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11 Answers

Flight Review in a taildragger. Instructor qualifications?

Asked by: 8800 views FAA Regulations

Flight review coming up and I located an instructor but she says that she can't fly with me (in my 185 Skywagon) because she does not have a tail wheel endorsement! Same thing for an IPC which I also need.

Are there any instructors out there who might have the real story on any regs that pertain to this. I looked and found that you need an "authorized instructor" for the Flight Review. Nothing about an instructor needing a tail wheel endorsement, just category and class and a type rating if the aircraft needed one.

(b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

(1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and

(2) If appropriate, a type rating.

Yes, an instructor would need a tail wheel endorsement if she were the PIC, but on a Flight Review, it's my understanding that the one needing the review is PIC.

I'm also calling our FSDO to see what they say.

Thanks in advance for any help on this!

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11 Answers



  1. Kris Kortokrax on Jun 20, 2014

    If your flight review has expired and the instructor needs to act as PIC, then the instructor would need the endorsement.

    If you were a pilot who had not flown recently in a tailwheel airplane or who did not have much experience in the plane, it would probably be a good idea to find an instructor with that experience.

    I would find a more knowledgeable instructor to give you the flight review. If you need to explain the regulations to her, she is not the one.

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  2. Mark Kolber on Jun 20, 2014

    It’s pretty much an open question.

    In the orphaned Part 61 FAQ, John Lynch of FAA Flight Standards gave a clear “no” – that the language in 61.1 defining as authorized instructor as one who is acting “accordance with the privileges and limitations of his or her flight instructor certificate” includes the flight instructor’s endorsements.

    Whether or not that analysis is correct from a regulatory standpoint – there are many who say it is not – I think the instructor you asked is making the right decision. Let’s make the scenario a bit more interesting – you have a landing incident the FAA investigates. Consider how the instructor would answer the simple question: “What made you think you were qualified to instruct in a tailwheel with no tailwheel experience yourself?”

    I would not care at all what the guy who happened to answer the phone at the FSDO that hour happened to say (call another time and you are likely to get someone with a different answer).

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  3. George Dyer on Jun 20, 2014

    “Consider how the instructor would answer the simple question: “What made you think you were qualified to instruct in a tailwheel with no tailwheel experience yourself?”

    Mark…Thanks for the reply and I am inclined to agree with your answer, knowing how the FAA would ultimately deal with a landing incident.

    Where I would still argue is on the fact I am clearly PIC (with over 1000+ comm. inst. in 185s) and the instructor is not giving instruction but rather doing what the Flight Review task requires, a “Review”. However if I screw up a wheel landing the instructor might want to show me how it should be done.

    Where I’m pissed.. is that I called made the appointment for the review, the gal said great, no problem, hours worth of driving, I arrive, and she says..can’t do it.

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  4. Mark Kolber on Jun 21, 2014

    Where I would still argue is on the fact I am clearly PIC (with over 1000+ comm. inst. in 185s) and the instructor is not giving instruction but rather doing what the Flight Review task requires, a “Review”.

    The problem with that analysis is what the very first sentence of the Flight Review regulation says about what the Flight Review is.

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  5. Kris Kortokrax on Jun 21, 2014

    Mark,

    The FAA removed the FAQ because it had no legal standing (I know you know this, just repeating it for the benefit of George).

    I have spoken with John many times in the past. One conversation concerned his definition of “high performance” in terms of horsepower. I suggested to him that he should define performance in terms of actual performance rather than horsepower since a Stearman with a 220 hp Continental engine cruising at 90 MPH would be considered “high performance”, yet a Seneca I with two 200 hp engines cruising at 150 K would not be considered “high performance”. He refused to consider modifying the definition.

    Also, if we use his definition requiring endorsements, a CFI would not be permitted to conduct a flight review in a Cessna 182 without first acquiring a high performance endorsement (which could be acquired in a 90 MPH Stearman).

    He has demonstrated a lack of critical thinking ability.

    Further, just from the standpoint of friendly debate, 61.56 leaves up to the flight instructor the maneuvers to be “reviewed”. While I think it would be ludicrous to conduct a flight review without evaluating takeoffs and landings, an instructor could try to make that case.

    Having said all that, I would question why a pilot would not seek out an instructor with tailwheel experience to conduct the flight review. In this day and age, I realize that there is a plethora of instructors trained in Cessna 172s with G1000 and relatively few with actual tailwheel experience. Also, possession of a tailwheel endorsement obtained in a Cub or Champ would not necessarily guarantee that the CFI could provide meaningful instruction in a Cessna 185 (which according to John, would also require a high performance endorsement).

    George,
    I don’t understand your comment about hours of driving to reach the instructor. Maybe you meant to say hours of flying (I presume you were using your plane).

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  6. Mark Kolber on Jun 21, 2014

    Kris, you won’t get any disagreement from me about the number of things in the orphaned FAA that are incorrect or the various mistakes John made in many of the answers. We could probably trade more than a few stories on that one!

    OTOH, while the FAQ has never been the authoritative last word on a subject of regulatory interpretation – the FAQ itself said do – it did and does* represent the thinking of Flight Standards, whether correct or not.

    Personally, I think it was removed mostly because of the problems incorrect answers caused, especially when those answers conflicted with the thinking of the Chief Counsel’s office. I know of one enforcement action that was terminated in part due to this problem. I can’t say it was the proverbial straw that broke the camel’s back but the timing suggests more than coincidence.

    *did and does – I know of people who deal with Flight Standards who say that the FAQ remains an internal document and continues to be updated. I can’t vouch for that personally, especially since Lynch’s retirement, but I did see a new numbered FAQ Q&A as recently as 2010 – some 4 years after the FAQ was removed. Punchline you’ll like – the answer was incorrect.

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  7. Bradley on Jun 22, 2014

    I think you have to give “John” a break. One guy at a FSDO cannot simply rewrite federal laws. It is his job to interpret and implement the law. I’m frankly glad it is not so simple as every FSDO able to change the rules to whatever they think best. Your logic is sound, it’s the rule that is flawed.

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  8. Mark Kolber on Jun 22, 2014

    You are right, Bradley. My personal view on the FAQ has always been that it is better for FSDO Inspectors to uniformly get it wrong, with the ability to correct all at once, than for different FSDOs to have different interpretations. I was sorry to see it go despite its flaws.

    That’s why I’m pleased at reports that it still exists as a guide for inspectors.

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  9. Kris Kortokrax on Jun 22, 2014

    Bradley,

    I’m not sure how much of a break we need to give to John. He did not just interpret and implement the regulations (not laws), he headed up the committee that did the rewrite in 1997. He also headed the committee that did the rewrite in 2009. He had an opportunity to correct the flaws in the regulations, but chose not to.

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  10. George Dyer on Jun 22, 2014

    Kris,

    Thanks for the reply. In it you said ” George, I don’t understand your comment about hours of driving to reach the instructor. Maybe you meant to say hours of flying (I presume you were using your plane).

    Kris, I had an hours worth of driving to and from the airfield where my airplane is hangared and the instructor is located. Even though the instructor initially agreed to do the review, when I got there she said no. I’m OK with it, but would have rather have gotten a phone call.

    When I did my part 135 check rides I never thought to ask if the check pilot had a tail wheel endorsement. I do understand the need for a better written rule, which would include wording for instructors needing tail wheel endorsement if they do a flight review in a tailragger.

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  11. Kris Kortokrax on Jun 23, 2014

    Not sure when you did your 135 check. If it was within the last 24 months, that will suffice for a flight review for 24 months after you did the check.

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