TSA rule - registration of freelance instructors

I was talking to a colleague who is a freelance CFI and had just visited the
local FBO to register so that he could comply with the TSA Alien Training
rule reporting requirements, assuming it goes ahead. I think he has existing
non-citizen students. Actually, my reading of the rule is that freelance
instructors have to register so they can use the TSA's systems, except they
can't register because they aren't a Part 141 school. But I won't go there.

Anyway, he said the FSDO processed him OK and told him (take care with this,
it's hearsay) that they can't handle more than one or two registrations a
week.

Western Washington CFI's, you have 13 days. I hope there are only four of
you.

-- David Brooks

"David Brooks" wrote in message ...
I was talking to a colleague who is a freelance CFI and had just visited the
local FBO to register so that he could comply with the TSA Alien Training
rule reporting requirements, assuming it goes ahead. I think he has existing
non-citizen students. Actually, my reading of the rule is that freelance
instructors have to register so they can use the TSA's systems, except they
can't register because they aren't a Part 141 school. But I won't go there.

Anyway, he said the FSDO processed him OK and told him (take care with this,
it's hearsay) that they can't handle more than one or two registrations a
week.

Western Washington CFI's, you have 13 days. I hope there are only four of
you.

-- David Brooks
Davis
BOHICA......right behind this is the national identity card and right
behind that is big brother grinning from ear to ear with a UN sticker
and a french looking grin. HR 10 and S2774 are the bills before
congress. It isn't enough that we as individuals are being turned into
private data bases for the government, but we are threatened with huge
fines and jail time if we don't comply.
Its gonna drive me out of the business of teaching people to fly. I'm
already "registered" with the FAA, and have to comply with FARS for my
instructional efforts. What dummy came up with this requiremnt for
TSA? Some butthead who doesn't have a clue what is going on in the
real world. Probably a college grad and their first job??
I don't think enough people are seeing this for what it is nor are
they making any noises about it until its too late. AOPA is shaking
like a sick dog and trying to mitigate the requirements instead of
outright opposing and resisting them.
What in hell ever happened to the spirit of freedom in this country
and the backbone to stand up and be heard? Sure we have a terrorist
problem and it ain't hard to figure out where it comes from? Why not
attack that problem instead of restricting us more and more every day
to avoid "offending" some clowns sensitivity. Gettin sick and tired of
bending over to appease a few....

"David Brooks" wrote in message ...
... I think he has existing
non-citizen students. Actually, my reading of the rule is that freelance

I got email from the help address on student registration web site that
explained that the rule doesn't apply if you start training before Oct. 20.
(As such, his existing students shouldn't have to worry. New ones starting
on or after Oct. 20 do need to register and they can't get through the
initial steps on the web site until the flight school is on the list.)

I'm planning on going for 3 trips in a T-6 in Nov. and I'm at the stage where
the school has to get registered before I can get any further through the
registration process.

Great Fun, rick

(Rick Macklem) wrote in
om:

"David Brooks" wrote in message
...
... I think he has existing
non-citizen students. Actually, my reading of the rule is that
freelance

I got email from the help address on student registration web site
that explained that the rule doesn't apply if you start training
before Oct. 20. (As such, his existing students shouldn't have to
worry. New ones starting on or after Oct. 20 do need to register and
they can't get through the initial steps on the web site until the
flight school is on the list.)

I'm planning on going for 3 trips in a T-6 in Nov. and I'm at the
stage where the school has to get registered before I can get any
further through the registration process.

Great Fun, rick



What is the definition of 'existing students'? If you keep going back to
the same CFI for your Flight Review every two years, are you considered an
existing student?


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Andrew Sarangan wrote in message .4...

What is the definition of 'existing students'? If you keep going back to
the same CFI for your Flight Review every two years, are you considered an
existing student?

I don't think there is a definition of "existing students" in the
rule. I believe they use
the term "course of instruction", although I don't recall a definition
of that.
(The rule and its preamble is interesting reading, if you enjoy
reading the
FARs and similar. Only 44 pages. You can find it under AOPA's web
site.)

As for answering questions, the web site is
https://www.flightschoolcandidates.gov and it references a help
address,
which I believe is .

If you are a "Provider" (ie School, Instructor,...), the web site is:
https://www.flightschoolcandidates.gov/fsindex.html

rick

Andrew Sarangan wrote in message .4...

What is the definition of 'existing students'? If you keep going back to
the same CFI for your Flight Review every two years, are you considered an
existing student?

I don't think there is a definition of "existing students" in the
rule. I believe they use
the term "course of instruction", although I don't recall a definition
of that.
(The rule and its preamble is interesting reading, if you enjoy
reading the
FARs and similar. Only 44 pages. You can find it under AOPA's web
site.)

As for answering questions, the web site is
https://www.flightschoolcandidates.gov and it references a help
address,
which I believe is .

If you are a "Provider" (ie School, Instructor,...), the web site is:
https://www.flightschoolcandidates.gov/fsindex.html

rick

In article , Andrew Sarangan
wrote:
What is the definition of 'existing students'? If you keep going back to
the same CFI for your Flight Review every two years, are you considered an
existing student?

And how are they defining courses of instruction? Does a BFR count as
something that has to be registered - considering the student will be
PIC and is already rated? What about checkout flights if you're a
foreigner going to a new FBO?

--
Dylan Smith, Castletown, Isle of Man
Flying: http://www.dylansmith.net
Frontier Elite Universe: http://www.alioth.net
"Maintain thine airspeed, lest the ground come up and smite thee"

Dylan Smith wrote in message ...

And how are they defining courses of instruction? Does a BFR count as
something that has to be registered - considering the student will be
PIC and is already rated? What about checkout flights if you're a
foreigner going to a new FBO?

I'm actually surprised there isn't a discussion going on w.r.t. the rule's
interpretation. (AOPA's web has a letter on it their General Counsel wrote
TSA asking for some clarifications.) Here's my layman's interpretation:
flight instruction - anything done with an instructor in an airplane or
simulator (doesn't say you have to go flying, but does exclude
"ground instruction")
course of instruction - not really defined in the 44 page document as I recall,
but the registration web site requires you specify a flight training
provider from the list and specify a start and end date, when you register
for "flight training"

Also, in the section that calculates cost, it assume a Candidate will register,
on average, twice a year.

So, I'd say, as it stands, every BFR requires a registration.

Oh, and although AOPA has asked for a clarification on this one, at this point
"recurrent training" is defined (on pg. 12) as training required for employees
of commercial operators or private business aircraft ops, so things like BFRs,
(the T-6 refresher I'm planning in Nov. etc) are all Category 3 (everything
else in aircraft 12,500lbs gross) and require registrations each time.
(You only have to do the fingerprinting the first time, it notes they'll keep
them on file. You do pay the $130 each registration, though.)

If I had known I was going to have to do all this for 3 flights in a T-6,
I wouldn't have bothered, but now that I've booked the flights and the plane
ticket to FL, I'm doing the whole sheebang, rick

I'm actually surprised there isn't a discussion going on w.r.t. the rule's
interpretation. (AOPA's web has a letter on it their General Counsel wrote
TSA asking for some clarifications.)

There are a bunch of submissions on the docket asking for interpretation
though.

Here's my layman's interpretation:
flight instruction - anything done with an instructor in an airplane or
simulator (doesn't say you have to go flying, but does exclude
"ground instruction")

Hey, Steve, wanna sit in the right seat while I do three and a hold? Don't
say anything, just enjoy the ride. I'll even pay the FBO the standard
instructor rate.

Instruction, or not? Can it come down to whether you write 1.2 in the Dual
Received column?

course of instruction - not really defined in the 44 page document as I
recall,
but the registration web site requires you specify a flight training
provider from the list and specify a start and end date, when you
register
for "flight training"

End date? For a Part 61 Instrument? Oh, please.

Also, in the section that calculates cost, it assume a Candidate will
register,
on average, twice a year.

So, I'd say, as it stands, every BFR requires a registration.

I think that's what it says.

Oh, and although AOPA has asked for a clarification on this one, at this
point
"recurrent training" is defined (on pg. 12) as training required for
employees
of commercial operators or private business aircraft ops, so things like
BFRs,
(the T-6 refresher I'm planning in Nov. etc) are all Category 3
(everything
else in aircraft 12,500lbs gross) and require registrations each time.
(You only have to do the fingerprinting the first time, it notes they'll
keep
them on file. You do pay the $130 each registration, though.)

It may be defined on page 12 as that, but it's defined in the actual Rule
differently. The preamble excludes Part 61, and the Rule itself includes 61.
So even a Part 61 BFR is recurrent training, so subject to different
record-keeping requirements from Category 3.

If I had known I was going to have to do all this for 3 flights in a T-6,
I wouldn't have bothered, but now that I've booked the flights and the
plane
ticket to FL, I'm doing the whole sheebang, rick

That's the problem - the TSA seems deaf to the complaint that there are lots
of businesses that need to plan ahead. We can't just assume they will wait
until the 19th and delay implementation. There are also outstanding requests
for clarification that businesses need, yesterday..

My FBO's chief pilot, who has been following closely, thinks they will fix
the problems with the citizen up-front requirements, but leave the alien
requirements (including Resident) in place.

-- David Brooks

I'm actually surprised there isn't a discussion going on w.r.t. the rule's
interpretation. (AOPA's web has a letter on it their General Counsel wrote
TSA asking for some clarifications.)

There are a bunch of submissions on the docket asking for interpretation
though.

Here's my layman's interpretation:
flight instruction - anything done with an instructor in an airplane or
simulator (doesn't say you have to go flying, but does exclude
"ground instruction")

Hey, Steve, wanna sit in the right seat while I do three and a hold? Don't
say anything, just enjoy the ride. I'll even pay the FBO the standard
instructor rate.

Instruction, or not? Can it come down to whether you write 1.2 in the Dual
Received column?

course of instruction - not really defined in the 44 page document as I
recall,
but the registration web site requires you specify a flight training
provider from the list and specify a start and end date, when you
register
for "flight training"

End date? For a Part 61 Instrument? Oh, please.

Also, in the section that calculates cost, it assume a Candidate will
register,
on average, twice a year.

So, I'd say, as it stands, every BFR requires a registration.

I think that's what it says.

Oh, and although AOPA has asked for a clarification on this one, at this
point
"recurrent training" is defined (on pg. 12) as training required for
employees
of commercial operators or private business aircraft ops, so things like
BFRs,
(the T-6 refresher I'm planning in Nov. etc) are all Category 3
(everything
else in aircraft 12,500lbs gross) and require registrations each time.
(You only have to do the fingerprinting the first time, it notes they'll
keep
them on file. You do pay the $130 each registration, though.)

It may be defined on page 12 as that, but it's defined in the actual Rule
differently. The preamble excludes Part 61, and the Rule itself includes 61.
So even a Part 61 BFR is recurrent training, so subject to different
record-keeping requirements from Category 3.

If I had known I was going to have to do all this for 3 flights in a T-6,
I wouldn't have bothered, but now that I've booked the flights and the
plane
ticket to FL, I'm doing the whole sheebang, rick

That's the problem - the TSA seems deaf to the complaint that there are lots
of businesses that need to plan ahead. We can't just assume they will wait
until the 19th and delay implementation. There are also outstanding requests
for clarification that businesses need, yesterday..

My FBO's chief pilot, who has been following closely, thinks they will fix
the problems with the citizen up-front requirements, but leave the alien
requirements (including Resident) in place.

-- David Brooks