solo endorsement question

[eliteflight]

I have a student who has already completed his first few local-area solo flights. On our first dual cross-country, he wants to fly to an airport near where his parents live, so they can come out to the airport to watch him fly. While at that airport, he would like to take a few laps around the pattern solo, while I wait on the ground with his parents.

Does he need a separate endorsement to solo at this airport? Note that he is not flying TO this airport solo, only flying AT this airport solo.

He has the basic 90-day solo endorsement, which is not airport specific. The airport-specific <25, <50, and cross-country endorsements are not appropriate, as he is not ready to fly solo cross-country yet.

So, is he covered by his existing endorsements. Or, do I need to give him another pre-solo exam and endorsement for this airport?

Thanks.

 

[shdw]

So, is he covered by his existing endorsements. Or, do I need to give him another pre-solo exam and endorsement for this airport?

From 61-65E

c. The following pre-solo requirements must be met:

(1) Before being authorized to conduct a solo flight, a student pilot must have
demonstrated satisfactory aeronautical knowledge by completion of a knowledge test (see
§ 61.87(b)). Before being authorized to conduct a solo flight, a student pilot must have received
and logged the flight training required by sections 61.87(c) and (d) through (m), as appropriate.
Satisfactory aeronautical knowledge and an acceptable performance level must have been
demonstrated to an authorized instructor, per section 61.87(b).

(2) Prior to solo flight, a student pilot is required to have his or her student pilot
certificate and logbook endorsed for the specific make and model aircraft to be flown.
Thereafter, the student pilot’s logbook must be endorsed every 90 days to retain solo flight
privileges. These endorsements must be given by an authorized flight instructor who has flown
with the student (per section 61.87(p)).

Here 61.87 (b) (ii)

Airspace rules and procedures for the airport where the solo flight will be performed

So to simply answer your question, he cannot solo at that airport without any further endorsements. It would be easiest to simply add this to his logbook:

5. Solo takeoffs and landings at another airport within 25 nm: section 61.93(b)(1).
I certify that (First name, MI, Last name) has received the required training of
section 61.93(b)(1). I have determined that he/she is proficient to practice solo takeoffs and
landings at (airport name). The takeoffs and landings at (airport name) are subject to the
following conditions: (List any applicable conditions or limitations.)


/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05

I recommend when you do your 90 day solo certificate you do it as such:

I have given Mr/Ms the flight training required by FAR 61.87(1). He/she has met
the requirements of FAR 61.87(1) and is competent to operate a (make and model of aircraft)
in day solo flight at (name of airport). This endorsement is not valid after (month, day, year).

This will prevent a student from ever using his privileges without your knowledge elsewhere or at least help to prevent it. I always add wind limitations as well ever since my solo student went up in 15G22 50 degrees off runway heading.


Links

61-65E: http://flighttraining.aopa.org/cfi_tools/pdfs/ac61_65e.pdf
CFI endorsement guide: http://home.comcast.net/~verhulst/GBSC/instructor/endorse.pdf

 

[jake.durham]

I have a student who has already completed his first few local-area solo flights. On our first dual cross-country, he wants to fly to an airport near where his parents live, so they can come out to the airport to watch him fly. While at that airport, he would like to take a few laps around the pattern solo, while I wait on the ground with his parents.

Does he need a separate endorsement to solo at this airport? Note that he is not flying TO this airport solo, only flying AT this airport solo.

He has the basic 90-day solo endorsement, which is not airport specific. The airport-specific <25, <50, and cross-country endorsements are not appropriate, as he is not ready to fly solo cross-country yet.

So, is he covered by his existing endorsements. Or, do I need to give him another pre-solo exam and endorsement for this airport?

Thanks.

Look under AC 61-65E and under student endorsements. There are two seperate ensorsements for these kinds of flights. One is a repeated cross country endorsement for airports within 50nm and the other is solo t/o and landings at an airport within 25nm.

With the 50 he needs his initial cross country endorsement, current solo endorsement, and the back of his ticket endorsed. Then you need to endorse him for the repeated 50nm cross country to that airport.

For the 25nm he just needs the logbook endorsement for that airport. I have students who use these all the time. You have to have at least one flight logged in his book in either instance to show you have flown with him to the airport in question.

That is all for solo stuff. If you are going to be there with him, however, he just needs his current solo endorsement (just what he would need to solo at his home airport) and make sure he is comfortable with airport ops at the other location. Hope this help.

 

[eliteflight]

To clarify, my student has completed his first solo at our home airport, and is properly endorsed for that. We are just now starting cross-country work, so it would not be appropriate to give him any of the 61.93 endorsements, as he is not ready to fly solo FROM one airport TO another airport.

But, he does want to fly solo AT another airport, so his parents can observe. We will be flying TO that airport together, so there is no issue regarding how he gets there.

I've been an instructor for eight years, and I'm familiar with Part 61, AC61-65, and all the solo requirements and endorsements. But, this is the first time this particular situation has come up, and none of the instructors I've talked to have encountered it either. I want to be sure my student and I are covered.

If you read 61.87(b), it simply refers to "conducting solo flight". It does not refer to "first solo" or "home airport" or anything like that, and the word "conducting" is far more inclusive than "initiating". So, if you were to take it literally, it would seem that a presolo written exam and endorsement would be required for every airport he flies to, including those he stops at on his solo cross-country flights (landing at an airport is "conducting flight"). Of course, that isn't what's required.

I know of many instructors who have their students conduct their first solo at a nearby non-towered airport (we are based at a moderatly busy towered airport), but they don't give the student another written exam and endorsement to solo at our home airport.

I believe my student is already properly endorsed to conduct a solo flight AT another airport. What I'm looking for is any first hand knowledge that would say otherwise. That first hand knowledge could be a legal opinion, a statement from a FSDO or DPE, or anything like that.

Thanks.

 

[shdw]

To clarify, my student has completed his first solo at our home airport, and is properly endorsed for that. We are just now starting cross-country work, so it would not be appropriate to give him any of the 61.93 endorsements, as he is not ready to fly solo FROM one airport TO another airport.

But, he does want to fly solo AT another airport, so his parents can observe. We will be flying TO that airport together, so there is no issue regarding how he gets there.

I've been an instructor for eight years, and I'm familiar with Part 61, AC61-65, and all the solo requirements and endorsements. But, this is the first time this particular situation has come up, and none of the instructors I've talked to have encountered it either. I want to be sure my student and I are covered.

If you read 61.87(b), it simply refers to "conducting solo flight". It does not refer to "first solo" or "home airport" or anything like that, and the word "conducting" is far more inclusive than "initiating". So, if you were to take it literally, it would seem that a presolo written exam and endorsement would be required for every airport he flies to, including those he stops at on his solo cross-country flights (landing at an airport is "conducting flight"). Of course, that isn't what's required.

I know of many instructors who have their students conduct their first solo at a nearby non-towered airport (we are based at a moderately busy towered airport), but they don't give the student another written exam and endorsement to solo at our home airport.

I believe my student is already properly endorsed to conduct a solo flight AT another airport. What I'm looking for is any first hand knowledge that would say otherwise. That first hand knowledge could be a legal opinion, a statement from a FSDO or DPE, or anything like that.

Thanks.

Reread my post, I already answered that. You are not covered with the initial solo endorsement because you have not signed him of for the airport you are signing him off for. This means your knowledge endorsement is only applicable to the airport where you signed him off for the solo.

Again I doubt they would care either way but it is safer to just give him the within 25NM endorsement (if it is) and if it isn't just take 60 seconds to write the knowledge and solo endorsement for that other airport. It really isn't that complicated just put the endorsement, better safe than sorry.

To beat it in and to re-quote myself this is why it is not legal.

Here 61.87 (b) (ii)

Quote:
Airspace rules and procedures for the airport where the solo flight will be performed

Your other CFIs are in the wrong for using one endorsement unless that endorsement states both airports that the student may solo at. If not then per 61.87 (b) (ii) they are not legal unless they have a knowledge test for each airport of intended solo.

 

[tgrayson]

Reread my post, I already answered that.

Actually, you only speculated, although you stated it as fact.

 

[shdw]

Actually, you only speculated, although you stated it as fact.

Explain what I speculated about here please? This is what we were taught at the college and had "for the airport" beat into us to make sure that we didn't do this exact scenario. So my speculation was from my aviation law class and in fact wasn't speculation it was a correct interpretation of what I believe to be a fairly straight forward regulation.

If you sign someone off for solo at airport X he cannot solo to any other airport unless he has another endorsement for that airport. That endorsement could be the 50/25NM endorsements or it could be an addon to the original endorsement if it is for the scenario given. But you must have a knowledge endorsement for each airport of intended solo otherwise your not covered.

 

[tgrayson]

But you must have a knowledge endorsement for each airport of intended solo otherwise your not covered.

You keep saying that, but have no evidence that your interpretation is correct. To my knowledge, the FAA has never stated that position, either in the old Part 61 FAQs or letters of interpretation, and there were plenty of opportunities to bring up multiple pre-solo exams.

While there is certainly an argument to be made for your interpretation, unless the FAA agrees with it and says so, your position is only an argument.

Anyone else here administering multiple pre-solo exams?

 

[eliteflight]

Reread my post, I already answered that.

No, you didn't. You quoted 61.87 and 61-65E extensively, then offered your personal interpretation.

...it is safer to just give him the within 25NM endorsement (if it is) and if it isn't just take 60 seconds to write the knowledge and solo endorsement for that other airport. It really isn't that complicated just put the endorsement...

Please re-read MY first post. The student is not ready to make solo cross-country flights. The title of 61.93 is "Solo cross-country flight requirements" -- the title of each section is important, as it defines the scope of that section. All the endorsements listed therein authorize solo cross-country flights, including the "within 25NM" and "not more than 50NM" endorsements. I don't know why this keeps coming up -- I'm not endorsing the student for cross-country flights at this point.

Of all the requirements listed in 61.87, the only one that is airport-specific is the knowledge test itself. Using the language recommended in 61-65E, none of the 61.87 solo endorsements are airport-specific. Even if they were, I could not simply "take 60 seconds" to write a new endorsement -- I would have to administer and review a new knowledge test before writing a new knowledge endorsement.

(As a side note, the pre-printed knowledge endorsement in the Jeppesen student logbook does not follow the 61-65E guidance, and states that the exam was written, and lists the specific airport in the endorsement.)

This is what we were taught at the college... So my speculation was from my aviation law class and in fact wasn't speculation it was a correct interpretation of what I believe to be a fairly straight forward regulation.

You sure do place a lot of faith in your college professors and your eight months of experience as a CFI. I hope you realize that your college professors are not the FAA, and that the argument "but that's what I learned in college" won't hold up in an administrative law hearing. This is not meant as an insult, but rather as a friendly word of caution.

You and your aviation law professor may be correct. But, I would want to see authoritative written evidence to support that. Is there any?

Now, getting back to the actual question at hand:

The regulation is anything but straighforward. The only airport-specific requirement is 61.87(b)(ii), which states that the knowledge test must include "airspace rules and procedures for the airport where the solo flight will be performed".

The requirement for the knowledge test was added back in 1997. I believe the intent was for it to be a single, pre-first-solo written exam, meant to be an additional check of readiness for solo flight. However, that's my interpretation, which is no better than anyone else's.

In truth, the regulation says nothing about single or multiple exams, does not reference the concepts of pre-solo, first-solo, or additional solo flights, does not distinguish between the "airport where the solo flight will be performed" and the student's home airport, does not limit the requirement to only airports from which local-area solo flights will be initiated, does not exclude airports the student will visit on solo cross-country flights, and doesn't even say that the exam has to be in written form. It doesn't need to address all that specifically, but it is missing a few clarifying words.

So, as I said before, a literal reading of this section would imply that a new knowledge exam is required for every airport at which a student performs solo flight. This would include every airport they visit on solo cross-country flights, as the regulation places no limits on which airports the requirement applies to. Of course, that isn't done in practice.

I should have made my initial question more explicit, but I didn't think it was necessary: I'm not looking for personal interpretations or "better safe than sorry" solutions -- I can get plenty of that without posting on-line. What I want is to learn from people who have first-hand experience in this grey area, who have hopefully received guidance from a higher authority -- FAA legal opinion, congressional record preamble to this section (which often contains clarifying explanations), FSDO opinions (I know they can be inconsistent, but at least its a start), enforcement actions, and so on.

Maybe none of that exists. Does anyone know how to submit a request for a legal opinion from the FAA?

 

[MidlifeFlyer]

Maybe none of that exists. Does anyone know how to submit a request for a legal opinion from the FAA?

I'm pretty sure none exist.

To write to FAA Legal:

Regulations Division
Office of the Chief Counsel
800 Independence Avenue SW
Washington, DC 20591

Don't expect an answer within the time frame you seem to be talking about.

In the FWIW department:

First solo at a second airport was pretty common at one time at my home base. We are a busy towered airport and there was a non-towered field not far away. Some instructors chose to do a first solo at the non-towered field and then a second one at home. I'm pretty sure that the way they handled it was to have questions about both airports on the presolo exam.

But that's not your situation since this wasn't all planned in advance.

You already said you don't want it, so this is for the purpose of discussion with the others:

My personal take is that, until dealing in the context of one of the other solo endorsements that involve going somewhere else, you need to comply with 61.87(b)(1)(ii) and quiz on local operations. A written test on each airport in the cross country context isn't required because the training requirements for the cross country endorsements pretty much require that the information has been covered.

I don't think the "solo at the airport where we flew together" flight needs a new endorsement, but just a brief written quiz that covers local procedures at the airport as an addendum to the one you already have. Right or wrong, if I were in that situation, it's precisely what I would do in the absence of some official guidance. It's quick, simple, and doesn't cover anything the student should not already know (if he prepared for the dual cross country properly).

 

[shdw]

You keep saying that, but have no evidence that your interpretation is correct. To my knowledge, the FAA has never stated that position, either in the old Part 61 FAQs or letters of interpretation, and there were plenty of opportunities to bring up multiple pre-solo exams.

While there is certainly an argument to be made for your interpretation, unless the FAA agrees with it and says so, your position is only an argument.

Anyone else here administering multiple pre-solo exams?

Ok thank you for clarifying what you were going for with that and sorry if my reply sounded snappy. I was going by what our aviation law professor told us and I figured he would have done this portion of the research before making a statement as such.

I should note, he didn't say you need to retake the entire pre-solo exam. He simply said you should ask a few questions about the new airport then give them an endorsement because that guarantees you are covered per this regulation.

This to me just sounds like a whole lot of work and a ton of worry for the savings of about a minute to write a 30 word endorsement that would guarantee your legal safety.

 

[eliteflight]

You already said you don't want it..

I apologize if my last post implied that I didn't want advice or opinions. Most of that post was in reply to a particular individual, and I didn't give proper consideration to how others would read it. My bad.

What I should have said was this: I welcome advice and opinion, particulary from the many experienced CFIs here, as long as it's stated as such. What I don't want is opinion stated as fact, followed by an argument about how "it is too fact" because someone else's opinion makes it so. Statements like those always seem to steer the thread away from a productive discussion.

In the case of this particular student, I will take the safe path, and will give him a supplemental written exam on the new airport. And, because I foolishly used the pre-printed knowledge endorsement in his Jeppesen logbook, I will have to give him another knowledge endorsement, but this one will be hand-written, and will use the non-airport-specific language from 61-65E. (And, I will hand-write this endorsement for all future students using that logbook. Lesson learned: Don't trust pre-printed endorsements.)

To summarize the outstanding questions:

* Where does it say the knowledge exam must be written? (Mine are, because I want a written record of the exam.)

* Where does it say that a knowledge exam is required for airports other than the first-solo airport? (I think a strict reading of 61.87(b) says so, but I also think the intent was only for a single presolo exam.)

* If more than one knowledge exam is required, where does it say that the cross-country airports are exempt? (I think they are exempt, but not because the cross-country the training requirements cover the knowledge, rather, because the intent was for a single exam.)

I could be totally wrong about all of this. But, I'd like an official answer. So, I will draft a letter to the FAA. I know it will be a long time before that produces any results, if any, so I will also see if someone at the FSDO is willing to discuss the issue, and I will also send the question to a 25+ year DPE I know.

If any of these produce answers, I'll post the results here.

 

[eliteflight]

I was going by what our aviation law professor told us and I figured he would have done this portion of the research before making a statement as such.

He/she was probably taking the "safe path" by giving the students advice he felt would keep them covered legally. I would do the same, but I would also make it clear that this is a grey area, and that my "safe path" recommendation is just an opinion, and not a regulation.

The problem is, without clear guidance, those "better safe than sorry" answers may not actually be any safer. Put yourself in the mindset of an FAA inspector, or an adminstrative law judge, who is out to make an example of some poor CFI. If it isn't exactly right, it's completely wrong. One can never be too careful when it comes to compliance with the regulations, especially where endorsements and logbooks are concerned, and that's why I was hoping someone had some "higher authority" guidance.

I wish "Doc's FAR Forum" were still around. He always seemed to be able to dig up the extra guidance that no one else could find.

 

[CoffeeIcePapers]

I wouldn't be surprised if the FSDo, FAA legal, and DPE all have different answers.

 

[MidlifeFlyer]

* Where does it say the knowledge exam must be written? (Mine are, because I want a written record of the exam.)

It doesn't. It can be computerized.

==============================
61.1(b)(11) Knowledge test means a test on the aeronautical knowledge areas required for an airman certificate or rating that can be administered in written form or by a computer.
==============================

* Where does it say that a knowledge exam is required for airports other than the first-solo airport? (I think a strict reading of 61.87(b) says so, but I also think the intent was only for a single presolo exam.)

* If more than one knowledge exam is required, where does it say that the cross-country airports are exempt? (I think they are exempt, but not because the cross-country the training requirements cover the knowledge, rather, because the intent was for a single exam.)

I could be totally wrong about all of this. But, I'd like an official answer. So, I will draft a letter to the FAA. I know it will be a long time before that produces any results, if any, so I will also see if someone at the FSDO is willing to discuss the issue, and I will also send the question to a 25+ year DPE I know.

If any of these produce answers, I'll post the results here.

You forgot one:

* Where does it say that you have to endorse the taking and passing of the knowledge test?

 

[shdw]

He/she was probably taking the "safe path" by giving the students advice he felt would keep them covered legally. I would do the same, but I would also make it clear that this is a grey area, and that my "safe path" recommendation is just an opinion, and not a regulation.

He is a 20 year aviation lawyer who told us the legal interpretation of that FAR and advised us as such. He may not be the FAA, but it is by far the best advice I have heard/read in this area on this specific topic and I would say a fairly credible source, my opinion of course. So you can take this however you want, but I will stake my ticket on the advice of a lawyer for aviation until a case study/government document states otherwise.

There is most likely nothing out for this because it is not part of a common training scenario.



Also:

Even if they were, I could not simply "take 60 seconds" to write a new endorsement -- I would have to administer and review a new knowledge test before writing a new knowledge endorsement.

I certify that (First name, MI, Last name) has satisfactorily completed the presolo knowledge
exam of section 61.87(b)(ii) for the (make and model aircraft) at (airport).

I cannot imagine this taking much over 30 seconds and it certainly does not require a full repeat of the knowledge test. You must simply edit the section you are claiming him competent for since you are not checking the other information on this new date (which I presume is why you think you need to redo the entire test).

You sure do place a lot of faith in your college professors and your eight months of experience as a CFI.

Thinking like this has killed many an airline captain sir. "This is not meant as an insult, but rather as a friendly word of caution."

 

[tgrayson]

A written test on each airport in the cross country context isn't required because the training requirements for the cross country endorsements pretty much require that the information has been covered.

But that isn't a test, so it doesn't meet the letter of the law in 61.87(b). I agree with eliteflight's interpretation...if you're going to apply this regulation outside the arena of the first solo flight only, then it would have to be applied for *every* airport of solo operation and every aircraft model the student will solo.

I don't gather that's what the FAA really intended, but the regulation doesn't make that clear.

 

[tgrayson]

He is a 20 year aviation lawyer who told us the legal interpretation of that FAR and advised us as such.

He probably gave you his opinion, since he doesn't likely have the FAA's. If there had been a FAA interpretation issued, Midlifeflyer and I would likely have a copy it.

 

[eliteflight]

He is a 20 year aviation lawyer who told us the legal interpretation of that FAR and advised us as such.

Does he have a written interpretation from the FAA or other government authority? If not, his legal interpretation is just a personal opinion. On the other hand, if he has a written interpretation, please get a copy and share it with us.

I cannot imagine this taking much over 30 seconds and it certainly does not require a full repeat of the knowledge test.

I never said anything about repeating the entire test. But I did say the additional test (which can be just a few questions about the new airport), the review of the answers with the student, and the new endorsement, will all take more than 30 or 60 seconds you have mentioned more than once.

Thinking like this has killed many an airline captain sir.

Huh? Please clarify what the phrase "thinking like this" refers to, and how it has killed many airline captains.

 

[eliteflight]

It doesn't. It can be computerized.

D'oh! I failed to check the definitions.

* Where does it say that you have to endorse the taking and passing of the knowledge test?

Excellent point. 61-65E contains recommended language for such an endorsement, but I have been unable to find anything in the FARs requiring it.