well with in his right to ask the questions he did.
Read the following FAQ's and legal interps and see if you still think so. They're pretty explicit about
ONE checkride for
ONE rating renewing them all. There is no mention anywhere of incorporating tasks from other checkrides.
<<Lawyers would also have a field day with him.>>
Skeptical. The examiner never testifies to your proficiency, he just says you met PTS standards. Any potential liability is greater if he deviates from the PTS because then he is
instructing, and that's forbidden by the FAA.
Letter of interp
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ANSWER: Ref. § 61.199(a); Yes, it is permissible for a flight instructor certificate to be reinstated on the basis of an applicant accomplishing an additional flight instructor rating practical test.
Answered by the FAA’s Donald P. Byrne, Assistant Chief Counsel, Regulations Division
July 14, 2000
Ms. Kathy Minner
Technical Specialist
Aviation Services Department
Aircraft Owners and Pilots Association
421 Aviation Way
Frederick, MD 21701-4798
Dear Ms. Minner:
This is in response to your letter dated February 4, 2000, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding section 61.199(a) (14 CFR section 61.199(a)). Specifically, you are concerned about the reinstatement of expired flight instructor certificates and ratings.
As you point out in your letter, section 61.199(a) provides, in pertinent part, that the holder of an expired flight instructor certificate may exchange that certificate for a new certificate with the same ratings by passing a practical test for one of the ratings listed on the expired flight instructor certificate. (Emphasis added)
You also point out in your letter that the General Aviation Inspector’s Handbook provides, in pertinent part, that the holder of an expired flight instructor certificate may have all ratings on the certificate reinstated by satisfactorily completing a single practical test.
You think the General Aviation Inspector’s Handbook indicates that “any” practical test for a flight instructor certificate or rating would reinstate the expired flight instructor certificate and all the ratings on it. Based on that, you don’t think that the holder of an expired flight instructor certificate is limited to taking a practical for one of the ratings listed on the expired flight instructor certificate to reinstate it as provided for under section 61.199(a). Accordingly, you ask “may a flight instructor reinstate an expired flight instructor certificate by taking any practical test for a flight instructor certificate or rating, or must it be confined to one of those listed on the expired certificate as it seems to state in the regulation.” The answer to this question is discussed below.
Section 61.199(a) applies when the holder of an expired flight instructor certificate only seeks to have that certificate reinstated with the same ratings. It has been the policy of the Flight Standard Services (AFS-800), as articulated in the General Aviation Inspector’s Handbook, to allow the holder of an expired flight instructor certificate who seeks an additional rating to one of those listed on the expired certificate, to reinstate the expired flight instructor certificate, and all the ratings on that expired certificate, by taking, and passing, a practical test for the additional rating sought. As a result, the holder of an expired flight instructor certificate may have that certificate and all of the ratings listed on it reinstated by taking, and passing, any practical test for a flight instructor certificate or rating.
I hope this satisfactorily answers your question.
Sincerely,
/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division
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FAQ's
{Q&A-387}
QUESTION: 61.199(a) states that an expired CFI may be exchanged (reinstated) by passing a practical test prescribed in 61.183(h). After reading 61.183(h)
one could conclude it to mean that a practical test is required for each rating.
ANSWER: One test renews all. There was no change intended. However, FAA Order 8700.1, Vol 2, Chapter 11 is my next project to rewrite to clarify this matter
{Q&A-13}
QUESTION: For example, a person holds a flight instructor certificate with the following ratings: Airplane Multiengine, Airplane Single-engine, Glider, Rotorcraft-Helicopter, Instrument-Airplane and Helicopter. The certificate expired on July 30 ,1997. And today is September 2, 1997. Does the rule allow for satisfactory completion of one practical test to renew for all the ratings? For example, does the rule allow for completion of a
Flight Instructor-Airplane Singe Engine [note absence of Instrument or multi] practical test in a Cessna 152 and a satisfactory completion of that practical test renew all the person’s flight instructor ratings?
ANSWER:
Yes, completion of
one practical test allows an exchange (re-instatement of) for all the person’s flight instructor ratings. Review the new § 61.199(a) which states:
(a) Flight instructor certificates. The holder of an expired flight instructor certificate may exchange that certificate for a new certificate by passing a practical test prescribed in § 61.183(h) of this part.
Read the words “. . . by passing a practical test . . .” It doesn’t say multiple practical tests, it says “. . . by passing a practical test . . .” In this case “a” means one.
However, this applies to the Flight Instructor certificate and ratings that were issued after November 1, 1975. If a person holds one of the old flight instructor certificates and ratings that was issued prior to November 1, 1975, review Order 8700.1, page 11-3, paragraph 13.
{Q&A-50}