Date: 201809
Location: ZZZ.Airport, US
Aircraft: Skyhawk 172/Cutlass 172
Operator: FBO
Operating under: Part 91
Flight plan: VFR
Mission: Training
Airspace: Class D ZZZ
ATC / advisory: Tower ZZZ
Reporter organization: FBO
Reporter function: Instructor
Reporter qualification: Flight Crew Instrument; Flight Crew Flight Instructor; Flight Crew Air Transport Pilot (ATP); Flight Crew Multiengine; Flight Crew Rotorcraft
Human factors: Confusion; Training / Qualification
Anomaly: Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Flight Crew
Result: Flight Crew Requested ATC Assistance / Clarification
Contributing factors: Manuals; Procedure
Primary problem: Manuals

Narrative: As a previous Flight Instructor returning to the trade; I have found Flight Instruction most enjoyable. I spent a month in preparation for my first student in almost ten years. Unfortunately; I discovered the regulations under FAR Part 61.85 similar and not clear to the changes made to the Medical Certification whereby not being allowed as a Student Certificate. The result was two of my students flew Solos without the proper Student Certificate; paper or plastic document. One student on a fast track flew 10 hours including all cross-country requirements; and the other student flew 1 hour as a first solo. After my mistake was presented to me; I consulted with a senior instructor; flight school owner; and our local designated examiner. We concluded that the students be reimbursed fully and the solo flights be made a second time with all proper documents and endorsements required to meet FAR Part 61.83; 61.85; 61.87. Like most pilots; I must blame myself for not being adequately informed either through my studies and/or seeking other means of ensuring I am up to date with all the changes made with these regulations. As a pilot; who began flying in 1994; I am very aware not to have an old school attitude; and to change as regulations are introduced. I own a current FAR/AIM 2018 and read FAR 61.83; 61.85 61.87; 61.105; 61.107; 61.109 many times to myself and with my students. Unfortunately; I find FAR 61.85 vague as to the new instructions for what is required by the Flight Instructor. It wasn't until my research uncovered; by AC 61.65F; Pre-solo Requirements and Privilege; did a greater informative explanation begin to develop. In my mind I have a few suggestions that could make this process easier that I would like to share: 1. FAR 61.85 should explain that the Medical Certificate is no longer a Student Pilot Certificate; and explain a [form] 8710 is required by Student Pilots 2. IACRA is a great tool; but it still difficult to navigate without help from others. 3. Flight schools should hold the primary responsibilities for ensure their clients are vetted and after pairing with a flight instructor; then should the [form] 8710 process begin and competed by the recommending instructor (RI) thereof. 4. CFI Renewal Process should explain FAR 61.85 and clarify the Student Certificate. As these recommendations are coming from a senior adult male in his mid 50s; I find a lot of us are returning to flight instruction; and it would be prudent for the aviation community to reinforce the regulation changes made in the last decade in order to emphasize and minimize inadvertent mistakes such as the one I committed.




Synopsis: C172 flight instructor reported endorsing two students for solo flights without proper documentation due to confusion over FAR Part 61.85.