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

D, Part 61.199: “ Reinstatement requirements of an expire d 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 regain ed 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 a fforded 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 sa me 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 an d 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 comp leting an FAA administered flight instruct o r 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 ofthe requirements in 61.173g, a curre nt 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 impracti cal because most instructors in military airplanes do not norm ally 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 exten sion 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 p roposed 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 qual ified 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.