Class D, C endorsements - recommendations?

[SportPilot]

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[3Dreaming]

§61.94 Student pilot seeking a sport pilot certificate or a recreational pilot certificate: Operations at airports within, and in airspace located within, Class B, C, and D airspace, or at airports with an operational control tower in other airspace.
(a) A student pilot seeking a sport pilot certificate or a recreational pilot certificate who wants to obtain privileges to operate in Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower, must receive and log ground and flight training from an authorized instructor in the following aeronautical knowledge areas and areas of operation:

(1) The use of radios, communications, navigation systems and facilities, and radar services.

(2) Operations at airports with an operating control tower, to include three takeoffs and landings to a full stop, with each landing involving a flight in the traffic pattern, at an airport with an operating control tower.

(3) Applicable flight rules of part 91 of this chapter for operations in Class B, C, and D airspace and air traffic control clearances.

(4) Ground and flight training for the specific Class B, C, or D airspace for which the solo flight is authorized, if applicable, within the 90-day period preceding the date of the flight in that airspace. The flight training must be received in the specific airspace area for which solo flight is authorized.

(5) Ground and flight training for the specific airport located in Class B, C, or D airspace for which the solo flight is authorized, if applicable, within the 90-day period preceding the date of the flight at that airport. The flight and ground training must be received at the specific airport for which solo flight is authorized.

(b) The authorized instructor who provides the training specified in paragraph (a) of this section must provide a logbook endorsement that certifies the student has received that training and is proficient to conduct solo flight in that specific airspace or at that specific airport and in those aeronautical knowledge areas and areas of operation specified in this section.


Per the FAA, this can be as many as 3 endorsements and as few as 1 endorsement.

If you (ANYBODY) have questions about this, I suggest you call the Light Sport Division of the FAA and get your own ruling. That's what I did.

If you read the FAR for students, there is nothing that says or implies this training must be given in one flight. As a matter of fact, in many cases it would be impossible to give it in one flight. The student must have flight training in the actual class B, class C, and class D and must be endorsed for the actual airspace every 90 days or he cannot fly in that particular airspace or any other class B, C, or D airspace for which he does not have a current 90 day endorsement. So, if the student wants to make a cross country to XYZ class D airport, an instructor must fly with him at XYZ airport and make the endorsement within 90 days. It is not reasonable to think the CFI would also have to take the student to some class B and class C airspace just so he can give him another 90 day class D endorsement for XYZ airport.

I maintain that for a student pilot, it is probably more common that there are multiple endorsements even though the FAR says the CFI must make A LOGBOOK ENDORSEMENT. Therefore, I believe A LOGBOOK ENDORSEMENT does not mean a single, all encompassing endorsement. It means A LOGBOOK ENDORSEMENT for one, two, or three specific class A, class B, and class C locations. Based on this, the language in the FAR for Sport Pilots that also says A LOGBOOK ENDORSEMENT can be construed to mean one, two, or three endorsements. That's my legal argument. I think I would prevail. The two FAR's involved leave open for interpretation the meaning of "A LOGBOOK ENDORSEMENT." Therefore, it can be interpreted correctly both ways.

This raises another issue for which I have no idea of the answer. What if a student receives this 90 day endorsement and then gets his Sport Pilot certificate? Does he need additional endorsements? What if they had expired before his flight test? What if they had not expired before his flight test? Yikes. My thought would be stay out of class B and C until after you get your Sport Pilot certificate, then go get the endorsements.

I have never said that the training must be in one flight. The only thing I have said regarding this regulation is that I think it is being confused with 61.325, and that is what's causing the problem.

I do have one simple question for you. Do you need to comply with (1), (2), and (3) of this regulation to give the student their endorsement? I made it red so you wouldn't miss it.

As for you last question, yes the sport pilot needs an additional endorsement. The reason is because the sport pilot endorsement is covered under a different regulation. What I have done in the past is provide the endorsement for 61.94, and 61.325 at the same time.

When I did this endorsement it was another time that the FAA was wrong in their interpretation of how it could be done. They said because he was a sport pilot student that the flight training, done by a CFI with a medical, needed to be in a light sport aircraft.

[SportPilot]

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[3Dreaming]

To make the endorsement do you need to do all of this? A simple yes or no will do.
(1) The use of radios, communications, navigation systems and facilities, and radar services.

[SportPilot]

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[3Dreaming]

[quote="SportPilot"]Yes, as applicable for the airspace. If you are in a class D, you can't do the radar procedures. If there is no class B or class C within 200 nm, you would have to do that training and endorsement at some other time for a student pilot. For a Sport Pilot, you might could go out and simulate the class B and C. I haven't seen anything that prevents that. So, you could do that part now or later and endorse for that part now or later.

Why don't you respond to my post about how you would do recurring 90 day endorsement for a student in class D airport XYZ if his class B and C was also expired and there is no class B and C close by or involved with airport XYZ. The FAR says the specific airspace.[/quot

Please show me where in the regulation that it says you only have to do the training for the applicable airspace?

I would consider radar procedures to be an area of aeronautical knowledge, just like it is for a private pilot. For the private pilot there is no flight training requirement for flight training in a radar environment. That being said if you are endorseing a student for clas B or C airspace you must do flight training in a radar environment.

For the question on the recurring airspace endorsement for the student there is a requirement for training in the specific airspace. See (4) and (5) in the regulation you posted. For the student pilot I would expect to see 3 individual endorsements, unless you could fly in all three types of airspace while doing the required training. If you had done all 3 and they had expired as in your scenario you would simple do the endorsement for class D airspace .
For the sport pilot there is no requirement for flight in any specific airspace to do the endorsement.

[SportPilot]

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[3Dreaming]

§61.325 How do I obtain privileges to operate a light-sport aircraft at an airport within, or in airspace within, Class B, C, and D airspace, or in other airspace with an airport having an operational control tower?
If you hold a sport pilot certificate and seek privileges to operate a light-sport aircraft in Class B, C, or D airspace, at an airport located in Class B, C, or D airspace, or to, from, through, or at an airport having an operational control tower, you must receive and log ground and flight training. The authorized instructor who provides this training must provide a logbook endorsement that certifies you are proficient in the following aeronautical knowledge areas and areas of operation:

(a) The use of radios, communications, navigation system/facilities, and radar services.

(b) Operations at airports with an operating control tower to include three takeoffs and landings to a full stop, with each landing involving a flight in the traffic pattern, at an airport with an operating control tower.

(c) Applicable flight rules of part 91 of this chapter for operations in Class B, C, and D airspace and air traffic control clearances.

I read this that you must receive both ground and flight training for class B, class C, and class D. I know you and Paul don't agree. There is nothing in the wording of the FAR that says or implies the flight training applies to only class D. As I have already repeated a number of times, I don't see anything that would prevent the class B and class C from being simulated IN FLIGHT.

I think both (a) and (c) would be considered aeronautical knowledge areas just like they are for a private pilot and there for could be done as ground training. You could also cover some of the items in flight if you wanted. I know that (b) would definitely be flight training. That meets the requirement for ground and flight training required by the regulation. The only definite flight training requirement is the three take offs and landings at an airport with an operating control tower. The operating control tower could be in any kind of airspace except A, because the regulation doesn't specify what kind of airspace it needs to be in. That is the big difference between the regulation for a student pilot and sport pilot. The student needs training in the specific airspace, and the sport pilot doesn't.

[SportPilot]

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[3Dreaming]

Why would you need to more flight training for a sport pilot to fly in the same airspace than what is require for a private pilot? Shouldn't the same training standards apply for both?

[drseti]

Anyone here is of course free to disagree with anything said on these forums, and to say so -- I believe strongly in freedom of expression. I would simply like to point out that you are disagreeing with two seasoned flight instructors, who have about a century of flight experience between them. That doesn't in itself make us right, except, of course, every CFI is required to take 16 hours of classroom training every two years, in order to renew our privileges. This is the very sort of thing we discuss extensively at our CFI renewal courses. Thus, since the Sport Pilot rules were implemented, Tom and I have had, together, at least 160 hours of classroom discussion on these very matters.

Still, you are of course free to disagree.

[SportPilot]

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[drseti]

I suspect I have been to almost as many CFI renewals as you and Tom (not combined).

Very possibly, but the ones that count most in the present case are the ones we attended after the SP/LSA rule was adopted ten years ago. Do you recall whether this was discussed in the classes you attended during that time period? If it wasn't, be sure to bring the question up at your next CFIR. I'd be curious to hear what kind of conversations ensue. (I'm not due to renew until next August, so if you renew before I do, please do keep us informed.)

[3Dreaming]

Paul, Sport Pilot is a CFI, but I don't know if he is current or active.

Earlier this year when I went to my CFI renewal the sport pilot discussion included talk about sets of aircraft. I had to tell them that sets went away in 2010. I also had to set the FAA inspector straight about how far out you could renew your CFI and keep the same expiration date. He didn't seem to understand calendar months.

[drseti]

He didn't seem to understand calendar months.