Request a change to the provisions in Title 14, Chapter I, Subchapter 

D, Part 61.199: “Reinstatement requirements of an expired flight 

instructor certificate”

Request Sec 61.199 include a provision for current military instructor 

pilots to be able to renew an expired FAA instructor certificates who:

1. Have maintained military instructors status since receiving their 

military equivalent CFI, or

2. Whose FAA certificate expired due to an expired military 

instructor rating but have since regained military instructor 

status by completing an appropriate military proficiency check 

as a military instructor.

The guidance to earn an initial military equivalent instructor certificate

outlined in Sec 61.73g is an amazing opportunity afforded to military 

instructors. The military instructor community is very grateful for 

being extended such a generous courtesy from the FAA and the 

change has been a tremendous success. 

I am requesting to continue building on the success of Sec 61.73g by 

extending the same generosity to military pilots in Sec 61.199 by 

adding a provision for CFI reinstatement for military instructor pilots

who can prove current military instructors status by submitting 

documentation of a valid and current proficiency check accomplished 

as a military instructor.

The requirements in Sec 61.73g and Sec 61.199 do not align. Sec 61.73 

requires a written test and military instructor proficiency check to gain 

an initial military equivalent CFI. As presently written, Sec 61.199 

states that once a military instructor equivalent CFI expires, the only 

way for a military instructor to reinstate a CFI rating is by completing 

an FAA administered flight instructor certification practical test. The 

requirements for CFI reinstatement for military in Sec 61.199 are more 

restrictive than the new requirements in Sec 61.73g. In the spirit of 
the requirements in 61.173g, a current military instructor should also 

be able to renew their CFI rating by showing documentation of a 

completed and current military instructor proficiency check. The 

requirements in Sec 61.199 should be re-written to more align with 

Sec 61.73g.

Second, FAA examiners are unable to conduct FAA examinations in 

military aircraft in which the military instructor is qualified. The other 

option for military instructors to complete an FAA is also impractical 

because most instructors in military airplanes do not normally fly in 

the same civilian aircraft that FAA examiners do, unless they are able 

to find the time and resources to fund mastering flying civilian aircraft. 

This impracticality would be addressed by including a provision in Sec 

61.199g for military pilots seeking to reinstate their CFI rating. 

A change to sec 61.199 outlining provisions for military instructor 

pilots with an expired FAA instructor certificate who hold a current 

instructor rating in the military would serve public interest by 

capitalizing on the existing skills and qualifications of military 

instructor pilots. It would also benefit the public interest by 

eliminating impracticalities in instructor certificate re-instatements for 

military pilots. And finally, a change in Sec 61.199 would continue to 

extend the goodwill shown to military members in Sec 61.73g.

Including a provision for the reinstatement of an equivalent instructor 

certificate for military instructors in Sec 61.199, would not adversely 

affect safety because is only an extension of the requirements that are 

already in practice as outlined in sec 61.73g. By only accepting a 

current military flight examination (<24 mos), it ensures that the same 

standard of safety is being applied to military and civilian pilots alike. 

The proposed wording for Sec. 61.199 would include a military 

instructor flight examination as meeting the requirement of Sec 

61.199(a)(1) and 61.199(a)(2). 
"(1) A flight instructor certification practical test, as prescribed by § 

61.183(h), for one of the ratings held on the expired flight instructor 

certificate or an official U.S. Armed Forces record or order that shows 

the person is qualified as a U.S. Armed Forces military instructor pilot 

or pilot examiner for the flight instructor rating being re-instated.

(2) A flight instructor certification practical test for an additional rating 

or an official U.S. Armed Forces record or order that shows the 

person is qualified as a U.S. Armed Forces military instructor pilot or 

pilot examiner for the flight instructor rating being sought.”

The privileges of this exemption would not be exercised outside of the 

United States. 

Thank you for your consideration on this matter.