Written Test Deficiency Endorsement?

[LoadMasterC141]

If I endorse a student to take a written test, and that student gets, say, a 95%, do I then have to provide an endorsement stating I have provided him instruction on his areas of deficiency?


An Example:

I have reviewed the areas of deficiency of mr john doe's knowledge exam and found him to be proficient in these areas after given flight instruction required by 14CFR 61.39(a).

If yes, where is the verbiage? It is not in AC 61-65E.

It does look like 61.139 alludes to it.....

(iii) (6) Have an endorsement, if required by this part, in the applicant's logbook or training record that has been signed by an authorized instructor who certifies that the applicant--
(i) Has received and logged training time within 60 days preceding the date of application in preparation for the practical test;
(ii) Is prepared for the required practical test; and
(iii) Has demonstrated satisfactory knowledge of the subject areas in which the applicant was deficient on the airman knowledge test; and

 

[Old Pete]

61.39a 6(iii)

(iii) Has demonstrated satisfactory knowledge of the subject areas in which the applicant was deficient on the airman knowledge test;

I would say it more than alludes to it, it seems pretty explicit to me.

I thought I read that AC 61-65E is not exhaustive of all endorsements that are required.

 

[tgrayson]

It does look like 61.139 alludes to it.....

You mean 61.39. Yes, those endorsements are needed for every checkride. As for the 95% issue, remember that you can't go for a checkride without a pass, so obviously deficient doesn't mean "failed."

As a student pilot, I made a 100% on the test, so my instructor didn't give me that endorsement. The examiner refused to give me the checkride. And my instructor left another endorsement the second time. I finally insisted that he sign every blank in the back of my logbook.

 

[Michael95U]

61.39a 6(iii)

I would say it more than alludes to it, it seems pretty explicit to me.

I thought I read that AC 61-65E is not exhaustive of all endorsements that are required.

So where do we go for the proper verbiage for the endorsement if it isn't contained within 61-65E?

 

[tgrayson]

So where do we go for the proper verbiage for the endorsement if it isn't contained within 61-65E?

The 61-65E points out these are merely examples, not required verbiages. Flight Instructors have a bit of latitude about how we write these things. Probably "I have fulfilled all the 61.39 requirements" would be good enough for that endorsement. The examiner I use just looks for the numbers "61.39".

BTW, it was the FAQ's which was a little defensive about the lack of inclusion of 61.39 in the 61-65E (and previous) document. The document clearly attempts to be comprehensive and the lack of the one endorsement that's needed for every checkride is a glaring omission, which is why most new instructors are oblivious to its existence. I'm surprised it hasn't been corrected. I guess fixing it would admit error.

 

[Michael95U]

The 61-65E points out these are merely examples, not required verbiages. Flight Instructors have a bit of latitude about how we write these things. Probably "I have fulfilled all the 61.39 requirements" would be good enough for that endorsement. The examiner I use just looks for the numbers "61.39".

BTW, it was the FAQ's which was a little defensive about the lack of inclusion of 61.39 in the 61-65E (and previous) document. The document clearly attempts to be comprehensive and the lack of the one endorsement that's needed for every checkride is a glaring omission, which is why most new instructors are oblivious to its existence. I'm surprised it hasn't been corrected. I guess fixing it would admit error.

I contacted one of my DPEs and he said there is no reference to it contained is his examiner manual. I contacted the FSDO and I am awaiting their reply. Though I have sent 5 CFI students to two different FSDO's in the last month and not one Inspector asked to see this endorsement.

 

[tgrayson]

I contacted one of my DPEs and he said there is no reference to it contained is his examiner manual.

Your examiner is not correct....I've cut and pasted the requirements from his own handbook numerous times.

It may or may not actually say "61.39", but it does list the actual endorsements. Some people include them without using the number, i.e., I have given the required training in the last 60 days and gone over the material the student missed on the knowledge test.

 

[tgrayson]

Your examiner is not correct....I've cut and pasted the requirements from his own handbook numerous times.

Here's a post I made a while back:

Here is a list of the endorsements that a DPE is supposed to look for in a Flight Insturctor candidate, from 8710.3E, Pilot Examiners Handbook. The ones bolded are the ones from 61.39:

C. Logbook Endorsement. An applicant for a Flight Instructor—Airplane or Flight Instructor—Glider rating must present a logbook endorsement from an authorized flight instructor who indicates the applicant is competent and proficient in stall awareness, spin entry, spin, and spin recovery procedures in an aircraft of the appropriate category. ​

(1) Except as provided in § 61.185(b), an applicant for a flight instructor certificate must have logged training and received a logbook endorsement on the fundamentals of instruction listed in § 61.185(a)(1).

(2) The applicant’s logbook or training record must contain an endorsement from an authorized instructor who certifies the applicant has received and logged some training within the 60 days preceding the date of the application in preparation for the practical test.
​

(3) The applicant’s logbook or training record must contain an endorsement from an authorized instructor who certifies the applicant is prepared to pass the practical test. In addition, the applicant must have a signed FAA Form 8710-1, Airman Certificate and/or Rating Application, with the authorized instructor’s signature.​

(4) The applicant’s logbook or training record must contain an endorsement from an authorized instructor that states the applicant has demonstrated satisfactory knowledge of the subject areas in which the applicant was deficient on the airman knowledge test. ​

(5) An applicant for a flight instructor certificate must have logged training and received a logbook endorsement from an authorized instructor on the training required by § 61.187(b) that is appropriate for the flight instructor rating sought. ​

 

[moxiepilot]

i agree with tgrayson. if the applicant does not get a 100%, there should be an endorsement stating that the CFI has reviewed the deficient information with the applicant and they determine that they are prepared for the practical.

For example an applicant receives a 70% theoretically showing thay are lacking 30% of important information necessary to fly. Thats 30% of rules and regs they could bust or weather they might get themselves into. The FAA wants to be sure that that does not happen which is why it is important to review those missed areas, and for purposes of CYA that it be documented

 

[Michael95U]

From the FSDO:

AC 61-65E, paragraph 10 states: Except as provided by section 61.39(c),
each applicant must have received an endorsement from an authorized
instructor who certified that the applicant received and logged the
required flight time/training in preparation for the practical test within
60 days preceding the date of the test and has been found proficient to
pass the practical test.
NOTE: The endorsement must also state that the applicant has satisfactory
knowledge of the subject areas in which he/she was shown to be deficient by
the FAA airman knowledge test report, if required.
These endorsements are required by section 61.39(a)(6)(i) and (iii).

In absence of an appropriate sample endorsement in AC 61-65E, the
following would meet the requirement.

60 day endorsement:
The examiner must review the applicant’s logbook/training records to verify
that the required amount of training occurred within the preceding 60 days.
This would not necessarily be a separate endorsement in the back of the
logbook.

Endorsement to show additional instruction was given in the subject areas
found deficient on the knowledge test:
An endorsement worded much like the statement on the knowledge test result
form or like the following would suffice: “I have given _____ additional
instruction in the subject areas found deficient on the knowledge test as
required by § 61.39(a)(6)(iii) and he/she demonstrates satisfactory
knowledge.”
NOTE: The instructor could also endorse the knowledge test result form
itself. While the knowledge test is normally endorsed to allow the
applicant to retake that knowledge test, this endorsement would also meet
the requirement of 61.39(a)(6)(iii).


Doug Jackson
Principal Operations Inspector
Kansas City FSDO

 

[tgrayson]

60 day endorsement:
The examiner must review the applicant’s logbook/training records to verify
that the required amount of training occurred within the preceding 60 days.
This would not necessarily be a separate endorsement in the back of the
logbook.

That strikes me as contrary to the regulations, the pilot examiner's handbook and the old FAQ's. But he otherwise agrees that the 61.39 endorsements are required. Be curious to know if other FSDO's are allowing examiners not to find the explicit endorsement for the 60 day training. One hair splitting problem with just looking at the training record is the ability to determine that any dual was actual preparation for the particular certificate/rating in question, since the purpose of training isn't a logging requirement.