TSA rule - registration of freelance instructors

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

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?


If you write 1.2 in the Dual column and put your instructor certificate number
in the logbook, the entry can be used for ratings and such. It's instruction.

If you don't, then it cannot be used for ratings, currency, or anything (and if
you are out of currency while you are doing it, it's illegal). So it's not
"official" instruction.

However, you are teaching something and the student is learning. To the best
of my knowledge, the mechanics of flying is not classified information. I
don't think there is anything to prevent you (whether or not you are a CFI)
from sharing your knowledge of unclassified material with any other person.

Jose






--
(for Email, make the obvious changes in my address)

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?


If you write 1.2 in the Dual column and put your instructor certificate number
in the logbook, the entry can be used for ratings and such. It's instruction.

If you don't, then it cannot be used for ratings, currency, or anything (and if
you are out of currency while you are doing it, it's illegal). So it's not
"official" instruction.

However, you are teaching something and the student is learning. To the best
of my knowledge, the mechanics of flying is not classified information. I
don't think there is anything to prevent you (whether or not you are a CFI)
from sharing your knowledge of unclassified material with any other person.

Jose






--
(for Email, make the obvious changes in my address)

On Mon, 11 Oct 2004 18:56:56 -0700, "David Brooks"
wrote:

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.

There is a blurb on the AOPA page where they are talking with the
bill's sponsor. His intentions were not what came out. It looks like
they are going to try to rework the bill, but as it's alredy been
passed how sucessful they are at changing things remains to be seen.

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com

snip

On Mon, 11 Oct 2004 18:56:56 -0700, "David Brooks"
wrote:

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.

There is a blurb on the AOPA page where they are talking with the
bill's sponsor. His intentions were not what came out. It looks like
they are going to try to rework the bill, but as it's alredy been
passed how sucessful they are at changing things remains to be seen.

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com

snip