8710 question

DBrown

Well-Known Member
Do they expire?

If so when and what regs explain it?

The scenario is a CFI going for his CFII was signed off last summer all his endorsements, iacara and a signed 8710, he was unable to take his checkride until recently and went out with a CFII and got current & his 2 month endorsement.

Dpe and FSDO both say no. They say 8710 expires in 60 days
My response is,
"then why do we have 2 month endorsements"
And "can you direct me to that reg"
All they say is nope but if you submit that 8710 it will be sent back
And your applicant will have to redo the checkride.
I'm not one to argue with Feds but what are your thoughts?
 
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My best guess is it's related to the 61.39(a)(6)(i) requirement for the 2-calendar month endorsement. At the time the IACRA 8710-1 is completed, it also contains the instructor's recommendation certifying that the pilot is ready for the test. "Ready" includes technical requirements such as the the 2-calendar month training. So, if the 2 calendar months goes by, the "readiness" certification is stale.
 
Not sure if this quite clears it up, but some others are under the impression that the 8710 is only valid for 60 days.

http://forums.jetcareers.com/threads/endorsement-duration.104673/
If all that trouble was gone through to get the endorsement, why would it then be an issue to have that instructor who just gave the instruction then sign off on a new 8710? That would seem to solve the problem right there...

That instructor that gave the 2 month was unwilling, with the excuse that "he didn't do the training he just verified that you were ok to take test" and "if you want all the endorsements from me we need to start at square 1 and cover everything"
 
So what is the purpose of the 2 calendar month endorsement?

If a signed 8710 is only valid for 2 months in what scenario would anyone ever need a 2 month endorsement then?

To keep a CFI from signing off someone he hasn't flown with in 2 months right?

instructors come and go and if an instructor signs someone off as ready to take the test, then 3 months pass for "fill in the blank reason" and that instructor has moved away or is not reachable the student is now required to get all new endorsements from a new instructor which puts him in a position of being at the mercy of a new instructor.
"which is what the dpe and FSDO is telling me"

It seems logical to me that the 2 month reg is intended for someone in this situation who has all the training and endorsements but too much time has passed so instead of having to cover everything again with a new instructor a simple checkout would suffice as (training) within 2 calendar months.

"This issue has been resolved with new endorsements but I'm still trying to figure out the purpose for the 2 month reg
Because the odds of it being added to the FARs because CFIs were out there signing off people that they didn't fly with in 2 months seems very unlikely"
 
To keep a CFI from signing off someone he hasn't flown with in 2 months right?
No. To make sure that someone who is taking a practical test has had a contemporaneous assessment of her flying skills and readiness to pass the practical test. Two months is a pretty good time frame; some might even consider it too long.

It seems logical to me that the 2 month reg is intended for someone in this situation who has all the training and endorsements but too much time has passed so instead of having to cover everything again with a new instructor a simple checkout would suffice as (training) within 2 calendar months.

That seems logical to me also but, as my Mom would say, what does that have to do with the price of tea in China?

The CFI who takes over needs to satisfy himself that the student is indeed ready before putting his signature on the two 2-month "readiness" endorsements. That, both legally and ethically, requires at least some due diligence. For most CFIs, that would probably involve a run-through of the PTS maneuvers and perhaps a mock oral. If there are weaknesses, they would need to be addressed.

The fact that there are some CFIs out there who would use it as the basis for milking a student means the CFI can accurately be described as certain dark part of mammalian anatomy. I really don't see it as a problem with a reg that requires a CFI assessment of a pilots' readiness withing 2 calendar months of taking a practical test.[/quote][/quote]
 
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I used to hate the people who would show up having expired endorsements demanding a new one from me in one flight.

"Uh, no. My name is now the one that's going to be in there, and I HAVE to do all of these things with you before it goes in there. Capiche!"

They'd usually get all butt hurt, and try and find another CFI. Go for it. The last thing I want to do is a carpet dance because I failed to accurately check, and log, that I did everything required because the student did somethingnstupid and caught the eye of a fed.
 
If the 8710 and other endorsements are only valid for 2 months then why in the world does a specific 2 month endorsement even exsist?
 
If the 8710 and other endorsements are only valid for 2 months then why in the world does a specific 2 month endorsement even exsist?
As I suggested before, I think you have it backwards. As the saying goes, "Do the math." Literally.

There is no regulation that makes the 8710-1 valid for only 2 months. In fact, the 8710-1 is not a regulatory creature at all. It's just an application from. It's where you list the information from your logbook that says you meet the instruction and experience requirements for the certificate or rating you're trying to get. It's just a form. Theoretically, the application could be just 3 lines:
1. Who are you?
2. Where do you live?
3. What are you applying for?​
No listed experience. No requirement to have a prior pilot certificate (even a student one). No breakdown of time to see if you meet requirements. No nothing. Heck, if you spend an extra $300 to have the examiner go through your logbook and fill out a checklist (since you haven't certified anything), so what?

But the FAA decided it made more sense for its record-keeping, to help out its examiners, and to keep people from wasting everyone's time and their money applying for things they are not qualified for, to have you and your instructor review your training records in advance and certify that you meet the regulatory requirements for what you are applying for.

One of those regulatory requirements is instruction within 2 calendar months before the test.

May 7, you fill out your IACRA and your CFI signs off on it. That tells the FAA that, as of the date on the application, you have met all the regulatory requirements and have the skill set to pass the test. That includes the 61.39 regulatory requirement for the 2 month endorsement.

Now it's September 15. Exactly where in the application can you find even one word that says, as of September 15, the applicant has met the 61.39 requirement for instruction within the previous 2 calendar months?

It doesn't. It can't. The endorsement in May simply can't certify that you had instruction in July or August. It's just stale. It no longer says what it needs to, simply by the passage of time. So the application is simply no longer good.

It's just the math. May is 4 calendar months before September.
 
If the 8710 expires after 60 days, why would IACRA let you use it later than that?
That would be fine also. It makes exactly as much sense for the FAA to take the view that it doesn't expire but that it's supplemented by a later logbook endorsement. It's a policy choice and like all policy choices, more than one choice can be valid; it's not a "right" and "wrong" situation.

But I thought DBrown's complaint was that they won't; that he was told it expires.
All they say is nope but if you submit that 8710 it will be sent back
And your applicant will have to redo the checkride.

Maybe the problem is witha lack of uniformity, like a whole bunch of other things.
 
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That would be fine also. It makes exactly as much sense for the FAA to take the view that it doesn't expire but that it's supplemented by a later logbook endorsement. It's a policy choice and like all policy choices, more than one choice can be valid; it's not a "right" and "wrong" situation.

But I thought DBrown's complaint was that they won't; that he was told it expires.


Maybe the problem is witha lack of uniformity, like a whole bunch of other things.
hmm, I assumed his complaint was with a DPE or inspector, not with the actual workings of IACRA.
 
hmm, I assumed his complaint was with a DPE or inspector, not with the actual workings of IACRA.

Could be. He did talk about it getting "kicked back" which could be that IACRA allows it but who ultimately reviews the information after the checkride doesn't. If it's a staleness of the 8710 issue along the lines that I suggested, IACRA should kick it or require an updated endorsement (but maybe it's not that smart).
 
If it's a staleness of the 8710 issue along the lines that I suggested, IACRA should kick it or require an updated endorsement (but maybe it's not that smart).
a few years back I would have bought it, but from my (admittedly limited during the last few years) experience with IACRA it's come a long way from the days when we'd print and sign paper 8710s too because IACRA didn't usually work.
 
In fact, the 8710-1 is not a regulatory creature at all. It's just an application from. It's where you list the information from your logbook that says you meet the instruction and experience requirements for the certificate or rating you're trying to get. It's just a form. Theoretically, the application could be just 3 lines:
1. Who are you?
2. Where do you live?
3. What are you applying for?​
No listed experience. No requirement to have a prior pilot certificate (even a student one). No breakdown of time to see if you meet requirements. No nothing. Heck, if you spend y,an extra $300 to have the examiner go through your logbook and fill out a checklist (since you haven't certified anything), so what?

But the FAA decided it made more sense for its record-keeping, to help out its examiners, and to keep people from wasting everyone's time and their money applying for things they are not qualified for, to have you and your instructor review your training records in advance and certify that you meet the regulatory requirements for what you are applying for.

Actually, an 8710-1 (or any other application for a certificate issued by the FAA) is driven by federal law:

49 USC, Section 44702: Issuance of Certificates

(a) General Authority and Applications.— The Administrator of the Federal Aviation Administration may issue airman certificates, design organization certificates, type certificates, production certificates, airworthiness certificates, air carrier operating certificates, airport operating certificates, air agency certificates, and air navigation facility certificates under this chapter. An application for a certificate must—
(1) be under oath when the Administrator requires; and
(2) be in the form, contain information, and be filed and served in the way the Administrator prescribes.

As for FARs, 61.13 (a) also drives the application:

§61.13 - Issuance of airman certificates, ratings, and authorizations.

(a) Application. (1) An applicant for an airman certificate, rating, or authorization under this part must make that application on a form and in a manner acceptable to the Administrator.

The "form and manner acceptable to the Administrator" in this case is an 8710-1 or 8710-11 (for sport pilot), or the IACRA equivalent.
 
Actually, an 8710-1 (or any other application for a certificate issued by the FAA) is driven by federal law:.
Of course it is. By "not a regulatory creature" I only meant that the regs did not prescribe its form and content. All government forms are ultimately driven by government law. I thought that was a given.
 
When he went to take his checkride he had

1. a signed 8710 from July of 2012

2. A signed application through iacara from his recommending CFI from July 2012

3. All appropriate endorsements also from July 2012

4. A log of all training given for the rating

5. A signed current 2 month endorsement from a different local instructor 3 days prior to the test that included log endorsements for 2 hrs ground and 1.8 flight.

why was this not adequate to take the test?

I can't find a reg that prohibits it.


I'm thinking midlife is right and this was just the opinion of the people he was dealing with.

Another DPE might have been ok with it.

Definitely wouldn't be the first time I got counterdicting opinions between FSDO's
Or even between 2 employees at the same FSDO!

I had never seen this issue or even heard of this happening so when I started digging in the regs I couldn't find anything stopping this applicant from taking the practical so I thought I would pick all your brains.

Edit:
"I totally understand that the easy fix is to just have the new CFI that did the two month endorsement sign a new 8710, I'm just trying to explore this"
 
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