau of Labor Statistics, NAICS 

481200—Nonscheduled Air Transportation 

www.bls.gov/oes/2022/may/naics4_481200.htm. 

50Percent of total compensation = 29.7%. Source: 

Bureau of Labor Statistics News Release. Employer 

Costs for Employee Compensation—December 

2020. www.bls.gov/news.release/archives/ecec_

03182021.htm. 

51Source: www.reginfo.gov/public/do/ 

PRAViewICR?ref_nbr=201809-2120-009. 

52Source: www.reginfo.gov/public/do/ 

PRAViewICR?ref_nbr=201809-2120-009. 

flight instructor certificates is to the 

FAA in the production and mailing of 

new certificates. In the detailed analysis 

in the following section, the FAA points 

out that it also estimated cost savings to 

industry of approximately $2.7 million 

present value at a 2 percent discount 

rate for this provision. Therefore, there 

have been no changes to this analysis as 

it was proposed except for updates with 

more recent data on the number of 

initial flight instructor certificates, the 

number of flight instructor certificate 

renewals, the number of pilot schools 

and the number of training centers. 

Additionally, this final rule has been 

updated from the NPRM to convert to 

2024 dollars from 2022 dollars and to 

add a present value discounted at two 

percent for cost savings and costs. 

1. Removing the Expiration Date on the 

Flight Instructor Certificate 

Currently, a flight instructor 

certificate expires 24 calendar months 

from the month in which the FAA 

issued, renewed, or reinstated that 

certificate. The FAA will remove the 

expiration date from the flight instructor 

certificate, which will eliminate the 

need to renew that certificate prior to its 

expiration date by passing a practical 

test or by submitting a completed and 

signed application with the FAA and 

satisfactorily completing one of the 

currently enumerated renewal 

requirements. These current renewal 

requirements will become recent 

experience requirements. Consequently, 

the FAA will no longer need to create 

new physical flight instructor 

certificates upon each applicant’s recent 

experience cycle after that person 

receives their permanent certificate 

without an expiration date. 

To estimate the cost savings 

associated with removing the expiration 

date from flight instructor certificates, 

the FAA begins with estimating the 

baseline number of certificates and 

associated costs avoided. The FAA 

estimates that from 2013 to 2023 the 

number of initial flight instructor 

certificates grew from 2,348 to 9,280 45

(i.e., the average annual growth rate 

from 2013 to 2023 was 14.73 percent). 

Using this 14.73 percent annual growth 

rate, the FAA forecasts the initial flight 

instructor certificates over the next 

years. Similarly, the FAA estimates that 

from 2013 to 2023, the number of flight 

instructor certificate renewals grew from 

41,467 to 61,782 46 (i.e., the average 

annual growth rate from 2013 to 2023 

was 4.07 percent). Using this 4.07 

percent annual growth rate, the FAA 

forecasts the flight instructor certificate 

renewals over the next years. 

The FAA determined the cost of 

issuing the physical flight instructor 

certificates by estimating the mean labor 

cost for the applicants that complete 

and submit FAA Form 8710 

applications.47 The FAA finds that the 

variety of people with various pay levels 

that work on issuing flight instructor 

certificates are classified using the May 

2022 North American Industry 

Classification System under NAICS 

code 48 481200, ‘‘Nonscheduled Air 

transportation.’’ 49 Therefore, the FAA 

assumes that the mean hourly wage of 

$47.13 of all occupations is 

representative of pilots and 

representative occupations. The FAA 

then applies the appropriate multipliers 

for overhead (this includes health 

benefits, vacation, sick time, etc.). More 

specifically, the FAA increases the base 

hourly rate by 42.25 percent, which is 

based on the percent of total 

compensation for transportation 

employees,50 resulting in a fully 

burdened wage rate of approximately 

$67.04 per hour. FAA estimates the time 

to produce each physical flight 

instructor certificate is 6 minutes, or 0.1 

hours.51

Using the preceding information, the 

FAA estimates that during the first five 

years, the cost savings to industry will 

be approximately $2.7 million present 

value at a 2 percent discount rate, with 

annualized savings of $573 thousand. 

The results are presented in Table 1. 

TABLE 1—TOTAL INDUSTRY COST SAVINGS

Year 

Initial 

flight 

instructor 

(forecast) 

Flight 

instructor 

renewals 

(forecast) 

Average 

wage per 

hour 

Time to 

process 

each flight 

instructor 

(in hours) 

Cost 

savings 

Present 

value at 

2% 3% 7% 

1 ........................................................................ 10,647 64,295 $67.04 0.1 $502,411 $502,411 $502,411 $502,411 

2 ........................................................................ 12,216 66,910 67.04 0.1 530,461 520,060 515,010 495,758 

3 ........................................................................ 14,015 69,632 67.04 0.1 560,769 538,994 528,579 489,798 

4 ........................................................................ 16,080 72,465 67.04 0.1 593,606 559,368 543,233 484,559 

5 ........................................................................ 18,449 75,412 67.04 0.1 629,244 581,324 559,075 480,047 

Total ........................................................... 71,407 348,714 .................... .................... .................... 2,702,157 2,648,308 2,452,573 

Notes: (i) initial certificates forecast based on historic rate of 14.73 percent per year; (ii) Flight instructor renewal forecast based on historic rate of 4.07 percent per 

year; and (iii) estimates may not total due to rounding. 

Using the initial flight instructor 

certificates forecast and the flight 

instructor certificate renewals forecast, 

the FAA estimates the costs savings to 

the Federal Government. The FAA 

determined the cost of issuing physical 

airman certificates by estimating the 

mean labor cost for clerks. The FAA 

estimates the salaries for the clerks 

based on the 2024 General Schedule 

Locality Pay Tables using the Rest of the 

United States locality pay multiplier. 

The FAA uses 36.25 percent to calculate 

the overhead benefits multiplier. The 

total salary, including overhead, is 

$92,597 ($44.52 per hour). The time to 

produce each flight instructor certificate 

is estimated at 0.1 hours.52 Using this 

information, the FAA estimates that 

during the first five years, the FAA cost 

savings will be approximately $1.8 

million present value at a 2 percent 

discount rate, with annualized savings 

of $381 thousand. The results are 

presented in Table 2. 


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53Based on the research conducted by the Airmen 

Certification and Training Branch of Flight 

Standards Service, this cost can range from about 

$500 to $1,000. The FAA estimates $750/hour 

(average of $500 and $1,000) for the cost of a 

designated pilot examiner to conduct the test. 54One of the most popular aircraft, the Cessna 

172 airplane, (four seat/single four-cylinder engine) 

rents from about $120/hour to $220/hour wet (with 

fuel and oil), depending on its age and equipment. 

The FAA estimates $170/hour (average of $120 and 

$220) for the rental cost. Additional cost may 

include the flight instructor’s fee (typically $30–$60 

per hour). The FAA estimates $45/hour (average of 

$30 and $60) for the flight instructor’s fee. 

55Flight Instructors that reinstated their flight 

instructor certificate within the first three-month 

period from the expiration of their certificate: 2019 

= 92, 2020 = 79, 2021 = 80, 2022 = 96, and 2023 

= 70. Source: Federal Aviation Administration 

Airmen Certification Branch (AFB–720). Average of 

92, 79, 80, 96, and 70 = 85. Received data on March 

19, 2024. For the NPRM, the FAA only had data 

points from 2019 to 2021, which were used to 

calculate the average. 

56 Difference in cost between taking a practical 

test and taking a FIRC = $2,805 ¥ $149.50 = 

$2,655.5 Average cost of taking a flight instructor 

reinstatement practical test: $2,805. Assumptions 

for the practical test: Airplane, not Helicopter; 

Airplane rental for training in preparation for the 

practical test = 6 hours × $170 = $1,020; Prep time 

for test with flight instructor = 6 hours × $45 = $270 

prep time; Airplane rental to and from test = 2 × 

$170 = $340; Airplane rental for the flight test (2– 

3 hours = 2.5 hours flight test × $170 = $425; 

Designated examiner to conduct the test average = 

$750. 

Note: This example reflects the most common 

practical reinstatement by practical test. However, 

each individual has different circumstances. 

Average cost for taking a FIRC = $149.50 (average 

of $0 and $299). 

TABLE 2—TOTAL FAA COST SAVINGS

Year 

Initial 

flight 

instructor 

(forecast) 

Flight 

instructor 

renewals 

(forecast) 

Average 

wage per 

hour 

Time to 

process 

each flight 

instructor 

(in hours) 

Cost 

savings 

Present 

value at 

2% 3% 7% 

1 ........................................................................ 10,647 64,295 $44.52 0.1 $333,642 $333,642 $333,642 $333,642 

2 ........................................................................ 12,216 66,910 44.52 0.1 352,269 345,362 342,009 329,223 

3 ........................................................................ 14,015 69,632 44.52 0.1 372,396 357,936 351,019 325,265 

4 ........................................................................ 16,080 72,465 44.52 0.1 394,202 371,466 360,751 321,787 

5 ........................................................................ 18,449 75,412 44.52 0.1 417,869 386,047 371,271 318,790 

Total ........................................................... 71,407 348,714 .................... .................... .................... 1,794,453 1,758,692 1,628,707 

Notes: (i) initial certificates forecast based on historic rate of 14.73 percent per year; (ii) Flight instructor renewal forecast based on historic rate of 4.07 percent per 

year; and (iii) estimates may not total due to rounding. 

2. Flight Instructor Refresher Course 

Allowing flight instructors whose 

recent experience has lapsed by no more 

than three calendar months to reinstate 

flight instructor privileges by taking a 

FIRC will result in cost savings for flight 

instructors. Under the previous rule, 

flight instructor applicants typically 

would incur the costs of taking a 

practical test. This expenditure 

generally included the applicant’s time 

for the test-which consisted of oral 

testing and a flight test (about 2–3 hours 

flight portion), the cost of a designated 

examiner to conduct the test,53 and the 

aircraft operational or rental costs 54

incurred while taking the test. The 

estimates provided here are based on a 

comprehensive review of (1) numerous 

flight schools throughout the United 

States, (2) the price designated pilot 

examiners charge across the country, 

and (3) the cost of taking FAA approved 

FIRCs conducted by current providers. 

This review was conducted by FAA 

personnel familiar with the training 

requirements and associated costs. The 

research conducted during this review 

indicates that a practical test to reinstate 

a flight instructor certificate could cost 

anywhere from about $800 to thousands 

of dollars when a rental aircraft is used 

for the practical test. Conversely, the 

cost of an online FIRC may be provided 

free of charge or cost as much as $299 

for a live classroom FIRC. By averaging 

these options ($0 and $299), the FAA 

assumes a cost of $149.50 per hour for 

the cost of taking a FIRC. 

To estimate the cost savings 

associated with taking a FIRC instead of 

a practical test, the FAA forecasts that 

on average 85 flight instructors will 

reinstate their flight instructor 

certificate within the first three-month 

period from the expiration of their 

certificate.55 The FAA determined the 

difference in cost between taking a 

practical test and taking a FIRC as 

$2,656.56 Therefore, the FAA estimates 

that during the first five years, the cost 

savings will be approximately $1.1 

million present value at a 2 percent 

discount rate, with annualized savings 

of $231 thousand. The results are 

presented in Table 3. 

TABLE 3—TOTAL FLIGHT INSTRUCTOR REFRESHER COURSE COST SAVINGS

Year 

Flight instructors that will 

reinstate their flight 

instructor certificate 

within first 3 month 

period from the 

expiration of their 

certificate (forecast) 

Cost of 

practical 

test minus 

cost of 

FIRC 

Cost 

savings 

Present value at 

2% 3% 7% 

1 .................................................................................................... 85 $2,656 $226,822 $226,822 $226,822 $226,822 

2 .................................................................................................... 85 $2,656 $226,822 $222,375 $220,216 $211,984 

3 .................................................................................................... 85 2,656 226,822 218,015 213,802 198,115 

4 .................................................................................................... 85 2,656 226,822 213,740 207,575 185,155 

5 .................................................................................................... 85 2,656 226,822 209,549 201,529 173,042 

Total ....................................................................................... 427 .................... .................... 1,090,501 1,069,944 995,118 

Note: (i) estimates may not total due to rounding. 

The FAA estimates that during the 

first five years, the combined cost 

savings (industry + FAA) will be 

approximately $5.6 million present 

value at a 2 percent discount rate, with 

an annualized savings of $1.2 million. 

The results are presented in Table 4. 


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57Section 61.195(h)(2)(iii) currently requires a 

flight instructor seeking to instruct an initial flight 

instructor applicant to have held their flight 

instructor certificate for at least 24 months. 

58U.S. Civil Airmen Statistics | Federal Aviation 

Administration (faa.gov). 

TABLE 4—TOTAL COST SAVINGS FOR THE INDUSTRY AND THE FAA 

Cost savings 

Present value at Annualized 

2% 3% 7% 2% 

Industry ............................................................................................................ $3,792,659 $3,718,253 $3,447,692 $804,644 

FAA .................................................................................................................. 1,794,453 1,758,692 1,628,707 380,708 

Total .......................................................................................................... 5,587,111 5,476,944 5,076,398 1,185,353 

Note: (i) estimates may not total due to rounding. 

3. FAA-Sponsored Pilot Proficiency 

Programs 

This new paragraph will add the 

FAA-sponsored pilot proficiency 

programs as a method to establish recent 

experience under § 61.197(a) and will 

codify the FAA’s current practice of 

permitting flight instructors to use the 

WINGS Program to satisfy § 61.197. 

Codifying FAA-sponsored pilot 

proficiency programs to allow flight 

instructors an additional method to 

establish flight instructor recent 

experience is essentially an enabling 

provision for flight instructors, which 

was triggered by the need to provide a 

regulatory basis for a policy that has 

allowed flight instructors to renew their 

certificate by means of the WINGS 

program. 

4. Revising Flight Instructor 

Qualifications Under 14 CFR 

61.195(h)(2) 

Currently, prior to instructing initial 

flight instructor applicants, a flight 

instructor must have held their flight 

instructor certificate for at least 24 

calendar months and have given a 

requisite number of hours of flight 

training. This Final Rule will create two 

additional options for a flight instructor 

to qualify to instruct initial flight 

instructor applicants. Under the first 

new option, flight instructors would 

have the option to qualify by training 

and endorsing at least five applicants for 

a practical test for a pilot certificate or 

rating, with at least 80 percent of those 

applicants passing the test on their first 

attempt. As another option, flight 

instructors may complete an FAAapproved FIEQTP and give a requisite 

number of hours of flight training. These 

two new qualification options will 

allow flight instructors to be eligible to 

instruct initial flight instructor 

applicants sooner than 24 calendar 

months. This provision will provide 

additional flexibility to instructors and, 

thus, the FAA finds it will provide a 

small cost savings.57

B. Regulatory Flexibility Act 

The Regulatory Flexibility Act (RFA) 

of 1980, (5 U.S.C. 601–612), as amended 

by the Small Business Regulatory 

Enforcement Fairness Act of 1996 (Pub. 

L. 104–121) and the Small Business Jobs 

Act of 2010 (Pub. L. 111–240), requires 

Federal agencies to consider the effects 

of the regulatory action on small 

business and other small entities and to 

minimize any significant economic 

impact. The term ‘‘small entities’’ 

comprises small businesses and not-forprofit organizations that are 

independently owned and operated and 

are not dominant in their fields, and 

governmental jurisdictions with 

populations of less than 50,000. 

Most of the parties affected by this 

rule will be small businesses such as 

flight instructors, aeronautical 

universities, FAA designated pilot 

examiners, parts 61 and 141 flight 

schools, and part 142 training centers. 

There were 131,577 58 flight instructors 

alone in 2023. Therefore, this final rule 

will affect a substantial number of small 

entities. However, it does not impose 

costs net of cost savings. This Final Rule 

is expected to provide cost savings to 

industry of about $4 million present 

value at 2 percent during the first 5 

years. If an agency determines that a 

rulemaking will not result in a 

significant economic impact on a 

substantial number of small entities, the 

head of the agency may so certify under 

section 605(b) of the RFA. Therefore, as 

provided in section 605(b) and based on 

the foregoing, the head of FAA certifies 

that this rulemaking will not result in a 

significant economic impact on a 

substantial number of small entities. 

C. International Trade Impact 

Assessment 

The Trade Agreements Act of 1979 

(Pub. L. 96–39), as amended by the 

Uruguay Round Agreements Act (Pub. 

L. 103–465), prohibits Federal agencies 

from establishing standards or engaging 

in related activities that create 

unnecessary obstacles to the foreign 

commerce of the United States. 

Pursuant to these Acts, the 

establishment of standards is not 

considered an unnecessary obstacle to 

the foreign commerce of the United 

States, so long as the standard has a 

legitimate domestic objective, such as 

the protection of safety, and does not 

operate in a manner that excludes 

imports that meet this objective. The 

statute also requires consideration of 

international standards and, where 

appropriate, that they be the basis for 

U.S. standards. 

The FAA has assessed the potential 

effect of this final rule and determined 

that the rule will have only a domestic 

impact and, therefore, no effect on 

international trade. 

D. Unfunded Mandates Assessment 

The Unfunded Mandates Reform Act 

of 1995 (2 U.S.C. 1531–1538) governs 

the issuance of Federal regulations that 

require unfunded mandates. An 

unfunded mandate is a regulation that 

requires a State, local, or Tribal 

government or the private sector to 

incur direct costs without the Federal 

government having first provided the 

funds to pay those costs. The FAA 

determined that the final rule will not 

result in the expenditure of 

$183,000,000 or more by State, local, or 

Tribal governments, in the aggregate, or 

the private sector, in any one year. 


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59The FAA obtained a list of active part 141 pilot 

schools and a list of active part 142 training centers 

from its internal record system, WebOPSS, on 

March 18, 2024. 

60The code was determined to be the appropriate 

code as the NAICS code for training and 

development specialists’ states ‘‘flight instructors 

are included with ‘‘Aircraft Pilots and Flight 

Engineers’’ (53–2010)’’. Source: Technical and 

Trade Schools—May 2022 OEWS Industry-Specific 

Occupational Employment and Wage Estimates 

(bls.gov). 

61Percent of total compensation = 29.5%. Source: 

Bureau of Labor Statistics News Release. Employer 

Costs for Employee Compensation—March 2022. 

Employer Costs for Employee Compensation 

Archived News Releases: U.S. Bureau of Labor 

Statistics (bls.gov). 

62The number of initial flight instructors are from 

U.S. Civil Airmen Statistics | Federal Aviation 

Administration (faa.gov); March 18, 2024. 

63 11,337 × 25% = 2,834 students. 

64Source: FAA Airman Certification Branch. 

E. Paperwork Reduction Act 

The Paperwork Reduction Act of 1995 

(44 U.S.C. 3507(d)) requires that the 

FAA consider the impact of paperwork 

and other information collection 

burdens imposed on the public. The 

FAA has determined that there will be 

a new requirement for information 

collection associated with this rule for 

the FIEQTP. The FAA notes that the 

Office of Management and Budget 

assigned OMB control number 2120– 

0816 to this information collection. As 

required by the Paperwork Reduction 

Act, the FAA has submitted this 

information collection request to OMB 

for its review. The new information 

collection would be entitled Flight 

Instructor Enhanced Qualification 

Training Program (FIEQTP): Preparation 

and Approval. The following discussion 

provides details on this information 

collection requirement. 

Summary: Flight instructors seeking 

to provide flight training to initial flight 

instructor applicants may complete an 

approved Flight Instructor Enhanced 

Qualification Training Program 

(FIEQTP) that will develop the flight 

instructor’s instructional ability. 

Participation in this new training 

program is not mandatory; instead, it is 

one option to become qualified to 

instruct initial flight instructor 

applicants. Any part 141 pilot school or 

part 142 training center wishing to offer 

the new training program is required to 

submit the curriculum to the FAA for 

approval. 

Use: The information collected for the 

FIEQTP will ensure flight instructors 

seeking to provide flight training to 

initial flight instructor applicants are 

adequately trained in the knowledge 

and skills of the intricacies of providing 

flight training to initial flight instructor 

applicants. The requirement to submit 

the FIEQTP curriculum to the FAA for 

approval ensures that the FIEQTP meets 

the regulatory requirements of such 

program and provides greater oversight 

of the training programs to ensure 

consistency of both course and 

instructional quality among pilot 

schools and training centers. 

Burden Estimate: As of May 2024, 

FAA records show 539 active part 141 

pilot schools and 50 active part 142 

training centers.59 The FAA estimates 

that 25 percent of these pilot schools 

and training centers would take 

advantage of the provision in this rule 

that would trigger an estimated 147 

responses to this new information 

collection for § 61.195(h)(3). Therefore, 

in the first year, the FAA estimates that 

about 134.75 pilot schools and 12.50 

training centers would submit a training 

program for approval for a total of 147 

respondents in the first year. Further, 

the FAA estimates that the development 

of each FIEQTP will take approximately 

80 hours and that the task would be 

performed by the pilot school’s or 

training center’s chief flight instructor. 

The Bureau of Labor Statistics estimates 

that the mean annual salary for a chief 

flight instructor is $90,330, from which 

the FAA estimates an average wage of 

$43.43 per hour.60 This wage was 

obtained using the North American 

Industry Classification System (NAICS) 

industry code 611500; occupation code 

53–2010 designate for aircraft pilots and 

flight engineers. This wage estimate was 

derived by dividing $90,330 by 2,080 

hours (assuming a 40-hour work week 

for 52 weeks), which is $43.43 per hour. 

Next, a fringe benefit multiplier 1.42 

was included. This results in an annual 

salary of $128,128 and hourly wage of 

$61.60.61

TABLE 5—INDUSTRY SALARY INCLUDING OVERHEAD

Job category Annual wage Multiplier Total Hourly wage 

Chief Flight Instructor ...................................................................................... 1 $90,330 2 1.42 $128,128 3 $61.60 

Sources: 

1 NAICS Code 611500; occupation code 53–2010. Technical and Trade Schools—May 2022 OEWS Industry-Specific Occupational Employment and Wage Estimates (bls.gov). 2Overhead benefit percent of total compensation = 29.5%. June 2022. https://www.bls.gov/bls/news-release/ecec.htm. 3 Using 2,080 working hours in one year. 

This would result in a first-year 

burden of about 11,780 hours and about 

$725,648 ((134.75 pilot schools +12.50 

training centers) × 80 hours × $61.60) for 

affected pilot schools and training 

centers to prepare and submit new 

training programs. For subsequent years, 

the FAA assumes a growth rate of one 

percent for both pilot schools and 

training centers. The FAA estimates that 

25 percent of those institutions would 

submit FIEQTP to the FAA for revisions, 

resulting in approximately 1.47 new 

respondents and an additional burden 

of about 118 hours and $7,256 in 

subsequent years. The FAA also 

estimates that each year at least 50 

percent of the pilot schools and training 

centers that provide the FIEQTP 

curriculum would require at least one 

revision to address any updates or 

deficiencies identified by the FAA, pilot 

school, or training center. As a result, 

the FAA estimates the total annual 

burden to pilot schools and training 

centers of submissions, including 

growth and revisions, at 4,749 hours 

and $292,553. 

The FAA reviewed the number of 

initial flight instructors certificated in 

the previous three years, which was 

reported as: 2023 (11,337), 2022 (8,364), 

and 2021 (7,759) equaling a total of 

27,460 newly certificated flight 

instructors.62 Using the most recent year 

of these newly certificated flight 

instructors, the FAA estimates 11,337 

student records would be generated in 

the first year. The FAA further assumes 

that 25 percent of the students would 

enroll in a FIEQTP regardless of other 

alternatives. The FAA, therefore, 

estimates that 2,834 students 63 would 

enroll in a FIEQTP in the first year. The 

FAA further estimates that the student 

population growth rate would be 0.6 

percent.64 In addition, the FAA 

estimates each record would require five 

minutes of processing time and that 

recordkeeping functions would be the 

responsibility of the chief flight 


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65Estimated as 50% of the total affected pilot 

schools and training centers per year adjusted for 

growth. 

instructor. This would result in an 

annual recordkeeping burden of 79 

hours and $4,888. 

The annual industry burden and cost 

of this information requirement for plan 

submission and revision and student 

recordkeeping is about 4,829 hours and 

$297,441. 

TABLE 6—INDUSTRY FIEQTP DEVELOPMENT AND REVISION BURDEN AND COSTS

[Information used for estimates] 

Category Element Estimate 

Pilot Schools ...................................... Number of pilot schools ................................................................................. 539 

Portion of pilot schools affected .................................................................... 25% 

Number of pilot schools affected ................................................................... (539 × 0.25 =) 134.75 

Growth rate of pilot schools ........................................................................... 1% 

Training Centers ................................. Number of training centers ............................................................................ 50 

Portion of training centers affected ............................................................... 25% 

Number of training centers affected .............................................................. (50 × 0.25 =) 12.50 

Growth rate of training centers ...................................................................... 1% 

FIEQTP .............................................. Time needed to develop and submit original ................................................ 80 hours 

Time for revisions .......................................................................................... 10 hours 

Percent revisions per year ............................................................................. 50% 65

Wage Rate ......................................... Chief flight instructor ...................................................................................... $61.60 

The FAA estimates the annual burden 

and cost to the Federal Government for 

the review and authorization of the 

FIEQTP would be 2,809 hours and 

$251,924. This burden and cost was 

determined by estimating the time 

required for FAA personnel to review 

FIEQTP curriculums and authorize an 

applicant’s program through the 

issuance of an approval letter. The FAA 

estimates FAA aviation safety inspectors 

(ASIs) would spend 40 hours on each 

review and 10 hours on each revision. 

Additionally, FAA clerks would spend 

30 minutes on issuance of an approval 

letter. The FAA estimates the salaries 

for the ASIs and clerks based on the 

2024 General Schedule Locality Pay 

Tables using the Rest of the United 

States locality pay multiplier. The FAA 

uses 36.25 percent to calculate the 

overhead benefits multiplier. The total 

salary, including overhead, is $188,696 

($90.72 per hour) for ASIs and $92,597 

($44.52 per hour) for clerks. The 

analysis uses the same number of 

responses estimated for industry 

FIEQTP submission and revision to 

estimate the burden and cost to the FAA 

of reviews and approvals. 

TABLE 7—FAA SALARIES INCLUDING OVERHEAD

Job category Aviation safety 

inspector Clerk 

Grade and Step ............................................................................................................................................. GS–14 Step 5 ..... GS–9 Step 5. 

Annual Base Salary ....................................................................................................................................... $118,552 1 ........... $58,176.1

Locality Multiplier ........................................................................................................................................... 1.1682 2 ............... 1.1682.2

Salary Adjusted by Locality Pay ................................................................................................................... $138,492 ............. $67,961. 

Overhead Benefit Multiplier ........................................................................................................................... 1.3625 3 ............... 1.3625.3

Salary including Overhead ............................................................................................................................ $188,696 ............. $92,597. 

Hourly Wage .................................................................................................................................................. $90.72 4 ............... $44.52.4

Sources: 

1 2024 General Schedule Pay. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2024/GS.pdf. 2FAA locality rate for the Rest of the United States. 

3 https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/memoranda/2008/m08-13.pdf. 4 Using 2,080 working hours in one year. 

The combined (industry + FAA) 

annual burden and cost is 7,637 hours 

and $549,365. The following provides 

additional detail of response, burden, 

and cost estimates to industry and the 

FAA (some estimates may not exactly 

total due to rounding). 

TABLE 8—ANNUAL BURDEN AND COSTS FOR THE INDUSTRY AND THE FAA 

Category Total 

responses 

Hours per 

response 

Burden hours 

Reporting Recordkeeping Disclosure Total Cost 

Industry: 61.195(h)(3): 

Development Cost—Pilot Schools ... 45.82 80 3,666 .............................. ........................ 3,666 $225,798 

Development Cost—Training Centers ................................................ 4.25 80 340 .............................. ........................ 340 20,946 

Cost—Revisions ............................... 74.36 10 744 .............................. ........................ 744 45,808 

Industry Recordkeeping Costs ......... 956.12 0.083 ........................ 79 ........................ 79 4,888 


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66See § 141.95. 

67 65 FR 67249 (Nov. 6, 2000). 

68FAA Order No. 1210.20 (Jan. 28, 2004), 

available at www.faa.gov/documentLibrary/media/ 

1210.pdf. 

TABLE 8—ANNUAL BURDEN AND COSTS FOR THE INDUSTRY AND THE FAA—Continued 

Category Total 

responses 

Hours per 

response 

Burden hours 

Reporting Recordkeeping Disclosure Total Cost 

Total Industry Costs for 

61.195(h)(3) ........................... ........................ ........................ 4,749 79 0 4,829 297,441 

FAA: 61.195(h)(3): 

Review cost of FIEQTP curriculums 50.07 40 2,003 .............................. ........................ 2,003 181,692 

Revision cost of FIEQTP curriculums .............................................. 74.36 10 744 .............................. ........................ 744 67,462

Cost of issuing approval letter ......... 124.43 0.5 62 .............................. ........................ 62 2,770 

Total FAA Costs for 

61.195(h)(3) ........................... ........................ ........................ 2,809 0 0 2,809 251,924 

Total Industry and FAA Costs for 

61.195(h)(3) .................................. ........................ ........................ 7,558 79 0 7,637 549,365 

Details may not add to row or column totals due to rounding. 

Finally, § 61.195(h)(3)(vii) will require 

part 141 pilot schools and part 142 

training centers to issue a graduation 

certificate to each flight instructor who 

successfully completes the FIEQTP. 

While part 141 already requires pilot 

schools to issue a graduation certificate 

to each student who completes an 

approved course of training,66 this will 

be a new requirement for part 142 

training centers, and only required for 

training centers in the context of 

FIEQTPs. The FAA does not know how 

many part 141 pilot schools or how 

many part 142 training centers will 

choose to provide the FIEQTP course. 

Additionally, the FAA does not know 

how many flight instructors will seek to 

attend this course at a part 141 pilot 

school, which is already required to 

issue a graduation certificate; or how 

many flight instructors will seek to 

attend this course at a part 142 training 

center, which are not currently required 

to issue graduation certificates. 

Therefore, the FAA is unable to quantify 

the costs to provide a graduation 

certificate. 

F. International Compatibility 

In keeping with U.S. obligations 

under the Convention on International 

Civil Aviation, it is FAA policy to 

conform to International Civil Aviation 

Organization (ICAO) Standards and 

Recommended Practices to the 

maximum extent practicable. The FAA 

has determined that there are no ICAO 

Standards and Recommended Practices 

that correspond to these regulations. 

G. Environmental Analysis 

FAA Order 1050.1F identifies FAA 

actions that are categorically excluded 

from preparation of an environmental 

assessment or environmental impact 

statement under the National 

Environmental Policy Act (NEPA) in the 

absence of extraordinary circumstances. 

The FAA has determined this 

rulemaking action qualifies for the 

categorical exclusion identified in 

paragraph 5–6.6f for regulations and 

involves no extraordinary 

circumstances. 

VII. Executive Order Determinations 

A. Executive Order 13132, Federalism 

The FAA has analyzed this final rule 

under the principles and criteria of 

Executive Order (E.O.) 13132, 

Federalism. The FAA has determined 

that this action will not have a 

substantial direct effect on the States, or 

the relationship between the Federal 

Government and the States, or on the 

distribution of power and 

responsibilities among the various 

levels of government, and, therefore, 

will not have federalism implications. 

B. Executive Order 13175, Consultation 

and Coordination With Indian Tribal 

Governments 

Consistent with Executive Order 

13175, Consultation and Coordination 

with Indian Tribal Governments,67 and 

FAA Order 1210.20, American Indian 

and Alaska Native Tribal Consultation 

Policy and Procedures,68 the FAA 

ensures that Federally Recognized 

Tribes (Tribes) are given the opportunity 

to provide meaningful and timely input 

regarding proposed Federal actions that 

have the potential to have substantial 

direct effects on one or more Indian 

Tribes, on the relationship between the 

Federal government and Indian Tribes, 

or on the distribution of power and 

responsibilities between the Federal 

government and Indian Tribes; or to 

affect uniquely or significantly their 

respective Tribes. At this point, the FAA 

has not identified any unique or 

significant effects, environmental or 

otherwise, on Tribes resulting from this 

final rule. 

C. Executive Order 13211, Regulations 

That Significantly Affect Energy Supply, 

Distribution, or Use 

The FAA analyzed this final rule 

under E.O. 13211, Actions Concerning 

Regulations that Significantly Affect 

Energy Supply, Distribution, or Use 

(May 18, 2001). The FAA has 

determined that it will not be a 

‘‘significant energy action’’ under the 

executive order and is not likely to have 

a significant adverse effect on the 

supply, distribution, or use of energy. 

D. Executive Order 13609, Promoting 

International Regulatory Cooperation 

Executive Order 13609, Promoting 

International Regulatory Cooperation, 

promotes international regulatory 

cooperation to meet shared challenges 

involving health, safety, labor, security, 

environmental, and other issues and to 

reduce, eliminate, or prevent 

unnecessary differences in regulatory 

requirements. The FAA has analyzed 

this action under the policies and 

agency responsibilities of Executive 

Order 13609, and has determined that 

this action will have no effect on 

international regulatory cooperation. 

VIII. Additional Information 

A. Electronic Access and Filing 

A copy of the NPRM, all comments 

received, this final rule, and all 

background material may be viewed 

online at www.regulations.gov using the 

docket number listed above. A copy of 

this final rule will be placed in the 

docket. Electronic retrieval help and 

guidelines are available on the website. 

It is available 24 hours each day, 365 

days each year. An electronic copy of 

this document may also be downloaded 

from the Office of the Federal Register’s 

website at www.federalregister.gov and 

the Government Publishing Office’s 

website at www.govinfo.gov. A copy 


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may also be found at the FAA’s 

Regulations and Policies website at 

www.faa.gov/regulations_policies. 

Copies may also be obtained by 

sending a request to the Federal 

Aviation Administration, Office of 

Rulemaking, ARM–1, 800 Independence 

Avenue SW, Washington, DC 20591, or 

by calling (202) 267–9677. Commenters 

must identify the docket or notice 

number of this rulemaking. 

All documents the FAA considered in 

developing this final rule, including 

economic analyses and technical 

reports, may be accessed in the 

electronic docket for this rulemaking. 

B. Small Business Regulatory 

Enforcement Fairness Act 

The Small Business Regulatory 

Enforcement Fairness Act (SBREFA) of 

1996 requires the FAA to comply with 

small entity requests for information or 

advice about compliance with statutes 

and regulations within its jurisdiction. 

A small entity with questions regarding 

this document may contact its local 

FAA official, or the person listed under 

the FOR FURTHER INFORMATION CONTACT

heading at the beginning of the 

preamble. To find out more about 

SBREFA on the internet, visit 

www.faa.gov/regulations_policies/ 

rulemaking/sbre_act/. 

List of Subjects 

14 CFR Part 11 

Administrative practice and 

procedure, Reporting and recordkeeping 

requirements. 

14 CFR Part 61 

Aircraft, Airmen, Aviation safety, 

Reporting and recordkeeping 

requirements, Teachers. 

14 CFR Part 63 

Aircraft, Airman, Aviation safety, 

Reporting and recordkeeping 

requirements. 

14 CFR Part 65 

Aircraft, Airmen, Aviation safety, 

Reporting and recordkeeping 

requirements. 

14 CFR Part 141 

Airmen, Educational facilities, 

Reporting and recordkeeping 

requirements, Schools. 

In consideration of the foregoing, the 

Federal Aviation Administration 

amends chapter I of title 14, Code of 

Federal Regulations as follows: 

PART 11–GENERAL RULEMAKING 

PROCEDURES 

■ 1. The authority citation for part 11 

continues to read as follows: 

Authority: 49 U.S.C. 106(f), 40101, 40103, 

40105, 40109, 40113, 44110, 44502, 44701– 

44702, 44711, 46102, and 51 U.S.C. 50901– 

50923. 

■ 2. Amend § 11.201 in the table in 

paragraph (b) by revising the entry for 

part 61 to read as follows: 

§ 11.201 Office of Management and Budget 

(OMB) control numbers assigned under the 

Paperwork Reduction Act. 

* * * * * 

(b) * * * 

14 CFR part or section identified and described Current OMB control number 

*******

Part 61 ................................................................................ 2120–0021, 2120–0034, 2120–0543, 2120–0571, 2120–0816 

*******

PART 61–CERTIFICATION: PILOTS, 

FLIGHT INSTRUCTORS, AND GROUND 

INSTRUCTORS 

■ 3. The authority citation for part 61 is 

revised to read as follows: 

Authority: 49 U.S.C. 106(f), 40113, 44701– 

44703, 44707, 44709–44711, 44729, 44903, 

45102–45103, 45301–45302; Sec. 2307, Pub. 

L. 114–190, 130 Stat. 615 (49 U.S.C. 44703 

note); sec. 318, Pub. L. 115–254, 132 Stat. 

3186 (49 U.S.C. 44703 note); and Sec. 820, 

Pub. L. 118–63, 138 Stat. 1330 (49 U.S.C. 

44939 note). 

Special Federal Aviation Regulation 

No. 100–2 [Removed] 

■ 4. Remove Special Federal Aviation 

Regulation No. 100–2 from part 61. 

■ 5. Amend § 61.2 by revising 

paragraphs (b)(1) and (2) to read as 

follows: 

§ 61.2 Exercise of Privilege. 

(b) * * * 

(1) Exercise privileges of an airman 

certificate, rating, endorsement, or 

authorization issued under this part 

unless that person meets the appropriate 

airman recent experience and medical 

requirements of this part, specific to the 

operation or activity. 

(2) Exercise privileges of a foreign 

pilot license within the United States to 

conduct an operation described in 

§ 61.3(b), unless that person meets the 

appropriate airman recent experience 

and medical requirements of the 

country that issued the license, specific 

to the operation. 

■ 6. Amend § 61.19 by revising 

paragraphs (a)(2), (c)(1), (d) and (e) to 

read as follows: 

§ 61.19 Duration of pilot and instructor 

certificates and privileges. 

(a) * * * 

(2) Except for a certificate issued with 

an expiration date, a certificate issued 

under this part is valid unless it is 

surrendered, suspended, or revoked. 

(c) * * * 

(1) A pilot certificate (including a 

student pilot certificate issued after 

April 1, 2016) issued under this part is 

issued without an expiration date. 

(d) Flight instructor certificate. (1) A 

flight instructor certificate issued under 

this part on or after December 1, 2024, 

is issued without an expiration date. 

(2) A flight instructor certificate 

issued before December 1, 2024, expires 

24 calendar months from the month in 

which it was issued, renewed, or 

reinstated, as appropriate. 

(e) Ground instructor certificate. A 

ground instructor certificate is issued 

without an expiration date. 

* * * * * 

■ 7. Amend § 61.39 by: 

■ a. Revising paragraphs (a) 

introductory text, (b) introductory text, 

(b)(3), (c) introductory text, and (c)(2); 

■ b. Redesignating paragraphs (e) 

through (g) as paragraphs (f) through (h); 

and 

■ c. Adding new paragraph (e). 

The revisions and addition read as 

follows: 

§ 61.39 Prerequisites for practical tests. 

(a) Except as provided in paragraphs 

(b), (c), (e), and (f) of this section, to be 

eligible for a practical test for a 

certificate or rating issued under this 

part, an applicant must: 

* * * * * 

(b) Except as provided in paragraph 

(e) of this section, an applicant for an 

airline transport pilot certificate with an 

airplane category multiengine class 

rating or an airline transport pilot 

certificate obtained concurrently with a 

multiengine airplane type rating may 


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take the practical test with an expired 

knowledge test only if the applicant 

passed the knowledge test after July 31, 

2014, and is employed: 

* * * * * 

(3) By the U.S. Armed Forces as a 

flightcrew member in U.S. military air 

transport operations at the time of the 

practical test and has satisfactorily 

completed the pilot in command aircraft 

qualification training program that is 

appropriate to the pilot certificate and 

rating sought. 

(c) Except as provided in paragraph 

(e) of this section, an applicant for an 

airline transport pilot certificate with a 

rating other than those ratings set forth 

in paragraph (b) of this section may take 

the practical test for that certificate or 

rating with an expired knowledge test 

report, provided that the applicant is 

employed: 

* * * * * 

(2) By the U.S. Armed Forces as a 

flightcrew member in U.S. military air 

transport operations at the time of the 

practical test and has satisfactorily 

completed the pilot in command aircraft 

qualification training program that is 

appropriate to the pilot certificate and 

rating sought. 

* * * * * 

(e) An applicant for an airman 

certificate or rating issued under this 

part 61 may take a practical test with an 

expired knowledge test if the applicant 

meets the requirements specified in 

§ 61.40. 

* * * * * 

■ 8. Add § 61.40 to read as follows: 

§ 61.40 Relief for U.S. Military and civilian 

personnel who are assigned outside the 

United States in support of U.S. Armed 

Forces operations. 

(a) Relief. A person who satisfies the 

requirements of paragraph (b) of this 

section may use the following 

documents to demonstrate eligibility to 

renew a flight instructor certificate, 

establish recent flight instructor 

experience, take a practical test, or 

renew an inspection authorization, as 

appropriate: 

(1) For flight instructor certificates 

issued before December 1, 2024, an 

expired flight instructor certificate to 

show eligibility for renewal of a flight 

instructor certificate under § 61.197; 

(2) Except as provided in paragraph 

(a)(3) of this section, for flight instructor 

certificates issued after December 1, 

2024, a record demonstrating the last 

recent experience event accomplished 

under § 61.197 to show eligibility to 

reestablish recent experience under 

§ 61.197; 

(3) For persons who were issued a 

flight instructor certificate after 

December 1, 2024, and who served in a 

U.S. military or civilian capacity outside 

the United States in support of a U.S. 

Armed Forces operation for some period 

of time during the 24 calendar months 

following the issuance of the person’s 

flight instructor certificate, a flight 

instructor certificate demonstrating the 

date of issuance to show eligibility to 

establish recent experience under 

§ 61.197; 

(4) An expired written test report to 

show eligibility under this part to take 

a practical test; 

(5) An expired written test report to 

show eligibility to take a practical test 

required under part 63 of this chapter; 

and 

(6) An expired written test report to 

show eligibility to take a practical test 

required under part 65 of this chapter or 

an expired inspection authorization to 

show eligibility for renewal under 

§ 65.93. 

(b) Eligibility. A person is eligible for 

the relief specified in paragraph (a) of 

this section if that person meets the 

following requirements: 

(1) The person must have served in a 

U.S. military or civilian capacity outside 

the United States in support of a U.S. 

Armed Forces operation during some 

period of time beginning on or after 

September 11, 2001; 

(2) One of the following occurred 

while the person served in an operation 

as set forth in paragraph (b)(1) of this 

section or within 6 calendar months 

after returning to the United States— 

(i) The person’s flight instructor 

certificate issued before December 1, 

2024, airman written test report, or 

inspection authorization expired; or 

(ii) For flight instructor certificates 

issued after December 1, 2024, the 

person has not met the flight instructor 

recent experience requirements within 

the preceding 24 calendar months in 

accordance with § 61.197; and 

(3) The person complies with § 61.197 

or § 65.93 of this chapter, as 

appropriate, or completes the 

appropriate practical test within 6 

calendar months after returning to the 

United States. 

(c) Required documents. To exercise 

the relief specified in paragraph (a) of 

this section, a person must complete 

and sign an application appropriate to 

the relief sought and send the 

application to the appropriate Flight 

Standards office. The person must 

include with the application one of the 

following documents, which must show 

the date of assignment outside the 

United States and the date of return to 

the United States: 

(1) An official U.S. Government 

notification of personnel action, or 

equivalent document, showing the 

person was a civilian on official duty for 

the U.S. Government outside the United 

States and was assigned to a U.S. Armed 

Forces operation some time on or after 

September 11, 2001; 

(2) Military orders validating the 

person was assigned to duty outside the 

United States and was assigned to a U.S. 

Armed Forces operation some time on 

or after September 11, 2001; or 

(3) A letter from the person’s military 

commander or civilian supervisor 

providing the dates during which the 

person served outside the United States 

and was assigned to a U.S. Armed 

Forces operation some time on or after 

September 11, 2001. 

■ 9. Amend § 61.51 by revising 

paragraph (h)(2)(ii) to read as follows: 

§ 61.51 Pilot logbooks. 

* * * * * 

(h) * * * 

(2) * * * 

(ii) Include a description of the 

training given, the length of the training 

lesson, and the authorized instructor’s 

signature, certificate number, and 

certificate expiration date or recent 

experience end date, consistent with the 

requirements of § 61.197. 

* * * * * 

■ 10. Effective March 1, 2027, amend 

§ 61.51 by revising paragraph (h)(2)(ii) 

to read as follows: 

§ 61.51 Pilot logbooks. 

* * * * * 

(h) * * * 

(2) * * * 

(ii) Include a description of the 

training given, the length of the training 

lesson, and the authorized instructor’s 

signature, certificate number, and recent 

experience end date. 

* * * * * 

■ 11. Amend § 61.56 by revising 

paragraphs (d)(2), (e), and (f) to read as 

follows: 

§ 61.56 Flight review. 

* * * * * 

(d) * * * 

(2) A practical test conducted by an 

examiner for one of the following: 

(i) The issuance of a flight instructor 

certificate, 

(ii) An additional rating on a flight 

instructor certificate, 

(iii) To meet the recent experience 

requirements for a flight instructor 

certificate in accordance with 

§ 61.197(b)(1); or 

(iv) The reinstatement of flight 

instructor privileges in accordance with 

§ 61.199(b)(2). 

(e) A person who has, within the 

period specified in paragraph (c) of this 


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section, satisfactorily accomplished one 

or more phases of an FAA-sponsored 

pilot proficiency program need not 

accomplish the flight review required by 

this section. 

(f) A person who holds a flight 

instructor certificate need not 

accomplish the one hour of ground 

training specified in paragraph (a) of 

this section if that person has, within 

the period specified in paragraph (c) of 

this section, met one of the following 

requirements— 

(1) Satisfactorily completed the recent 

experience requirements for a flight 

instructor certificate under § 61.197; or 

(2) Reinstated the person’s flight 

instructor privileges by satisfactorily 

completing an approved flight instructor 

refresher course in accordance with 

§ 61.199(a)(1). 

* * * * * 

■ 12. Amend § 61.195 by revising 

paragraph (h) to read as follows: 

§ 61.195 Flight instructor limitations and 

qualifications. 

* * * * * 

(h) Qualifications to provide ground 

or flight training to initial flight 

instructor applicants—(1) Ground 

training. The ground training provided 

to an initial applicant for a flight 

instructor certificate must be given by 

an authorized instructor who— 

(i) Holds a ground or flight instructor 

certificate with the appropriate rating, 

has held that certificate for at least 24 

calendar months, and has given at least 

40 hours of ground training; or 

(ii) Holds a ground or flight instructor 

certificate with the appropriate rating, 

and has given at least 100 hours of 

ground training in an FAA-approved 

course. 

(2) Flight training. A flight instructor 

who provides flight training to an initial 

applicant for a flight instructor 

certificate must meet the eligibility 

requirements prescribed in § 61.183; 

hold the appropriate flight instructor 

certificate and rating; meet the 

requirements of the part under which 

the flight training is provided; and meet 

one of the following requirements— 

(i) Have held a flight instructor 

certificate for at least 24 calendar 

months; and 

(A) For training in preparation for an 

airplane, rotorcraft, or powered-lift 

rating, have given at least 200 hours of 

flight training as a flight instructor; or 

(B) For training in preparation for a 

glider rating, have given at least 80 

hours of flight training as a flight 

instructor; 

(ii) Have trained and endorsed, during 

the preceding 24 calendar months, at 

least five applicants for a practical test 

for a pilot certificate or rating, and at 

least 80 percent of all applicants 

endorsed in that period passed that test 

on their first attempt; or 

(iii) After completing the flight 

training requirements in paragraph 

(h)(2)(i)(A) or (B) of this section, as 

appropriate, have graduated from an 

FAA-approved flight instructor 

enhanced qualification training program 

that satisfies the requirements specified 

in paragraph (h)(3) of this section. 

(3) Flight instructor enhanced 

qualification training program. A flight 

instructor enhanced qualification 

training program must be approved and 

conducted under part 141 or 142 of this 

chapter, and meet the following 

requirements- 

(i) The ground training must include 

at least 25 hours of instruction that 

includes the following subjects: 

(A) Flight instructor responsibilities, 

functions, lesson planning, and risk 

management, including how to instruct 

an initial flight instructor applicant on 

these subjects. 

(B) Teaching methods, procedures, 

and techniques applicable to instructing 

an initial flight instructor applicant. 

(C) Methods of proper evaluation of 

an initial flight instructor applicant to 

detect improper and insufficient transfer 

of instructional knowledge, training, 

and performance of the initial flight 

instructor applicant. 

(D) Corrective action in the case of 

unsatisfactory training progress. 

(ii) The flight training must include at 

least 10 hours of training that includes 

the following areas: 

(A) Scenario-based training to develop 

the flight instructor’s ability to instruct 

an initial flight instructor applicant how 

to satisfactorily perform the procedures 

and maneuvers while giving effective 

flight training. 

(B) Instructional knowledge and 

proficiency to teach an initial flight 

instructor applicant in abnormal and 

emergency procedures, which must 

include stall awareness, spin entry, 

spins, and spin recovery procedures, if 

applicable to the category and class of 

aircraft used in the flight instructor 

enhanced qualification training 

program. 

(C) Risk management and potential 

results of improper, untimely, or nonexecution of safety measures critical to 

flight training. 

(D) Methods of proper evaluation of 

an initial flight instructor applicant to 

detect improper and insufficient transfer 

of instructional knowledge, training, 

and performance of the initial flight 

instructor applicant. 

(E) Corrective action in the case of 

unsatisfactory training progress. 

(F) Methods to detect personal 

characteristics of an initial flight 

instructor applicant that could 

adversely affect safety. 

(iii) Each flight instructor enrolled in 

the flight instructor enhanced 

qualification training program must 

satisfactorily complete an end-of-course 

written test specific to the ground 

training subjects in paragraph (h)(3)(i) of 

this section and an end-of-course 

instructional proficiency flight test 

specific to the flight training areas in 

paragraph (h)(3)(ii) of this section. 

(iv) A full flight simulator or flight 

training device may be used to meet the 

flight training requirements of 

paragraph (h)(3)(ii) of this section. The 

FFS or FTD must be— 

(A) Qualified and maintained in 

accordance with part 60 of this chapter, 

or a previously qualified device as 

permitted in accordance with § 60.17 of 

this chapter; 

(B) Approved by the Administrator 

pursuant to § 61.4(a); and 

(C) Used in accordance with the part 

under which the FAA-approved course 

is conducted. 

(v) A maximum of 5 hours of training 

received in an advanced aviation 

training device may be used to meet the 

flight training requirements of 

paragraph (h)(3)(ii) of this section for 

part 141 flight instructor enhanced 

qualification training programs. The 

advanced aviation training device must 

be- 

(A) Approved by the Administrator 

pursuant to § 61.4(c); and 

(B) Used in accordance with part 141 

of this chapter. 

(vi) No certificate holder may use a 

person, nor may any person serve, as an 

instructor of the flight instructor 

enhanced qualification training program 

unless the instructor holds a flight 

instructor certificate or ground 

instructor certificate and meets one of 

the following qualifications: 

(A) Serves as a chief instructor or 

assistant chief instructor in a part 141 

pilot school; 

(B) Serves as a training center 

program manager or assistant training 

center program manager of a part 142 

training center; or 

(C) Meets the qualifications of an 

assistant chief instructor, pursuant to 

§ 141.36(d). 

(vii) A part 141 pilot school or part 

142 training center must issue a 

graduation certificate to each flight 

instructor who successfully completes 

the flight instructor enhanced 

qualification training program. 

■ 13. Revise § 61.197 to read as follows: 


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§ 61.197 Recent experience requirements 

for flight instructor certification. 

(a) A person may exercise the 

privileges of the person’s flight 

instructor certificate only if, within the 

preceding 24 calendar months, that 

person has satisfied one of the recent 

experience requirements specified in 

paragraph (b) of this section. The 24 

calendar month period during which 

the flight instructor must establish 

recent experience shall start from one of 

the following— 

(1) The month the FAA issued the 

flight instructor certificate; 

(2) The month the recent experience 

requirements of paragraph (b) of this 

section are accomplished; or 

(3) The last month of the flight 

instructor’s current recent experience 

period provided the recent experience 

requirements of paragraph (b) of this 

section are accomplished within the 3 

calendar months preceding the last 

month of the certificate holder’s current 

recent experience period. 

(b) A person who holds a flight 

instructor certificate may establish 

recent experience by satisfying one of 

the following requirements— 

(1) Passing a practical test for— 

(i) One of the ratings listed on the 

flight instructor certificate; or 

(ii) An additional flight instructor 

rating; or 

(2) Satisfactorily completing one of 

the following recent experience 

requirements, and submitting 

documentation of such in a form and 

manner acceptable to the 

Administrator— 

(i) During the preceding 24 calendar 

months, the flight instructor has 

endorsed at least 5 applicants for a 

practical test for a certificate or rating 

and at least 80 percent of all applicants 

endorsed passed that test on the first 

attempt. 

(ii) Within the preceding 24 calendar 

months, the flight instructor has served 

as a company check pilot, chief flight 

instructor, company check airman, or 

flight instructor in a part 121 or 135 

operation, or in a position involving the 

regular evaluation of pilots. 

(iii) Within the preceding 3 calendar 

months, the person has successfully 

completed an approved flight instructor 

refresher course consisting of ground 

training or flight training, or a 

combination of both. 

(iv) Within the preceding 24 calendar 

months from the month of application, 

the flight instructor passed an official 

U.S. Armed Forces military instructor 

pilot or pilot examiner proficiency 

check in an aircraft for which the 

military instructor already holds a rating 

or in an aircraft for an additional rating. 

(v) Within the preceding 24 calendar 

months from the month of application, 

the flight instructor has served as a 

flight instructor in an FAA-sponsored 

pilot proficiency program, provided the 

flight instructor meets the following 

requirements— 

(A) Holds a flight instructor certificate 

and meets the appropriate flight 

instructor recent experience 

requirements of this part; 

(B) Has satisfactorily completed at 

least one phase of an FAA-sponsored 

pilot proficiency program in the 

preceding 12 calendar months; and 

(C) Has conducted at least 15 flight 

activities recognized under the FAAsponsored pilot proficiency program, 

during which the flight instructor 

evaluated at least 5 different pilots and 

has made the necessary endorsements in 

the logbooks of each pilot for each 

activity. 

(c) Except as provided in paragraph (f) 

of this section, a person who fails to 

establish recent experience in 

accordance with paragraph (b) of this 

section during the 24 calendar month 

period specified in paragraph (a) of this 

section may not exercise flight 

instructor privileges until those 

privileges are reinstated in accordance 

with § 61.199. 

(d) The practical test required by 

paragraph (b)(1) of this section may be 

accomplished in a full flight simulator 

or flight training device if the test is 

accomplished pursuant to an approved 

course conducted by a training center 

certificated under part 142 of this 

chapter. 

(e) A person who holds an unexpired 

flight instructor certificate issued before 

December 1, 2024, may renew that 

certificate by establishing recent 

experience in accordance with 

paragraph (b) of this section prior to the 

month of expiration on that person’s 

flight instructor certificate. Except as 

provided in § 61.40, if that person fails 

to establish recent experience prior to 

the expiration of that person’s flight 

instructor certificate, that person may 

not exercise flight instructor privileges 

until those privileges are reinstated in 

accordance with § 61.199. 

(f) A person who qualifies for the 

relief prescribed in § 61.40 may 

establish recent experience in 

accordance with paragraph (b) of this 

section, provided the requirements of 

§ 61.40 are met. 

■ 14. Amend § 61.199 by revising the 

section heading and paragraph (a), and 

removing paragraphs (c) and (d). The 

revisions read as follows: 

§ 61.199 Reinstatement of flight instructor 

privileges. 

(a) Flight instructor privileges. The 

holder of a flight instructor certificate 

who has not complied with the flight 

instructor recent experience 

requirements of § 61.197 may reinstate 

their flight instructor privileges by filing 

a completed and signed application 

with the FAA and satisfactorily 

completing one of the following 

reinstatement requirements: 

(1) If 3 calendar months or less have 

passed since the last month of the flight 

instructor’s recent experience period, 

the flight instructor may successfully 

complete an approved flight instructor 

refresher course consisting of ground 

training or flight training, or a 

combination of both, or satisfy one of 

the requirements specified in paragraph 

(a)(2) of this section. 

(2) If more than 3 calendar months 

have passed since the last month of the 

flight instructor’s recent experience 

period, the flight instructor must 

satisfactorily complete one of the 

following: 

(i) A flight instructor certification 

practical test, as prescribed by 

§ 61.183(h), for one of the ratings held 

on the flight instructor certificate; or 

(ii) A flight instructor certification 

practical test for an additional rating. 

(3) For military instructor pilots and 

pilot examiners, provide a record 

showing that, within the preceding 6 

calendar months from the date of 

application for reinstatement, the 

person— 

(i) Passed a U.S. Armed Forces 

instructor pilot or pilot examiner 

proficiency check; or 

(ii) Completed a U.S. Armed Forces 

instructor pilot or pilot examiner 

training course and received an 

additional aircraft qualification as a 

military instructor pilot or pilot 

examiner that is appropriate to the flight 

instructor rating sought. 

* * * * * 

■ 15. Revise § 61.215 by adding 

paragraph (e) to read as follows: 

§ 61.215 Ground instructor privileges. 

* * * * * 

(e) Ground training provided to an 

initial applicant for a flight instructor 

certificate may only be provided by an 

authorized instructor in accordance 

with § 61.195(h)(1). 

■ 16. Revise § 61.425 to read as follows: 

§ 61.425 How do I establish recent 

experience for my flight instructor 

certificate with a sport pilot rating? 

(a) If you hold a flight instructor 

certificate with a sport pilot rating 

issued after December 1, 2024, you must 


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establish recent experience in 

accordance with § 61.197. 

(b) If you hold an unexpired flight 

instructor certificate with a sport pilot 

rating issued before December 1, 2024, 

you must renew your certificate by 

establishing recent experience in 

accordance with § 61.197 prior to the 

month of expiration on your flight 

instructor certificate. If you fail to 

establish recent experience prior to the 

expiration of your flight instructor 

certificate, you may not exercise flight 

instructor privileges until you reinstate 

those privileges in accordance with 

§ 61.427. 

■ 17. Revise § 61.427 to read as follows: 

§ 61.427 How do I reinstate my flight 

instructor privileges if I fail to establish 

recent experience for my flight instructor 

certificate with a sport pilot rating? 

If you fail to establish recent 

experience for your flight instructor 

certificate with a sport pilot rating, you 

must reinstate your flight instructor 

privileges by satisfactorily completing 

one of the following reinstatement 

requirements: 

(a) If 3 calendar months or less have 

passed since the last month of your 

recent experience period, you must 

successfully complete an approved 

flight instructor refresher course 

consisting of ground training or flight 

training, or a combination of both, or 

satisfy the requirements specified in 

paragraph (b) of this section. 

(b) If more than 3 calendar months 

have passed since the last month of the 

flight instructor’s recent experience 

period, you must pass a practical test as 

prescribed in § 61.405(b) or § 61.183(h) 

for one of the ratings listed on your 

flight instructor certificate with a sport 

pilot rating. The FAA will reinstate any 

privilege authorized by that flight 

instructor certificate with a sport pilot 

rating. 

PART 63—CERTIFICATION: FLIGHT 

CREWMEMBERS OTHER THAN 

PILOTS 

■ 18. The authority citation for part 63 

is revised to read as follows: 

Authority: 49 U.S.C. 106(f), 40113, 44701– 

44703, 44707, 44709–44711, 45102–45103, 

45301–45302. 

■ 19. Amend § 63.35 by revising 

paragraphs (c), (d)(1)(iii) and (d)(2), and 

adding paragraph (d)(3) to read as 

follows: 

§ 63.35 Knowledge requirements. 

* * * * * 

(c) Before taking the written tests 

prescribed in paragraphs (a) and (b) of 

this section, an applicant for a flight 

engineer certificate must present 

satisfactory evidence of having 

completed one of the experience 

requirements of § 63.37. However, the 

applicant may take the written tests 

before acquiring the flight training 

required by § 63.37. 

(d) * * * 

(1) * * * 

(iii) Meets the recurrent training 

requirements of the applicable part or, 

for mechanics, meets the recency of 

experience requirements of part 65 of 

this chapter; 

(2) Within the period ending 24 

calendar months after the month in 

which the applicant passed the written 

test, the applicant participated in a 

flight engineer or maintenance training 

program of a U.S. scheduled military air 

transportation service and is currently 

participating in that program; or 

(3) An applicant is eligible to take a 

practical test for a flight engineer 

certificate or rating under this part with 

an expired written test report in 

accordance with § 61.40 of this chapter. 

* * * * * 

■ 20. Amend § 63.53 by revising 

paragraph (b), and adding paragraph (c) 

to read as follows: 

§ 63.53 Knowledge requirements. 

* * * * * 

(b) A report of the test is mailed to the 

applicant. Except as provided in 

paragraph (c) of this section, a passing 

grade is evidence, for a period of 24 

calendar months after the test, that the 

applicant has complied with this 

section. 

(c) An applicant is eligible to take a 

practical test for a flight navigator 

certificate under this part with an 

expired written test report in 

accordance with § 61.40 of this chapter. 

PART 65—CERTIFICATION: AIRMEN 

OTHER THAN FLIGHT 

CREWMEMBERS 

■ 21. The authority citation for part 65 

is revised to read as follows: 

Authority: 49 U.S.C. 106(f), 40113, 44701– 

44703, 44707, 44709–44711, 45102–45103, 

45301–45302. 

■ 22. Amend § 65.55 by revising 

paragraph (b), and adding paragraph (c) 

to read as follows: 

§ 65.55 Knowledge requirements. 

* * * * * 

(b) Except as provided in paragraph 

(c) of this section, the applicant must 

present documentary evidence 

satisfactory to the Administrator of 

having passed an aircraft dispatcher 

knowledge test within the preceding 24 

calendar months. 

(c) An applicant is eligible to take a 

practical test for an aircraft dispatcher 

certificate under this part with an 

expired written test report in 

accordance with § 61.40 of this chapter. 

■ 23. Amend § 65.71 by revising 

paragraphs (a)(4) and (b) to read as 

follows: 

§ 65.71 Eligibility requirements: General. 

(a) * * * 

(4) Comply with the sections of this 

subpart that apply to the rating the 

applicant seeks. 

(b) A certificated mechanic who 

applies for an additional rating must 

meet the requirements of § 65.77 and, 

within a period of 24 calendar months, 

pass the tests prescribed by §§ 65.75 and 

65.79 for the additional rating sought, 

except as provided in § 65.75(d). 

■ 24. Amend § 65.75 by adding 

paragraph (d) to read as follows: 

§ 65.75 Knowledge requirements. 

* * * * * 

(d) An applicant is eligible to take a 

practical test for a mechanic certificate 

or rating under this part with an expired 

written test report in accordance with 

§ 61.40 of this chapter. 

■ 25. Amend § 65.93 by revising 

paragraph (a) introductory text, and 

adding paragraph (d) to read as follows: 

§ 65.93 Inspection authorization: Renewal. 

(a) Except as provided in paragraph 

(d) of this section, to be eligible for 

renewal of an inspection authorization 

for a 2-year period an applicant must 

present evidence during the month of 

March of each odd-numbered year, at 

the responsible Flight Standards office, 

that the applicant still meets the 

requirements of § 65.91(c)(1) through 

(4). In addition, during the time the 

applicant held the inspection 

authorization, the applicant must show 

completion of one of the activities in 

paragraphs (a)(1) through (5) of this 

section by March 31 of the first year of 

the 2-year inspection authorization 

period, and completion of one of the 

five activities during the second year of 

the 2-year period: 

* * * * * 

(d) A person who qualifies for the 

relief prescribed in § 61.40 of this 

chapter is eligible to renew an expired 

inspection authorization under this 

section, provided the requirements of 

§ 61.40 of this chapter are met. 

PART 141—PILOT SCHOOLS 

■ 26. The authority citation for part 141 

is revised to read as follows: 

Authority: 49 U.S.C. 106(f), 40113, 44701– 

44703, 44707, 44709, 44711, 45102–45103, 

45301–45302. 


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■ 27. Amend § 141.11 by adding 

paragraph (b)(2)(ix) and paragraph (b)(4) 

to read as follows: 

§ 141.11 Pilot school ratings. 

* * * * * 

(b) * * * 

(2) * * * 

(ix) Flight instructor enhanced 

qualification training program. 

* * * * * 

(4) Combined Private Pilot 

Certification and Instrument Rating 

Course. (Appendix M). 

■ 28. Amend appendix K to part 141 by: 

■ a. Revising the paragraph heading of 

paragraph 4; 

■ b. Revising paragraphs 4.(a) through 

(c); and 

■ c. Adding paragraph 14. 

The revisions and addition read as 

follows: 

Appendix K to Part 141—Special 

Preparation Courses 

* * * * * 

4. Use of full flight simulators, flight 

training devices, or aviation training 

devices. 

(a) The approved special preparation 

course may include training in a full 

flight simulator or flight training device, 

provided it is representative of the 

aircraft for which the course is 

approved, meets requirements of this 

paragraph, and the training is given by 

an authorized instructor. A flight 

instructor enhanced qualification 

training program may include training 

in an advanced aviation training device 

in accordance with paragraph 14 of this 

appendix and § 61.195(h)(3)(v) of this 

chapter. 

(b) Except for the airline transport 

pilot certification program in paragraph 

13 of this appendix and the flight 

instructor enhanced qualification 

training program in paragraph 14 of this 

appendix, training in a full flight 

simulator that meets the requirements of 

§ 141.41(a) may be credited for a 

maximum of 10 percent of the total 

flight training hour requirements of the 

approved course, or of this section, 

whichever is less. 

(c) Except for the airline transport 

pilot certification program in paragraph 

13 of this appendix and the flight 

instructor enhanced qualification 

training program in paragraph 14 of this 

appendix, training in a flight training 

device that meets the requirements of 

§ 141.41(a), may be credited for a 

maximum of 5 percent of the total flight 

training hour requirements of the 

approved course, or of this section, 

whichever is less. 

* * * * * 

14. Flight instructor enhanced 

qualification training program. An 

approved flight instructor enhanced 

qualification training program must 

include the ground and flight training 

specified in § 61.195(h)(3) of this 

chapter. The FAA will not approve a 

course with fewer hours than those 

prescribed in § 61.195(h)(3) of this 

chapter. 

Issued under authority provided by 49 

U.S.C. 106(f), 44701(a)(5), 44703(a), and 

Sec. 820 of Public Law 118–63, 138 Stat. 

1330 (49 U.S.C. 44939 note) in 

Washington, DC. 

Michael Gordon Whitaker, 

Administrator. 

[FR Doc. 2024–22018 Filed 9–30–24; 8:45 am] 

BILLING CODE 4910–13–P 


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