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4 Answers

CFII 61.39 Practical Test Endorsement Expiration

Asked by: 10057 views , , , ,
FAA Regulations, Flight Instructor

I have read similar forums but nothing answers my question directly. 

Heres my situation:

I received a CFII endorsement on 7/20/18. I submitted my IACRA application for the CFII today 9/10/18. It is my understanding that the IACRA application expires after 2 calendar months (I don't now of a reg that states this, but I'm pretty sure the IACRA system locks the DPE out after 2 calendar months from the month of application). Therefore, I should be eligible to take the practical until 11/30/2018, because 61.39 (a)(6)(i) only states "has received and logged training time within 2 calendar months preceding the month of application.." it does not reference the practical test; only the application. Also, part 61 subpart H does not have a requirement for "three hours within the preceding 2 calendar months from the month of test" the way that private and commercial checkrides do. 

Many people that I talk to are under the impression that the 61.39 endorsement expires after 2 calendar months, but I don't see this anywhere in the regs. So am I correct in stating that I should be eligible to take the practical until 11/30/18?

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4 Answers



  1. KDS on Sep 10, 2018

    I believe your interpretation is correct. HOWEVER, the last thing you want is to encounter an examiner who interprets it differently. In a situation like that, you just aren’t in as good a place as you could have been with the endorsement. So, why not guard against the possibility that you and I are both wrong or that we’re both right and the examiner is wrong. Getting another endorsement is very simple and painless. The regulation says:

    “Has received and logged training time within 2 calendar months preceding the month of application in preparation for the practical test;”

    It doesn’t say you have to fly, it doesn’t say you have to have training on everything under the sun, it only says you have to have received and logged training time. Just grab your instructor, tell him your concern, and ask him to sit down with you for a little bit, go over a segment of what you need in preparation for the test, and make a new endorsement. Then you can walk into the test without some worry rattling around in the back of your head that is going to distract you.

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  2. jrdelli on Sep 11, 2018

    I would be cautious about that interpretation and here is why: During my initial CFI checkride (April 2018) I was asked how long the 8710 is good for. The examiner wanted to hear 60 days, which sounds like what you are saying BUT here is where I would be cautious. The 8710 technically does not have an expiration, the thing that make the 8710 valid in the first place is the endorsement. So if the endorsement is out of date, the 8710 is out of date. So I would say based on this interpretation, which I was told in April of 2018 you would be showing up to a checkride with an invalid 8710 because your endorsement was not within 60 days.

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  3. Kris Kortokrax on Sep 12, 2018

    What really needs to be determined is when it becomes an application. Is it when you initially enter the information? Or is it when your instructor signs the recommendation? Or is it when you actually sign the application (which occurs in front of the DPE on the day of your practical)?

    I would say that it does not become an application until you have signed it. Without a signature, it is nothing. When you sign, you are certifying that the information on the application is complete and true.

    Therefore, your 8710 would not become an application until the day of your practical and the instruction for 61.39(a)(6) would need to have occurred in the 2 calendar months preceding the date on which you sign the application.

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  4. vaflyer on Sep 15, 2018

    Look at AC 61.65G, page A-15, endorsement A.44. Reference the note under this endorsement. You must also have endorsement A.1 and A.2. If your A.1 endorsement is on 7/20 then it is good until the last day of September (“two calendar months). I’m a DPE and that is what I would go by.

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