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Answer to 61-65 A.42 question

Asked by: 995 views General Aviation

For some reason, I can't post an answer to the question about CFI written endorsements.  Here it is:

Mark,

Take a look at the wording in 61.103(d) and compare it to 61.183(d) & (f).

61.103(d) requires an endorsement to take the Private Pilot knowledge test.

61.183(d) requires an endorsement to take the FOI knowledge test.

61.183(f) only requires passing the appropriate instructor knowledge test. There is no requirement for an endorsement.

As an interesting side note, while 61.195(i) contains a prohibition against self endorsement by a flight instructor, Subpart I contains no such proscription for Ground Instructors.

My copy of regulations from 1970 contains no requirement for an endorsement for any knowledge test. My dad and I studied for the test, traveled to the South Bend FSDO and took the Private knowledge test, administered by an inspector.

My 1981 copy of the regs has no requirement for an endorsement for a knowledge test, only a requirement to show that one has completed a ground instruction course or home study course (like King Schools).

Considering the cost of the knowledge tests, I don't know why there is a requirement for the endorsement for any knowledge test. If a pilot wants to waste his money without having the proper preparation, why should the FAA care?

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3 Answers



  1. Bryan on Nov 10, 2022

    I agree with everything you’ve said here Kris. Do I just bring all of it up if the DPE wonders why A.42 post-dates my test date?

    Also, any CFII can endorse me for this because I’m not an initial applicant for CFI, right?

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  2. Kris Kortokrax on Nov 10, 2022

    I would not bother with the endorsement. I retired from the FAA as a Principal Operations Inspector last November. The FAA often makes mistakes. They have made one here, by creating an endorsement that is not required by regulation. One thing that they teach inspectors from the start is, if there is a conflict between regulations and other publications like the AIM or ACs, the regulations prevail. If an instructor creates the endorsement for you, it perpetuates the myth that it is required. I would first have the discussion with the DPE concerning the regulation vs. the AC. The fact that the testing center administered the test without the endorsement would bolster your side of the discussion. The endorsement was not included in AC 61-65E. It first appeared in 61-65F published in February 2016. There is a Feedback Form at the end of the AC. Someone with time on his hands should submit one.

    If an instructor were to enter the endorsement, he would be opening himself up to a charge of falsification. How does he determine that you have received the required training? How did he determine that you were prepared for the test?

    When you say self study, did you take a course from King or Sporty’s?

    Yes, any CFII can give you the training and endorse you for the practical test, as you already hold a Flight Instructor certificate.

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  3. Bryan on Nov 10, 2022

    Sporty’s course…learning enough this time around that I wonder how I passed the instrument ride the first time–although that always happens when you’re preparing to teach something.

    I’ll use the feedback form…or maybe even call the FSDO just to make sure there isn’t a huge problem the morning of my check ride.

    Thanks for the thoughts and help!

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