Industry Updates

DATES: This final rule is effective December 1, 2024, except that amendatory instruction 10 is effective March 1, 2027.

CFI Renewal now Recent Experience

This action removes the expiration date on flight instructor certificates to align with other airman 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 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).

 
The FAA is not removing any existing allowances to renew a flight instructor certificate. 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.  

The 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. 

Initial CFI applicants

The final rule also adds two new methods for flight instructors to qualify to train initial applicants. The first new option is based on training and endorsing successful applicants for practical tests.  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. 

The FAA is also introducing a second new option as a method of qualification by completion of a new training program, approved and conducted under part 141 or part 142, designed to prepare flight instructors to train initial flight instructor applicants.  

Flight instructors may complete an FAA-approved Flight Instructor Enhanced Qualification Training Program (FIEQTP) if they 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).  The FIEQTP is designed to train relatively inexperienced flight instructors how to teach new flight instructors.  The FIEQTP provides specialized training to develop the attendee’s ability to instruct initial flight instructor applicants.  

FIEQTP require 25 hours of ground training and 10 hours of flight training.  These courses must be taught by a Part 141 Chief or Assistant Chief Instructor(s) (or instructors meeting § 141.36(d)) or Part 142 program managers and assistant training center program managers.

Expired CFI certificate

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.

Examining Authority allows a Part 141 flight school to certify students for a certificate or rating at the completion of a course without a practical test.  Prior to 1997, flight schools had to have nine out of ten of their most recent graduates pass an interim or final test on the first try.

The current regulations require that a flight school has a minimum quantity of training and a minimum quality of training.  These are distinct requirements.  Below you will find a response from the Office of the Chief Counsel to our request for clarification of § 141.63.  In this response, the FAA makes clear that the quantity and quality standards are distinct.  

Link to the current version of the regulation.

For the minimum Quantity of Training, the school must "have trained at least 10 students in the training course for which examining authority is sought and recommended those students for a pilot, flight instructor, or ground instructor certificate or rating."  There is no requirement for any number of these students to have their test administered by an FAA inspector nor a non-employee designated pilot examiner.  This is due to the fact that the Quantity of Training is based on the recommendation for the certificate or rating and not based on the practical tests themselves.

For the minimum Quality of Training, at least "90 percent of those students passed the required practical or knowledge test, or any combination thereof, for the pilot, flight instructor, or ground instructor certificate or rating on the first attempt, and that test was given by—

(A) An FAA inspector; or

(B) An examiner who is not an employee of the school."

In a legal interpretation in 2011 (Testa 2011), the FAA provided additional detail for calculating Quality of Training for § 141.5.  While this regulation covers issuance of a pilot school certificate, the guidance provided in questions 1 and 2 may prove useful when calculating Quality of Training when applying for Examining Authority.

The Ragland 2016 legal interpretation is provided for completeness.  While most of this legal interpretation clarifies that Examining Authority is based on a given course, the FAA also makes clear that the minimum quantity and minimum quality requirements are separate requirements.  It also makes clear that employee DPEs administering practical tests are not included in the Quality of Training calculation.

Finally, the FAA must issue Examining Authority to any school that satisfies § 141.63 per § 141.9.  This was made clear in the Federal Register in 2009 when § 141.63 was amended as well as in a legal interpretation (Milner 2010).