FARs Regarding Tailwheel Endorsement (is it required?)

[Ersatz L-4]

"I certify that Stu D. Ent has received the required training to qualify for solo flying. I have determined he meets the applicable requirements of § 61.87(n) and is proficient to make solo flights in the Piper J-3 Cub, C.F.Eye, 12-25-2004 C.F.Eye 123456CFI." is a tailwheel endorsement.

Just for clarification, Sport Pilot Certificate holders are not required to have a generic tailwheel endorsement.

Also, a Sport Pilot CFI can give any certificated airman instruction in a LSA, and a subsequent unlimited endorsement for any tailwheel aircraft.

 

[MauleSkinner]

"I certify that Stu D. Ent has received the required training to qualify for solo flying. I have determined he meets the applicable requirements of § 61.87(n) and is proficient to make solo flights in the Piper J-3 Cub, C.F.Eye, 12-25-2004 C.F.Eye 123456CFI." is a tailwheel endorsement.

I disagree. 61.87(n) does not show compliance with 61.31(i).

Just for clarification, Sport Pilot Certificate holders are not required to have a generic tailwheel endorsement.

Can you elaborate?

 

[Lindberg]

I disagree. 61.87(n) does not show compliance with 61.31(i).

Ok. But what about "the required training to qualify for solo flying"?

 

[midlifeflyer]

I'm pretty sure that works as well - point being is that the endorsement needs to be clear that the requirements of the tailwheel endorsement have been met.

Since it's the FAA's language for the endorsement, I'm completely sure it works well

 

[midlifeflyer]

Just for clarification, Sport Pilot Certificate holders are not required to have a generic tailwheel endorsement

You mean a sport pilot is not a "person"?

Perhaps you can point us to the sport pilot regulation ot FAA guidancevthat exempts them from 61.31(i).

 

[MauleSkinner]

Ok. But what about "the required training to qualify for solo flying"?

Sounds like 61.87 again. Either way, I hope your verbiage in your training entries in the logbook is more specific than your endorsement verbiage.

 

[Lindberg]

Sounds like 61.87 again. Either way, I hope your verbiage in your training entries in the logbook is more specific than your endorsement verbiage.

That's the FAA's recommended verbiage.

 

[Capt. Geoffrey Thorpe]

Perhaps you can point us to the sport pilot regulation ot FAA guidancevthat exempts them from 61.31(i).

61.303 You may operate "A) Any light-sport aircraft for which you hold the endorsements required for its category and class."

That gets you around at least 61.31(D) (must have category and class) which is necessary because 61.317 - the sport pilot certificate is issued without category or class... And, if 61.31D does not apply????????????

You mean a sport pilot is not a "person"?

Real pilots have real medicals.

 

[Ersatz L-4]

The FAA produced a document, an "executive summary" of AC 61-65H, dated 8/27/18-- which in its 58 pages does not state that a Student Pilot seeking a Sport Pilot Certificate, or a Sport Pilot seeking an Instructors certificate require a tailwheel endorsement-- of step by step procedures and endorsements required to obtain a sport pilot certificate, and to add additional privileges to a Sport Pilot's certificate.
https://www.faa.gov/sites/faa.gov/files/student_pilot_guidance.pdf
It is also the first link listed here under resources for Sport Pilots and Sport Pilot Instructors
https://www.faa.gov/licenses_certificates/airmen_certification/sport_pilot

Contained within "§ 61.87 Solo requirements for student pilots," is the requirement that a student pilot, prior to solo, must receive instruction, and demonstrate proficiency in "(d)(2) Taxiing or surface operations, including runups;" and "(d)(3) Takeoffs and landings, including normal and crosswind;"
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-61/subpart-C/section-61.87

There is no requirement for a Student Pilot seeking a Sport Pilot Certificate to obtain a separate Tailwheel endorsement. Obviously, if one trains in a Piper J-3, which is a tailwheel (or tailskid) equipped aircraft, and one is endorsed, "....I have determined she has demonstrated the proficiency of § 61.87(d) and is proficient to make solo flights in a Piper J-3C Cub..." Then one is endorsed as being proficient to operate a small Continental engine, an airplane flown from the back seat, an airplane with a USA-35 airfoil, and most importantly an aircraft with a tailwheel.

Quoting AC 61-65H, For a person with a certificate other than a Sport Pilot Certificate "to act as pilot in command in a tailwheel airplane: § 61.31(i). This endorsement may be given in a sport pilot aircraft by a sport pilot instructor, or in an airplane by a flight instructor with a rating other than a sport pilot rating. 'I certify that [First name, MI, Last name], [grade of pilot certificate], [certificate number], has received the required training of § 61.31(i) in a [make and model] of tailwheel airplane. I have determined that [he or she] is proficient in the operation of a tailwheel airplane...'"
https://www.faa.gov/documentlibrary/media/advisory_circular/ac_61-65h.pdf

 

[Ersatz L-4]

Real pilots have real medicals.

Real pilots build their own airplanes

 

[dbahn]

Ok. But what about "the required training to qualify for solo flying"?

Might work, but why take the chance? You roll the dice with both the FAA and the insurance company in the event of an accident. All you need to do in the endorsement is to be specific with respect to the training required.

Years ago I did a Flight Review for a guy in a Maule. When I asked him to do a wheel landing he told me that he had never done one, yet he had been endorsed by the Maule factory. The factory pilot told me that they don't recommend wheel landings in the Maule because of its relatively higher center of gravity and risk of nose-overs. When I talked to an ASI that I know at the FAA (not snitching on the pilot) he told me that his endorsement would have been acceptable if it had simply stated that it "does not apply to wheel landings", but he emphasized that the wording in an endorsement has to be very specific.

 

[MauleSkinner]

That's the FAA's recommended verbiage.

For a tailwheel endorsement?

 

[MauleSkinner]

The FAA produced a document, an "executive summary" of AC 61-65H, dated 8/27/18-- which in its 58 pages does not state that a Student Pilot seeking a Sport Pilot Certificate, or a Sport Pilot seeking an Instructors certificate require a tailwheel endorsement-- of step by step procedures and endorsements required to obtain a sport pilot certificate, and to add additional privileges to a Sport Pilot's certificate.
https://www.faa.gov/sites/faa.gov/files/student_pilot_guidance.pdf
It is also the first link listed here under resources for Sport Pilots and Sport Pilot Instructors
https://www.faa.gov/licenses_certificates/airmen_certification/sport_pilot

Of course it doesn’t state that a student pilot doesn’t require a tailwheel endorsement…there are still those rare student pilots who learn in tricycle gear airplanes.

Contained within "§ 61.87 Solo requirements for student pilots," is the requirement that a student pilot, prior to solo, must receive instruction, and demonstrate proficiency in "(d)(2) Taxiing or surface operations, including runups;" and "(d)(3) Takeoffs and landings, including normal and crosswind;"
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-61/subpart-C/section-61.8

wheel landings is distinctly missing from those requirements.

There is no requirement for a Student Pilot seeking a Sport Pilot Certificate to obtain a separate Tailwheel endorsement. Obviously, if one trains in a Piper J-3, which is a tailwheel (or tailskid) equipped aircraft, and one is endorsed, "....I have determined she has demonstrated the proficiency of § 61.87(d) and is proficient to make solo flights in a Piper J-3C Cub..." Then one is endorsed as being proficient to operate a small Continental engine, an airplane flown from the back seat, an airplane with a USA-35 airfoil, and most importantly an aircraft with a tailwheel.

So why does a student pilot seeking Private Pilot privileges, or a Private Pilot for that matter, require a tailwheel endorsement? The regs and endorsements are identical.

Quoting AC 61-65H, For a person with a certificate other than a Sport Pilot Certificate "to act as pilot in command in a tailwheel airplane: § 61.31(i). This endorsement may be given in a sport pilot aircraft by a sport pilot instructor, or in an airplane by a flight instructor with a rating other than a sport pilot rating. 'I certify that [First name, MI, Last name], [grade of pilot certificate], [certificate number], has received the required training of § 61.31(i) in a [make and model] of tailwheel airplane. I have determined that [he or she] is proficient in the operation of a tailwheel airplane...'"
https://www.faa.gov/documentlibrary/media/advisory_circular/ac_61-65h.pdf

this is simply clarifying that a CFI-SP can provide the endorsement for the holder of any level of pilot certificate. It is not an exemption for Sport Pilots.

 

[Lindberg]

Might work, but why take the chance? You roll the dice with both the FAA and the insurance company in the event of an accident. All you need to do in the endorsement is to be specific with respect to the training required.

I'm open to the counterargument. Why wouldn't it work?

Years ago I did a Flight Review for a guy in a Maule. When I asked him to do a wheel landing he told me that he had never done one, yet he had been endorsed by the Maule factory. The factory pilot told me that they don't recommend wheel landings in the Maule because of its relatively higher center of gravity and risk of nose-overs. When I talked to an ASI that I know at the FAA (not snitching on the pilot) he told me that his endorsement would have been acceptable if it had simply stated that it "does not apply to wheel landings", but he emphasized that the wording in an endorsement has to be very specific.

The required training specifically excludes wheel landings if the manufacturer recommends against them. And the required (or FAA recommended) endorsement doesn't mention wheel landings.

 

[Lindberg]

For a tailwheel endorsement?

What is required to be contained in a tailwheel endorsement? More specifically, she's the regulation require that the endorsement list the training given? Or that the training even be given by the instructor making the engagement?

 

[MauleSkinner]

What is required to be contained in a tailwheel endorsement? More specifically, she's the regulation require that the endorsement list the training given? Or that the training even be given by the instructor making the engagement?

61.31(i).

 

[dbahn]

I'm open to the counterargument. Why wouldn't it work?

It might, but the FAA has a tendency to nit-pick when an event causes them to review details, and it's so easy to avoid the chance.

The required training specifically excludes wheel landings if the manufacturer recommends against them. And the required (or FAA recommended) endorsement doesn't mention wheel landings.

I'm going by what the AI at our FSDO told me. The endorsement needs to exclude wheel landings, so if a pilot gets an endorsement in a Maule without wheel landings he is not endorsed to do wheel landings in a different aircraft that does not have the manufacturer's restriction.

 

[Ersatz L-4]

When I talked to an ASI that I know at the FAA (not snitching on the pilot) he told me that his endorsement would have been acceptable if it had simply stated that it "does not apply to wheel landings", but he emphasized that the wording in an endorsement has to be very specific.

This ASI-- not surprisingly--contradicts 14 CFR § 61.31 "(i)(1)(ii) Wheel landings (unless the manufacturer has recommended against such landings);"

 

[Ersatz L-4]

61.31(i).

(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.

If you train on an aircraft with a tailwheel, per "§ 61.87 Solo requirements for student pilots.(c) Pre-solo flight training." your presolo endorsement attests to the fact that you fulfilled the following requirements: "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 (2) Demonstrated satisfactory proficiency and safety, as judged by an authorized instructor, on the maneuvers and procedures required by this section in the make and model of aircraft or similar make and model of aircraft to be flown."

 

[MauleSkinner]

If you train on an aircraft with a tailwheel, per "§ 61.87 Solo requirements for student pilots.(c) Pre-solo flight training." your presolo endorsement attests to the fact that you fulfilled the following requirements{ "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 (2) Demonstrated satisfactory proficiency and safety, as judged by an authorized instructor, on the maneuvers and procedures required by this section in the make and model of aircraft or similar make and model of aircraft to be flown."

True, and feel free to treat it that way if it’s important for you to do so. I truly hope you never have to defend that position with the FAA.

 

[Lindberg]

What is required to be contained in a tailwheel endorsement? More specifically, [does] the regulation require that the endorsement list the training given? Or that the training even be given by the instructor making the [endorsement]?

61.31(i).

All I see in 61.31(i) about an endorsement is that I must have "an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane." So do you agree that the endorsement is not required to list the training I've received, and that the instructor making the endorsement need not give me any training at all?

Why would an endorsement from an authorized instructor that, "I certify that Joe Pilot has received the required training to qualify for solo flying. I have determined he meets the applicable requirements of § 61.87(n) and is proficient to make solo flights in a Piper J-3 Cub," not satisfy the requirements of 61.31(i)? What specifically do you find missing that's required by 61.31(i)?

 

[IK04]

What do I sign to petition to have the tailwheel endorsement requirement removed?

That would solve everything and nothing at the same time.

...Tailwheel endorsement! PPFFFT!

 

[midlifeflyer]

61.303 You may operate "A) Any light-sport aircraft for which you hold the endorsements required for its category and class."

That gets you around at least 61.31(D) (must have category and class) which is necessary because 61.317 - the sport pilot certificate is issued without category or class... And, if 61.31D does not apply???????????

It doesn't mean some other part of 61.31 doesn't apply.

If there was an exemption for sport pilots, I'd expect things like paragraph 33.3 in AC 61-65H to read:

33.3 Tailwheel Endorsement. Section 61.31(i) prescribes additional training required for operating tailwheel airplanes. Some tailwheel airplanes have different configurations such as wheels, floats, or skis. If a pilot other than a sport pilot is going to act as PIC of an aircraft configured (equipped) with main wheels and a tailwheel, the pilot must have the training and endorsement. If the aircraft has skis or floats in place of the wheeled landing gear, the training cannot be accomplished and thus the endorsement is not required. The training and endorsement required by the regulation must be done when the aircraft has a tailwheel in the wheeled landing gear configuration. Refer to § 61.31(i)(2) for an exception to the training and endorsement requirement.

(text in red added)​

 

[MauleSkinner]

All I see in 61.31(i) about an endorsement is that I must have "an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane." So do you agree that the endorsement is not required to list the training I've received, and that the instructor making the endorsement need not give me any training at all?

If you’re comfortable signing an endorsement based on another instructor’s training, go ahead. I hope you don’t have to defend that position with the FAA.

Why would an endorsement from an authorized instructor that, "I certify that Joe Pilot has received the required training to qualify for solo flying. I have determined he meets the applicable requirements of § 61.87(n) and is proficient to make solo flights in a Piper J-3 Cub," not satisfy the requirements of 61.31(i)? What specifically do you find missing that's required by 61.31(i)?

“61.31(i)”, the ability to carry passengers upon completion of checkride, and the ability to fly any tailwheel aircraft other than a J-3.

 

[Daleandee]

My take is that § 61.87 Solo requirements are for student pilots. The DPE will want to see those skills demonstrated during the certificate ride. If what you are saying is correct then a student could get his endorsement for tailwheel in a cub during training and take his flight test with the DPE in a C-152 and still hold the tailwheel endorsement yet never having to demonstrate those skills to the DPE. That ain't happening.

The requirement given under § 61.31 (i) (1) clearly states, "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 ..."

I agree with MauleSkinner and hope you are never in a position to have to defend this with the FAA or your insurance company ...

 

[dbahn]

This ASI-- not surprisingly--contradicts 14 CFR § 61.31 "(i)(1)(ii) Wheel landings (unless the manufacturer has recommended against such landings);"

I don't think it contradicts 61.31. He simply said that if tailwheel training is not done, then the endorsement needs to reflect that by limiting operation to exclude wheel landings.

 

[Ersatz L-4]

The FAA could have made it clearer... but that would have stifled a bunch of pilots actively debating the regulations, their wording, and their intent.

It boils down to the interpretation of § 61.87 (c)(1) "....Received and logged flight training ... appropriate to the make and model of aircraft to be flown; and (2) ... the make and model of aircraft or similar make and model..."

What the regulations do not say is just as important as what they do say. AC 60-28B which pertains to fluency in the English language outlines procedures to insure that persons from Puerto Rico or outside the United States meet this requirement. By establishing a procedure for those individuals it effectively exempts persons from the United States (except for Puerto Rico).

 

[RyanShort1]

Anyone jeopardizing their student’s future with an FAA inspector over trying to save 1 minute of writing and a penny worth of ink should quit instructing.

Use the wording in the AC and be done with it.

 

[dbahn]

What's so ironic in this nit-picking level of discussion that in 1990 you only had to have logged time as PIC in a tailwheel aircraft. Period. That means that you could have been sole manipulator of the controls in cruise (not acting as PIC) and logged it having never even done a single take off or landing. You're grandfathered, but a year later you were required to demonstrate proficiency as described in 61.31.

Partially as a result (insurance plays a role as well) most pilots now seem to spend 8 to 10 hours for the endorsement. Many if no most of us that are grandfathered just got "checked out" in an hour or two to be able to rent a Cub or similar aircraft.

 

[Ersatz L-4]

My take is that § 61.87 Solo requirements are for student pilots. The DPE will want to see those skills demonstrated during the certificate ride. If what you are saying is correct then a student could get his endorsement for tailwheel in a cub during training and take his flight test with the DPE in a C-152 and still hold the tailwheel endorsement yet never having to demonstrate those skills to the DPE. That ain't happening.

The requirement given under § 61.31 (i) (1) clearly states, "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 ..."

I agree with MauleSkinner and hope you are never in a position to have to defend this with the FAA or your insurance company ...

I am talking about Sport Pilot Certification. A person cannot take a Sport Pilot practical in a 1500-1550 lb GW C-150 or a 1670 lb GW C-152, if a person is obtaining a Private Pilot Certification then the Private Pilot rules apply. While a person obtaining a Sport Pilot Certification must train in an aircraft with a GW of 1320 lb or under, there is no reason that a person cannot obtain a Private Pilot Certification in an aircraft that has a GW of 1320 lb or less...

Well... unless the aircraft only has one seat*... 'cause you can obtain a SPC in a single seat aircraft that weights less than 1320 lb...

Or it is an Experimental with only three gauges on the instrument panel*... a tach, oil temp, and oil pressure gauge. You can obtain a SPC in that aircraft as well.

*Full disclosure, I'm not certain you can't obtain a PPC in these cases, but I know you can obtain a SPC.

 

[Lindberg]

“61.31(i)”, the ability to carry passengers upon completion of checkride, and the ability to fly any tailwheel aircraft other than a J-3.

The reg doesn't require all that to be in the endorsement.

 

[Daleandee]

I am talking about Sport Pilot Certification.

The reg is the rule and as far as I can tell a "Sport Pilot" is still a "Person" ...

"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 ..."

 

[Ersatz L-4]

Use the wording in the AC and be done with it.

As it pertains to Sport Pilots, there is no wording in AC 61-65H, dated 8/27/18, for a discrete tailwheel endorsement for Student Pilots seeking a Sport Pilot Certificate or for Sport Pilots seeking a CFI-S. There is wording for a CFI-S to provide a required tailwheel endorsement for the holder of a Private Pilot Certificate, a Commercial Pilot Certificate, or an ATP.

 

[MauleSkinner]

The reg doesn't require all that to be in the endorsement.

I should have been more clear…”61.31(i)” is missing from the endorsement. The rest is why it wouldn’t satisfy the requirements.

 

[MauleSkinner]

I don't think it contradicts 61.31. He simply said that if tailwheel training is not done, then the endorsement needs to reflect that by limiting operation to exclude wheel landings.

I don’t think one can restrict the endorsement. The reg simply states that you don’t have to do wheel landings in, say, a Maule in order to issue the endorsement.

 

[Ersatz L-4]

I don't think it contradicts 61.31. He simply said that if tailwheel training is not done, then the endorsement needs to reflect that by limiting operation to exclude wheel landings.

By which the ASI contradicted the regulation by adding a restriction that is not contained in the regulation.

If I take my practical in an A-65-8 powered Cub the CFI-S cannot add an unauthorized: "Limited to aircraft of not more than 65 hp..." limitation.

 

[Ersatz L-4]

....the pilot must have the training and endorsement...

Per "§ 61.87 Solo requirements for student pilots.(c) Pre-solo flight training." your presolo endorsement attests to the fact that you fulfilled the following requirements: "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 (2) Demonstrated satisfactory proficiency and safety, as judged by an authorized instructor, on the maneuvers and procedures required by this section in the make and model of aircraft or similar make and model of aircraft to be flown."

For a Sport Pilot you are endorsed to fly one particular make and model of aircraft, this would include ground operations, takeoffs and landings. Therefore, in a tailwheel equipped aircraft, said endorsement would attest to proficiency with ground operations, takeoffs and landings in a tailwheel equipped airplane.

To argue otherwise is to say that one's Texas birth certificate does not establish US citizenship.

 

[EdFred]

I should have been more clear…”61.31(i)” is missing from the endorsement. The rest is why it wouldn’t satisfy the requirements.

Is it a requirement by regulation that "61.31(i)" MUST appear in the endorsement? Or can I just sign it saying "Joe Pilot is cool to fly tailwheel aircraft" ? And if I can say that, why wouldn't "Joe Pilot is cool to fly [specific make and model tailwheel]" suffice?

 

[MauleSkinner]

Is it a requirement by regulation that "61.31(i)" MUST appear in the endorsement? Or can I just sign it saying "Joe Pilot is cool to fly tailwheel aircraft" ?

Your choice, AFAIK. But “Joe Pilot is cool to solo a Cub” doesn’t authorize him to carry passengers in it or fly a Champ at all, even after he passes his checkride.

And given that endorsements have been a major area for CFI checkride busts for a lot of years, I would suspect the FAA would like them to be as specific as possible regarding the regs involved.

 

[Lindberg]

I should have been more clear…”61.31(i)” is missing from the endorsement. The rest is why it wouldn’t satisfy the requirements.

The reg doesn't require "61.31(i)" to be in the endorsement. Again, all that is required is "an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane." The rest is merely a training requirement.