Tailwheel endorsement

[TwoTwoLeft]

How about this. Student soloed in a Super Cub. Instructor signed the back of his medical. Takes checkride in Super Cub. Does he still need a tailwheel endorsement? Examiner told me no. Same as if he took checkride in C182, no hp endorsment needed?

Your DPE is correct.

Instructors don't endorse medicals, they endorse student pilot certificates. That same piece of paper is two separate legal documents. The student pilot certificate and medical portion may expire, but the make and model endorsements never do. That's why the CFI or student should never discard an expired medical/student pilot cert. Those endorsements and dates mean something, and are still relevant.

The make and model endorsement on the student pilot cert, the training logged under 61.87(c&d) and initial solo endorsements in the logbook all make up the authorization for the student to act as PIC with student limitations.


Edited to include 61.87(c&d)

 

[WS]

I see what you are saying there, but I disagree.

An Cessna 185 sitting on amphibious floats is NOT configured to be a tailwheel airplane, however it IS still the same MAKE and MODEL as a Cessna 185 on conventional gear is it not? Could in fact be the same airplane in a different configuration. While I would say that this scenario is highly unlikely, you could endorse some rich dude to solo his shiny 185 on those amphibious floats (no water landings as a limitation?), then he could later rip them off without your knowledge and go back to the tailwheel configuration where he would require the additional training and in my opinion the endorsement, but yet still be flying the same make and model aircraft.

By your logic, if I gave all the training required of 61.87(d), endorsed and soloed them, I would NOT be required to teach Wheel landings which are required by 61.31. I really doubt that the FAA doesn't think that needs to be covered just because the student is soloing.

At any rate, I fail to see why you wouldn't just give them the endorsement before soloing them as cheap insurance.

(i) Additional training required for operating tailwheel airplanes.
(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:

• • 
    (i) Normal and crosswind takeoffs and landings;
    (ii) Wheel landings (unless the manufacturer has recommended against such landings); and
    (iii) Go-around procedures.
  (2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.
  
  

 

[WS]

How about this. Student soloed in a Super Cub. Instructor signed the back of his medical. Takes checkride in Super Cub. Does he still need a tailwheel endorsement? Examiner told me no. Same as if he took checkride in C182, no hp endorsment needed?

Your DPE is correct.

Instructors don't endorse medicals, they endorse student pilot certificates. That same piece of paper is two separate legal documents. The student pilot certificate and medical portion may expire, but the make and model endorsements never do. That's why the CFI or student should never discard an expired medical/student pilot cert. Those endorsements and dates mean something, and are still relevant.

The make and model endorsement on the student pilot cert, the training logged under 61.87(d) and initial solo endorsements in the logbook all make up the authorization for the student to act as PIC with student limitations.

The student taking a check-ride with a DPE has to be the pilot in command. If he is the PIC with the examiner on board, he is not solo and I fail to see how that endorsement would be valid without a HP or Tailwheel or whatever applied to that aircraft. Also, it is a student pilot endorsement which in my opinion would no longer apply once the student became a private pilot. Even if it did, the student would have done all of their training in that aircraft make and model, but never received the HP/Tailwheel/Whatever endorsement to do anything other than fly solo in it? That makes no sense.

I could be wrong about this, it has happened before, but I still don't see how it makes any sense to not give them the applicable endorsement, and see no clear guidance that says it is NOT required.

 

[TwoTwoLeft]

Here it is... It's in 61.87(c)

(c) Pre-solo flight training. Prior to conducting a solo flight, a student pilot must have:

(1) Received and logged flight training for the maneuvers and procedures of this section that are appropriate to the make and model of aircraft to be flown; and....


This is where the instructor is required to include additional Tailwheel, complex, or high performance training requirements. If you read 61.31 these are all classified as "additional training". Additional, as in not covered initially... The endorsement is given to certify the satisfactory completion of the additional training.

61.31 outlines the training that need to be done and 61.87 applies it to the student pilot.


(i) Additional training required for operating tailwheel airplanes.

(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person’s logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:

(i) Normal and crosswind takeoffs and landings;

(ii) Wheel landings (unless the manufacturer has recommended against such landings); and

(iii) Go-around procedures.

(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.



The additional training appropriate to make and model required under 61.87(c) is outlined in 61.31(i). "received an endorsement in the person’s logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane"
What kind of endorsement or the language is not specified in the regs. With a student, you are in fact endorsing them when you endorse them for solo. Everyone asks, " How can a student be PIC with out an endorsement"? Well, they can't. And they do have an endorsement that allows them to act as PIC. If the training was in a Tailwheel, then the additional training outlined in 61.31(i) needs to be completed and logged as well. The endorsement is there, it's just not the typical "Tailwheel Endorsement" you would write. The initial solo endorsement meets the requirement of having an endorsement per 61.31(i).


As for the what happens after the checkride? The student has the training logged and the make and model solo endorsement in their logbook.



Trust me, I know this. And it's a very common mistake with CFIs. It's been almost 10 years now but part of my CFI checkride was to prove this to the FAA inspector. I'm just going off memory and don't have my notes. Do you know why I had to prove it? Because I don't have a complex endorsement after 9/4/97.

 

[MidlifeFlyer]

Trust me, I know this.

Would it be ok with you if I trusted my reading of the FAA Chief Counsel's office 2010 Grayson letter (some folks here will remember Taylor) instead?

Your analysis is sound except for one small thing. The FAA has historically shown a dislike for implicit endorsements or meeting of requirements. "OK to solo" for example, is not a sufficient endorsement for student solo flight, even if a detailed review if the logbook shows all requirements are met. Vectors that bring a VFR pilot in the direction of Class B are not an implicit clearance into the Class B.

Just think. In the time you took to write that detailed analysis you could have simply written the endorsement for the student pilot's logbook.

BTW I'm not sure what not having a complex endorsement after 1997 has to do with the price of tea in China. I don't have one either. In fact I don't have a "complex" endorsement at all. But in my case, and I expect yours, there's specific language in the FAR that says I don't need it.

 

[ahw01]

We really like to debate the minutiae here. Just give them all the endorsements. Isn't that better than having to call the FSDO/invoke FAA legal to save some ink?

 

[MidlifeFlyer]

We really like to debate the minutiae here. Just give them all the endorsements. Isn't that better than having to call the FSDO/invoke FAA legal to save some ink?

Debating the minutiae of the regs has educational value. "Understanding" and "correlation" (this is the CFI Corner after all) of questions about any rule might help us understand other FAA rules that are more significant.

But I agree with your bottom line that it's better to give the endorsements.

If the "minutiae" for the tailwheel requirement said, for example [modifying 61.3(i)(2)] said, for example

The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991, or held a student pilot solo endorsement for a tailwheel make and model of aircraft.​

.
you probably wouldn't want to bother. But it doesn't, so (even without the FAA Counsel opinion that it needs to be done), providing the endorsement is the obvious better practice for the instructor. Even if I felt as TwoTwoLeft did, I would be hesitant about putting my student at future risk of needing to justify something that would have taken all of 30 extra seconds to make clear while I was writing endorsements anyway.

 

[ahw01]

I love aviation because we get into such detail about this and want to do it right. It's a shame so much isn't cut and dried.

I need my tailwheel, so will keep all this in mind!

 

[TwoTwoLeft]

Would it be ok with you if I trusted my reading of the FAA Chief Counsel's office 2010 Grayson letter (some folks here will remember Taylor) instead?

Your analysis is sound except for one small thing. The FAA has historically shown a dislike for implicit endorsements or meeting of requirements. "OK to solo" for example, is not a sufficient endorsement for student solo flight, even if a detailed review if the logbook shows all requirements are met. Vectors that bring a VFR pilot in the direction of Class B are not an implicit clearance into the Class B.

Just think. In the time you took to write that detailed analysis you could have simply written the endorsement for the student pilot's logbook.

BTW I'm not sure what not having a complex endorsement after 1997 has to do with the price of tea in China. I don't have one either. In fact I don't have a "complex" endorsement at all. But in my case, and I expect yours, there's specific language in the FAR that says I don't need it.

No one is saying "ok to solo" is an acceptable endorsement. A proper solo endorsement meets the requirements of an additional training endorsement in 61.31. Provided that training was given.

All 61.31 says is the you must receive additional training and an endorsement. Where you are in your training (student vs certificated pilot or pilot training for an additional class rating who is yet unable to act as PIC) is where the CFI has to correctly determine which endorsement is appropriate.

The general counsel's response in the Grayson letter is simply stating the additional training must be done along with an endorsement. It reads just like 61.31(e-k).

This may be a local thing, but out of the three DPEs in my area this endorsement:

“I certify that (Pilot’s Name), (Pilot’s Certificate), (Pilot’s Certificate Number), has received the required training of section 61.31(i) in a (make and model tailwheel airplane). I have determined that he/she is proficient in the operation of a tailwheel airplane.”

Is not required if a student pilot was signed off to solo in a Tailwheel because this meets the same requirement:

I certify that {First Name, MI, Last Name} has received the required pre-solo training in a {make and model aircraft}. I have determined that {he/she} has demonstrated the proficiency as required by §61.87(d)( {subsections d through m as appropriate*} ) and is proficient to make solo flights in a {make and model aircraft}.


If a CFI wants to throw in a bunch of extra endorsements, then go ahead.. I've soloed plenty of Tailwheel students this way and never had a problem with a DPE or FSDO. In fact, this is one of the topics our local DPE goes over in mock checkrides for CFI applicants.

 

[MidlifeFlyer]

N

This may be a local thing, but out of the three DPEs in my area this endorsement:

...and right there is the problem. DPEs often don't have special knowledge of the rules and regulations. And the "local thing" makes it worse for the pilot who, years later, has his authority questioned in the wrong situation.

I'm pleased you are willing to opine that the 61.31 endorsements are implied in the 61.87 endorsements. OTOH, the inference I'm going to make is that the Chief Counsel's office knew very well the question

You have asked whether student pilots and checkride candidates are thus required to obtain the additional training and endorsements for the aircraft designated in § 61.31(e) through (j) before they may act as pilot in command of those aircraft​

involved student pilots and checkride candidates with 61.87 endorsements when they answered

student pilots and checkride candidates are required to comply with the additional training requirements and hold the appropriate endorsements prior to acting as pilot in command of the aircraft designated in § 61.31(e) through (j).​

It's really not so much a solo or checkride issue as an issue for the future. Three years down the line the student gets into a tailwheel accident and either the FAA or the pilot's insurer doesn't share your or your DPEs opinion. Even if the pilot manages to win, that's a lot of aggravation and expense for avoiding 20 seconds of extra writing.

 

[TwoTwoLeft]

But this issue originated with the operations inspectors at the FSDO, not the DPEs... None of our DPEs will throw out an applicant because they have the endorsement. It's just under agreement that it is not necessary.

 

[WS]

I suppose the regulations could be interpreted differently depending who is reading them, which would also include different inspectors at a different FSDO. I'm not willing to take that chance with my certificate or my students, and if any of those endorsements apply, the student gets them.

Besides, if you only endorse them for the make and model airplane, even though you have argued that it would include that tailwheel training, I feel it would be irresponsible to put my student in the position of possibly having to try to explain to an FAA inspector that his student pilot certificate endorsement satisfies his tailwheel endorsement years down the road, especially if they are in a different make and model tailwheel aircraft.

If you don't want to give them that endorsement, that's your call. I hope you or anyone you endorse never runs into an inspector that disagrees with you. It still just seems silly not to specifically endorse them for a tailwheel and avoid all of this. Just the fact that we are all debating this leads me to believe it would lead to problems in many cases.

 

[MidlifeFlyer]

But this issue originated with the operations inspectors at the FSDO, not the DPEs... None of our DPEs will throw out an applicant because they have the endorsement. It's just under agreement that it is not necessary.

I would actually prefer you were right. It obviously makes sense. And maybe your FSDO is correct. But the risk/reward just isn't there.

To support the bottom line for both of us, the orphaned Part 61 FAQ agrees with your FSDO (which is probably where it comes from). But there's a caveat, which, as I said before, makes the 20 seconds worth it.

The endorsements on a student pilot’s certificate and associated logbook/training record per Subpart C - Student Pilots [§§ 61.81 through 61.95] provided the authorization for flight of aircraft by category and make & model. The endorsements per § 61.31 are not required for student pilot solo operations as authorized 61.31(k)(2)(ii). The endorsements, as appropriate, become required as soon as the student pilot passes a practical test and is issued a recreational or higher pilot certificate. (my emphasis)​

So, assuming this is the rule (and I have my doubts the Chief Counsel's office world agree), the implicit endorsement is only valid until the checkride is complete. So, after the checkride, the student can't simply go fly without getting the endorsement.

Not much value in that compared with the extra 20 seconds of including the endorsement as part of the solo sign-off. I've known students who have taken checkrides at airports other than their home base. Can you imagine? The flight home after passing the checkride is a FAR violation!

And yes, that makes absolutely no sense whatsoever. Either the 61.31 endorsement is implicit in the solo endorsement or it isn't. If it is, why the need for the endorsement after passing the checkride? The make & model logbook endorsement should suffice.

 

[USMCmech]

Besides, if you only endorse them for the make and model airplane, even though you have argued that it would include that tailwheel training, I feel it would be irresponsible to put my student in the position of possibly having to try to explain to an FAA inspector that his student pilot certificate endorsement satisfies his tailwheel endorsement years down the road, especially if they are in a different make and model tailwheel aircraft.

If you don't want to give them that endorsement, that's your call. I hope you or anyone you endorse never runs into an inspector that disagrees with you. It still just seems silly not to specifically endorse them for a tailwheel and avoid all of this. Just the fact that we are all debating this leads me to believe it would lead to problems in many cases.

Ditto,

It's not like you are exposing yourself to any added liability by endorsing them.

 

[lhornaday]

I've used the FAA interpretation that MidlifeFlyer mentioned. If there is something more recent I am unaware.

"Student pilots and checkride candidates are required to comply with the additional training requirements and hold the appropriate endorsements prior to acting as pilot in command" Grayson 2010

It doesn't make sense to combine the tailwheel endorsement with an initial solo which is make and model specific. It would be useless later when you want private pilot privileges.