SFAR 73 Flight Instructor Endorsement - Help Me Interpret the reg.


Just another CFI
I'm trying to figure out the CFI Endorsement for SFAR 73, and wether or not it requires flight for the endorsement. As I read it I don't see a codified requirement for a flight at the time the endorsement is given. It looks like a verification of training records by a DPE would be enough to satisfy the section, but maybe you all have a better answer for me, the one that I think is catching me right now it (5)(iii) so it is in bold below. Here's what I've got:

SFAR 73 (5)(i) requires that the Instructor have completed SFAR training. (My interpretation is that the current SFAR 73 training and endorsement satisfies this, all Robby pilots should have this and be current)

SFAR 73 (5)(ii) are the flight hour requirements. (My interpretation on this is that no additional flight is required unless a CFI doesn't have the minimum hours specified here.)

SFAR 73 (5)(iii) requires completing training in the R22, R44, or both in enhanced autos, low rotor rpm, no governor. The specific language in the reg is "has completed flight training..." (If the DPE has already flown with you, and these areas were a part of those flights, and your training logbook shows this flight training and experience, do you have to go up and re-demonstrate the skills, or can the DPE sign the endorsement based on the training record and experience of previous flights?)

SFAR 73 (5)(iv) just requires the endorsement showing training and experience from an FAA or DPE.

Would really appreciate the collective take on this. Thanks.
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SFAR 73 5(iv) Has been authorized by endorsement from an FAA aviation safety inspector or authorized designated examiner that the instructor has completed the appropriate training, meets the experience requirements and has satisfactorily demonstrated an ability to provide instruction on the general subject areas of paragraph 2(a)(3) of this SFAR, and the flight training identified in paragraph 2(b)(5)(iii) of this SFAR.

You have to demonstrate the ability to instruct the SFAR 73 requirements. While there's nothing there saying it has to be in the aircraft, you'd be hard pressed to find a DPE that'll sign his name to you going out to teach Low Rotor RPM with a brand new student without making damn sure you can actually roll the throttle down without drooping to a rotor stall.

I just got my CFI in an R-22 in August, so if you have any other questions, let me know.
I'm already a CFI too man, I was just having the conversation with a few other CFI's, a DPE, and a couple owners, and we tend to have a 50/50 split on interpreting the regulation. Half of us think that the legalese used allows for previous flight experience in the R22/R44 to satisfy the requirements - that a review of your SFAR currency and training, or familiarity (say - if the DPE is also one of the CFI's you've trained with or know) would meet the SFAR73 requirements for the CFI endorsement. Even the part you've bolded above doesn't expressly state that the demonstration has to occur during a separate examination specific to a CFI endorsement, and the wording doesn't state that the previous flight experience doesn't satisfy that requirement.

The only time I think an entire flight itself would be needed would be if an instructor was transitioning onto the Robinson platform, and had to do an entire SFAR checkout and transition anyways.
I think everyone is saying the same thing using different words. IF a DPE puts his name on the line through whatever judgment that person uses, then the regulatory requirement has been met.

What the DPE wants to set as a standard is up to the DPE. What liability exposure everyone is willing to take is another aspect, but that isn't part of the regulation.

In your group conversation, what was the DPE's view?
Two DPE's, both of them owners of two different schools in two different states and both of them with two different opinions. The one I know better was of the opinion that a flight was required. The one that has the most Robinson experience is the one from another state and his opinion was that so long as there is verifiable proof of training or familiarity that a sign off could be done without a flight.
I guess it's more...do you really want to argue law with the FAA in the event something ever went wrong. Though, I'm sure they have varying opinions on the interpretation too at this point.
I guess it's more...do you really want to argue law with the FAA in the event something ever went wrong. Though, I'm sure they have varying opinions on the interpretation too at this point.

I think you really hit at the essence of a lot of legal discussions. Just to use 14 CFR 91.13(a) as an example; where is the fuzzy line between careless and not careless? It's somewhere in the judge's mind and no two judges are exactly alike. Then you have to throw in "how well is your case being presented to that judge". The prudent person will approach decisions in a manner that would leave any doubt in any judge's mind that they were being careful.
If you do not have the 50 in the 22 it's moot. If you have the time requirements and need to go to the Robbie (extortion) Course (if you plan to instruct, you pretty much have to go) you can get the endorsement as part of that training.