CaptainChocks
Filing Flight Plan
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CaptainChocks
This post serves as a follow-up question.
In this interpretation, Mr. Grannis asked “whether instruction received from a commercial pilot or airline transport pilot in particular flight operations, such as ferry flights, aerial work operations, banner towing, aerial photograph or survey, or firefighting, would fall under the "student instruction." exception of§ 119 .1 ( e )( 1 ).”
The FAA responded defining:
"Student instruction broadly as referring to an operation in which a person receives flight training from an authorized instructor for the purpose of obtaining a certificate, privilege, rating, or authorization under part 61”.
Furthermore, the FAA defined “Flight Training” as “training, other than ground training, received from an authorized instructor in flight in an aircraft”.
The FAA clarified that a “person who holds only a commercial pilot or ATP certificate may not conduct flight training for purpose of satisfying the "student instruction" exception in § 119 .1 ( e )(1) because he or she does not hold a flight instructor certificate”.
Then, the FAA interprets a “Training Flight” as:
“Operations in which a person receives training for the purpose of satisfying a training requirement outside of part 61”.
The FAA omitted the phrase “from an authorized instructor” when defining a training flight.
Examples of a training flight are given “such as the crewmember training requirement of § 91.313.”
Following the definition of a training flight, the FAA states:
“Flight crewmember training in special purpose operations, such as crop dusting, seeding, spraying, and banner towing, would fall under the "training flights" exception of§ 119.3( e)(3)”.
How I understand this letter of interpretation:
A person who only possess an ATP or CPL is unable to give student instruction towards a rating under Part 61 as they are not an authorized instructor. Flight training is the airborne portion of “student instruction” and to give student instruction, you must be an authorized instructor. The FAA clearly differentiates between flight training and a training flight. A training flight is training towards a requirement outside of part 61. The FAA makes no remark that a training flight (training towards a requirement outside of part 61) must be conducted by an authorized instructor. Which leads me to this conclusion:
A commercial pilot (or ATP) may conduct a training flight as a trainer in special purpose operations, such as crop dusting, seeding, spraying, and banner towing.
Do you agree with this interpretation?
In this interpretation, Mr. Grannis asked “whether instruction received from a commercial pilot or airline transport pilot in particular flight operations, such as ferry flights, aerial work operations, banner towing, aerial photograph or survey, or firefighting, would fall under the "student instruction." exception of§ 119 .1 ( e )( 1 ).”
The FAA responded defining:
"Student instruction broadly as referring to an operation in which a person receives flight training from an authorized instructor for the purpose of obtaining a certificate, privilege, rating, or authorization under part 61”.
Furthermore, the FAA defined “Flight Training” as “training, other than ground training, received from an authorized instructor in flight in an aircraft”.
The FAA clarified that a “person who holds only a commercial pilot or ATP certificate may not conduct flight training for purpose of satisfying the "student instruction" exception in § 119 .1 ( e )(1) because he or she does not hold a flight instructor certificate”.
Then, the FAA interprets a “Training Flight” as:
“Operations in which a person receives training for the purpose of satisfying a training requirement outside of part 61”.
The FAA omitted the phrase “from an authorized instructor” when defining a training flight.
Examples of a training flight are given “such as the crewmember training requirement of § 91.313.”
Following the definition of a training flight, the FAA states:
“Flight crewmember training in special purpose operations, such as crop dusting, seeding, spraying, and banner towing, would fall under the "training flights" exception of§ 119.3( e)(3)”.
How I understand this letter of interpretation:
A person who only possess an ATP or CPL is unable to give student instruction towards a rating under Part 61 as they are not an authorized instructor. Flight training is the airborne portion of “student instruction” and to give student instruction, you must be an authorized instructor. The FAA clearly differentiates between flight training and a training flight. A training flight is training towards a requirement outside of part 61. The FAA makes no remark that a training flight (training towards a requirement outside of part 61) must be conducted by an authorized instructor. Which leads me to this conclusion:
A commercial pilot (or ATP) may conduct a training flight as a trainer in special purpose operations, such as crop dusting, seeding, spraying, and banner towing.
Do you agree with this interpretation?
