Confusing requirements for towered airport endorsement

6 Answers

1. 
   

   
   

   John D Collins on Dec 15, 2020

   Just reading thru the two regulations,

   61.94 deals with a Student pilot seeking a sport pilot certificate or a recreational pilot certificate. They need the endorsement for each airport and involves ground and flight training and an endorsement. This endorsement only applies to student pilots and not to rated pilots.

   61.101 says a rated recreational pilot needs training and an endorsement in order to act as PIC in a class D, C, or B airspace or a towered airport. Without this endorsement, a recreational pilot does not have the basic privilege of operating in any B, C, or D or towered airspace.

   +1 Votes 1 Votes  0 Votes

2. 
   

   
   

   stillkicking on Dec 16, 2020

   John, thank you for your reply.

   So, does the training as a student pilot, in regards to work done at towered airports to meet the requirements of a sign off for that one airport…. does that training translate to what is needed of the rated recreational pilot meet the needs for a blanket towered airport endorsement?

   In any case, then, how many different towered airports are required to meet the rated pilot towered airport endorsement?

   0 Votes 0 Votes  0 Votes

3. 
   

   
   

   John D Collins on Dec 16, 2020

   The way I read the regulation, for a student pilot, each airport airspace that qualifies requires a separate endorsement and it is only good for 90 days.

   61.94 in part:
   (4) Ground and flight training for the specific Class B, C, or D airspace for which the solo flight is authorized, if applicable, within the 90-day period preceding the date of the flight in that airspace. The flight training must be received in the specific airspace area for which solo flight is authorized.
   (5) Ground and flight training for the specific airport located in Class B, C, or D airspace for which the solo flight is authorized, if applicable, within the 90-day period preceding the date of the flight at that airport. The flight and ground training must be received at the specific airport for which solo flight is authorized.
   (b) The authorized instructor who provides the training specified in paragraph (a) of this section must provide a logbook endorsement that certifies the student has received that training and is proficient to conduct solo flight in that specific airspace or at that specific airport and in those aeronautical knowledge areas and areas of operation specified in this section.

   OTOH, none of this training needs to be provided for a pilot to obtain their recreational pilot certificate and by default, such rated pilots are limited and do not have the privilege to fly into Class, B, C, or D airspace or towered airports. To do so requires the training and endorsement in 61.101(d)

   (d) A person who holds a recreational pilot certificate may act as pilot in command of an aircraft in Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower, provided that person has—
   (1) Received and logged ground and flight training from an authorized instructor on the following aeronautical knowledge areas and areas of operation, as appropriate to the aircraft rating held:
   (i) The use of radios, communications, navigation system and facilities, and radar services.
   (ii) Operations at airports with an operating control tower to include three takeoffs and landings to a full stop, with each landing involving a flight in the traffic pattern at an airport with an operating control tower.
   (iii) Applicable flight rules of part 91 of this chapter for operations in Class B, C, and D airspace and air traffic control clearances;
   (2) Been found proficient in those aeronautical knowledge areas and areas of operation specified in paragraph (d)(1) of this section; and
   (3) Received from an authorized instructor a logbook endorsement, which is carried on the person’s possession or readily accessible in the aircraft, that certifies the person has received and been found proficient in those aeronautical knowledge areas and areas of operation specified in paragraph (d)(1) of this section.

   So the instructor that provides the 61.101(d)(3) endorsement, must have provided the instruction. There is no specification as to how many airports this must have been accomplished at, but the pilot must have done three takeoffs and landings at a towered airport in the traffic pattern to a full stop. I think it would be possible for the same instructor to have provided a 61.94 endorsement to qualify for some of the experience and instruction requirements, but not necessarily all. The 61.94 requirement is for a specific airport and specific airspace, for example class D only at a specific airport, say the Class D at KVUJ. The 61.101 endorsement includes all airspace types and is more general. Certainly, if the instructor making the 61.101 endorsement has to be the one that provided all of the relevant instruction and whether or not earlier instruction would count towards the endorsement is not a question I would answer without a FAA general counsel opinion on the subject, but if I was asked to provide the 61.101 endorsement to a rated pilot, I would review all the knowledge areas, provide any needed ground training and require that I provide the flight training at least one towered airport before I would be willing to certify it in an endorsement.

   +3 Votes 3 Votes  0 Votes

4. 
   

   
   

   stillkicking on Dec 24, 2020

   Again, thank you for your reply.

   You mention “a FAA general counsel opinion on the subject”.

   Any idea how a student pilot might obtain such clarification on the matter from the FAA?

   Surely I am not the first to ask this question.

   Thank you.

   0 Votes 0 Votes  0 Votes

5. 
   

   
   

   John D Collins on Dec 26, 2020

   I really doubt anyone has asked the FAA Chief Counsel this question. I searched the current FAA downloadable database of pilot certificates. There were about 485,712 pilots of all kinds. Of those only 101 hold a Recreational Pilot Certificate. More popular is the Sport Pilot Certificate, there were 5,622 entries. There were 137,924 Student pilots, 130,034 Private Pilots, 92,564 Commercial Pilots, and 119,467 ATP rated pilots. So 101 out of 485,712 is only 0.02% Because of the restrictions and the introduction of the Sport Pilot rating, there is close to zero interest in the Recreational Pilot rating as it has too many limitations and it is almost as easy to just get one’s Private Pilot that does not have similar restrictions.

   My comments about clarifying the applicability of using logged endorsements as a student to fly into/out of class B, C, D and towered airports for meeting the regulation requiring an endorsement after they are rated is the only area that may be fuzzy and need some clarification. If you want to ask the FAA Chief Counsel for an opinion, you can try sending your question to Mark.Bury@faa.gov who is an assistant chief Counsel whose office handles these question, but personally I don’t think it is worth asking. I would just get the endorsement and ignore the student log entries or continue on and get the rest of the training for a private pilot certificate.

   I also suspect that if one is getting their training while based at a towered airport is probably the only legitimate reason one would need the endorsement during training as a student.

   0 Votes 0 Votes  0 Votes

6. 
   

   
   

   stillkicking on Dec 27, 2020

   Your advice makes sense and I will likely go that route.

   The time (hours) I have already invested in towered airport training will not be in vane as it all goes into the vault.

   For me, the recreational pilot certificate made the most sense given my age (late 60\’s), and my desire mainly to just go up in my Cessna 150 with my little dog and fly around on nice days.

   I will say it has not been a easy path and one made more difficult by flight schools and freelance CFI\’s reluctant to offer the training.

   Thanks again.

   +1 Votes 1 Votes  0 Votes