Get extra lift from AOPA. Start your free membership trial today! Click here

Preflight

Security rules

Instructors work to comply with TSA regs

It used to be that when student pilots, certificated pilots, and flight instructors got together, the talk was almost always about flying. And it seems like those days weren't all that long ago.

But more recently, the talk -- among flight instructors, at least-tended to emphasize the Transportation Security Administration's security requirements, especially the alien flight training/citizenship validation rule and security awareness training for flight instructors and flight school employees.

Part of this is old hat to many instructors. TSA on September 21, 2004, issued an interim final rule on flight training for aliens and other designated individuals. As currently written, the rule requires every person -- including U.S. citizens -- to prove his or her citizenship status before beginning flight training for a new or additional pilot certificate or rating in an aircraft weighing 12,500 pounds or less. So, recurrent training is exempted from the requirement. In addition, foreign flight students must complete a TSA background check. Aliens who currently hold a pilot certificate and begin training for a new certificate or rating on or after December 20, 2004, must comply with the rule. And flight schools and flight instructors who wish to train foreign students must first register with TSA.

But some flight instructors found compliance to be more challenging than they expected. AOPA heard from dozens of CFIs and flight schools that reported problems obtaining their authorizations. Some reported that their cases were exacerbated by a lack of response from TSA's telephone help line or finger-pointing between TSA and FAA flight standards district offices.

One CFI we know -- a consummate professional -- had this to say about his experience: "I went through the whole TSA registration thing because I fly with so many foreign nationals. This included going to the FSDO and getting my secret access code to their Web site and learning the secret handshake.

"For a month I had the local TSA rep referring people to me -- I'm not kidding -- because I had more information than he did," he continued. "And the foreign registration that absolutely, positively had to happen by October 22, 2004 [that original deadline was extended by 60 days], and absolutely, positively had to use TSA [registration] cards and only TSA cards? I ordered my cards three weeks before the deadline and received them in early January." He noted that Bureau of Alcohol, Tobacco, and Firearms; FBI; and Sheriff's Department cards cannot be used, even though they appear identical.

"I jumped through hoops until I couldn't jump any more and then realized their definition of 'flight training' -- it has to result in an airman certificate or rating-doesn't apply to me, so I was off the hook. What a boondoggle!

"I have a CFI refresher course the middle of next month, and I'm dying to see how they treat this."

The same TSA rule also required flight schools to provide security awareness training to each ground and flight instructor -- as well as administrative staff and any other employee who has direct contact with flight students, regardless of their citizenship or nationality -- by January 18. Independent flight instructors must obtain the training too; a free online training program was offered on the TSA Web site. A course completion certificate must be printed and retained.

One flight instructor, who also captains a business jet, wasn't sure if course completion had to be reported to TSA. AOPA's Pilot Information Center told him that all he had to do was retain the completion certificate.

Another instructor completed TSA's online course but wasn't able to print the completion certificate. Flight instructors are nothing if not resourceful. When no other computer tricks would work, this individual grabbed a digital camera, shot a picture of the screen, and printed the image -- ensuring that the all-important date was legible.

Active CFIs who have not received the training, which has also been added to the AOPA Air Safety Foundation's live Flight Instructor Refresher Clinics, should take it immediately. Inactive instructors are encouraged to take the course as well. TSA has indicated that it wants to focus on compliance, not enforcement -- but flight training security remains an emphasis, and that policy could change.

AOPA Online contains a wealth of information about the rule, with explanations of how it affects all categories of pilots and links to additional resources, including TSA's online security awareness training course.

Unless you never add a rating or upgrade your pilot certificate, this rule eventually will affect every pilot flying in the United States. So don't be surprised when, before that first instrument lesson, your instructor asks for an original birth certificate and photo ID, passport, or other proof of citizenship. In the meantime, be aware of this additional responsibility flight instructors have undertaken in order to keep enjoying -- and sharing -- the gift of flight.

Mike Collins
Mike Collins
Technical Editor
Mike Collins, AOPA technical editor and director of business development, died at age 59 on February 25, 2021. He was an integral part of the AOPA Media team for nearly 30 years, and held many key editorial roles at AOPA Pilot, Flight Training, and AOPA Online. He was a gifted writer, editor, photographer, audio storyteller, and videographer, and was an instrument-rated pilot and drone pilot.

Related Articles