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Working with the new student pilot rules

Starting April 1, a CFI is one of the authorized individuals to accept an application for a student pilot certificate. Advisory Circular 61-65F, issued Feb. 25, outlines the new rule. Now what?

First, CFIs are probably going to want to introduce students to the Integrated Airman Certification and Rating Application (IACRA) at the beginning of training instead of toward the end. The FAA can issue the certificate based on a student application and instructor signature through IACRA. That new plastic student pilot certificate must be in hand before the solo, and students won’t get it when they go for their flight physical with an aviation medical examiner. A TSA security vetting process that is supposed to take three or fewer weeks to complete could cause delays if you have a student who is speeding through the flight training process.

What about accelerated training?

Given the current turnaround times for processing all other types of certificates, it is possible a client will complete all required dual training before the student pilot receives the certificate. There is no process in place to issue a temporary student pilot certificate. The best advice is to have the student apply for the student pilot certificate as soon as he or she even thinks about learning to fly, and not wait until the student shows up for the first day of training. Nothing stops potential pilots from applying for the certificate, even if they are just starting to think about pursuing training.

What about endorsements?

Endorsements all go in the student pilot’s logbook. There is no longer a requirement to endorse the back of the student pilot certificate. The language of the endorsements doesn’t change; you still need to endorse students for the specific make and model aircraft to be flown, and students still require an updated solo endorsement every 90 days until they take their checkride. Solo cross-country endorsements are now made in the logbook for the specific aircraft category to be flown, as well as specific make and model and each solo cross-country flight after review of the cross-country planning.

A benefit of the new rule is that the new plastic student pilot certificate doesn’t expire, just like all other pilot certificates. Students will have to get a new medical, if required, should their training time exceed the expiration date of their medical certificate. And the logbook endorsements for solo still have the same expiration periods (as in the 90-day solo requirement) that will need to be kept up, but the certificate itself doesn’t expire.

Some tips for making this work well for your clients:
• Fly the introductory flight. If they are hooked, sit down with them, help them to create their IACRA profile, and apply for a student pilot certificate. Provide them with the list of AMEs in your area, and have them make an appointment for a medical certificate, if required. Have them bring the TSA-required proof of citizenship documents (a state-issued driver’s license, a military or other government agency-issued ID, and a passport still are the most common acceptable forms) to the next lesson.
• If they’re not hooked yet, make that next appointment, explain that you’ll be helping them to create the IACRA profile then, tell them why, and ask them to bring their TSA-required documents.
• Have a plan to train students in areas that traditionally are beyond solo so that you are not waiting around for a certificate.
• Be up front with your clients about the regulations. Explain that while the process may take a little bit longer, they can continue training with you and don’t have to stop and wait to get the certificate. This may not be applicable at Part 141 schools.
• Make sure they have their required forms of identification to speed the process along and check and recheck that everything matches on the 8710, is spelled correctly, and is in the proper format to speed up the IACRA process.

While the FAA still accepts paper Form 8710s, they shouldn’t be used, said Jason Blair, a designated pilot examiner and flight instructor in Kalamazoo, Michigan, who discussed the new rules Feb. 10 at the Flight School Association of North America conference. “We strongly urge you not to use paper,” Blair said. “It will take longer and the error rate does go up.”

Blair said he’s not concerned about flight schools that process large numbers of students. “What I’m worried about is the instructor who has [trained] one student in the last 10 years and can barely use his own IACRA,” he said. “If we have those document errors, we will not do a checkride.”

Schools that train students from other locations need to be mindful about home addresses, Blair said. If the student puts a home address in the IACRA system, the certificate will go there—but will the student be training with you when the certificate arrives? Blair suggested adding a separate mailing address, but make sure the correct home address is listed.

The key is to plan ahead as much as possible, and perhaps appoint a dedicated member of your staff who knows the document requirements “to make sure [you] get this right,” Blair said.

John Collins is manager of AOPA Air Safety Institute aviation safety programs.

John Collins

Aviation Safety Programs
John Collins is the AOPA Air Safety Institute's chief flight instructor and manager of aviation safety programs. Before joining ASI, John was AOPA's manager of airport policy. He earned his flight instructor certificate in 1996 and enjoys seeing students light up when they put it all together and nail a maneuver.

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