No Dumb Questions

Q.We're thinking about adding a recreational pilot course to our full line of training courses, but we're located at a towered airport. If we decide to establish the course, can we train at our home airport using some sort of instructor endorsement, similar to the one students need to fly to eligible Class B airports, or will we have to train at a nontower airport?

Warren Smith,
Flight Training Manager
Flightstar - Savoy, Illinois

A.Regardless of the certificate they seek - recreational or private - student pilots are student pilots. There's nothing in the federal aviation regulations that specifically prohibits students from earning a recreational pilot certificate at a towered airport.

The key is the privileges and limitations (P) the federal aviation regulations list for each certificate and rating the FAA issues. Pilots must adhere to P for the certificates and ratings they hold - not the certificates and/or ratings they seek.

For example, recreational pilots cannot fly at airports or in airspace that requires ATC communication, unless they have a specific endorsement to do so (see below). This limitation does not apply to student pilots. Whether they want a recreational or private pilot certificate, student pilots can learn to fly at almost any airport - with or without a tower - because a flight instructor directly supervises and "approves" their flying.

Students applying for a recreational certificate can also take their checkrides at a towered airport thanks to a new recreational P that took effect in August 1997.

FAR 61.101(h) allows recreational pilots to make solo flights to airports and in airspace that requires ATC communication if they have the required training and instructor endorsement. Students training at a towered airport for a recreational certificate qualify for this endorsement. And, when it's checkride time, this endorsement must accompany the instructor's checkride endorsement.

On a checkride, the applicant meets the solo requirement of FAR 61.101(h) because the examiner is neither the pilot in command nor a passenger. FAR 61.47, "Status of an Examiner Who is Authorized by the Administrator to Conduct Practical Tests," says:

(b) The examiner is not the pilot in command of the aircraft during the practical test unless the examiner agrees to act in that capacity for the flight or a portion of the flight by prior arrangement?.

(c) Not withstanding the type of aircraft used during the practical test, the applicant and examiner ? are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter [Part 61].

Thanks for an excellent question, one that no one has asked before, apparently. At least I couldn't find any FAA chief counsel opinions on it, and none of the FAA inspectors I talked with ever remember being asked this one.

Like most pilots, they assumed that because recreational pilots couldn't fly to towered airports, they had to learn to fly at a nontower airport. But after dissecting the regulations and the applicability of each certificate's and rating's P, we agreed that the FARs never prohibited students from training for a recreational (or any other) certificate at a towered airport.

They found no fault with this answer, but they said that if the FAR 61.101(h) endorsement, which allows recreational pilots to fly where ATC communication is required, does not accompany the instructor's checkride endorsement, applicants for a recreational certificate would have to take their checkride at a nontower airport.