CFI “Experience Validation” (No Expiration)?!

This image from an FAA presentation got a lot of attention (and I am sorry we do not have much information yet). But this is a very early “pre-decisional proposal” – basically a “media balloon” – intended to test public opinion and start a discussion (yes the FAA watches social media very carefully). The FAA proposal is to eliminate expirations for flight instructors and simultaneously restrict “exercising the privilege” based on some required activity and/or experience – consistent with most other certificates. Any formal proposal will have to go through a very long official NPRM – comment – process. This will require lots of input from industry and individual CFIs – so don’t panic yet. This idea has been around for many years – see this article from 2010  and there are some good reasons to consider a change. More details will be forthcoming from the FAA, but let’s explore this just a little.

This action would remove the expiration date on flight instructor certificates. In addition, it would remove the requirement for a flight instructor to renew his or her flight instructor certificate. Instead, the rule would call for the flight instructor to meet and demonstrate recent experience requirements to exercise the privileges of his or her certificate.

I renewed a CFI Friday (as this story was breaking) using his FAA WINGS activity. Remarkably, this is not on the FAA WINGS Instructor page but only available in AC 61-91J. But wouldn’t it be great if there was a tab on the FAA WINGS site where a CFI could keep their instructor certificate valid – no FIRC – the same as pilots keep their certificate current? The WINGS program would be a natural learning platform for providing CFIs with “master-level” education. The FAA already has lots of other “activity renewals” under CFR 61.197(a)2ii. Most DPEs can perform any of these functions and it currently only takes about 10 minutes to renew based on activity. CFIs are qualified for renewal under CFR 61.197(a)2ii based on their activites/experience over the last two years. I would imagine the new process would be similar but not require the DPE.

Many part-time CFIs immediately expressed displeasure, imagining the FAA will only count 8710 sign-offs for “activity” – and their instructor privileges might be in jeopardy. But “active” by that definition only represents 8% of the current CFI population. And professional pilots, teaching part-time, are the richest source of experience in our flight training community. FIRCs, now almost exclusively online, have increasingly diminished in duration and quality in recent years. And the NTSB is crying for better FAA oversight of CFIs – and enforcement of an 80% pass rate for active CFIs. Change is in the wind, we’ll soon see where this goes. Fly safe out there (and often).

Thank you to Jason Blair for the link to the new FAA proposal: HERE

Join SAFE and enjoy great benefits (like 1/3 off ForeFlight)! Your membership supports our mission of increasing aviation safety by promoting excellence in education.  Our FREE SAFE Toolkit App puts all required pilot endorsements and experience requirements right on your smartphone and facilitates CFI+DPE teamwork. Our SAFE CFI insurance was developed by SAFE specifically for CFIs (and is the best value in the business). #flySAFE

Author: David St. George

SAFE Director, Master CFI (12X), FAA DPE, ATP (ME/SE) Currently jet charter captain.

10 thoughts on “CFI “Experience Validation” (No Expiration)?!”

  1. As my blog post from 2020 (referenced in your article) explains, I am in favor of removing the expiration date on CFI certificates. AOPA long ago proposed that CFIs log activity and/or retain a course completion certificate from a FIRC or other recurrent training as an “endorsement,” like a flight review endorsement, that allows an instructor to continue acting as a CFI. Removing expiration dates would also reduce the paperwork burden on FAA, which must process all the CFI renewals as they do all new pilot certificates. I also strongly endorse the idea of eliminating FIRCs in favor of other more effective evidence of instructor currency.

    1. There certainly is an opportunity to reduce “friction” and workload and increase professionalism. We’Lk see if it “flies” this time👍✈️

  2. Both for and against. Technically you can never take to the air ever in an aircraft and retain a biannual flight review through the wings program in a Red Bird Sim.
    That is right, you can go decades without flying and get your biannual renewal through the wings program and be ‘legal’ to fly.
    That is a frightening thought, but driving a car requires far less and the highways are not safe now.

    1. Safety (despite all rules) depends on the operator’s judgment and risk management. Most “FAA minimums” – starting with “1 sm clear of clouds” – are scary! Flight review people come in after 15 year lapse and expect 61.56 min “one hour of ground, one hour of flight” – “like riding a bicycle” NOT!

    2. I would welcome that -provided- the CFI can show recurrent training similar to something like 135 pilots have to do every 6 months. At the very least a refresher on the regulations and latest teaching techniques/theory.

  3. I do not agree with this proposal. The eFIRC from AOPA is a great refresher tool and in no way diminished in subject matters or content. I used it to renew my CFI last year. The presentations where so good that I did ALL the modules, not just the required ones. I understand that there are some cheap or free eFIRCS out there. They need better oversight!

    Basing CFI privileges on “currency” is a trojan horse. Define “currency”! 10x a filed 8710 for a MEL or more? This way only big flight schools will survive and we will loose the experience of an airline pilot who instructs on the side.

    It would be more prudent to oversee the quality of instruction at those big academies. I seen horrible things in my 30 years of flying.

    I am a retied airline pilot and Checkairman who is still flying for a private company and instruct on the side.

    1. According to what we have learned, FIRCs will continue (as before) and no CFIs lost – every CFI will have a pathway to meet the “current experience” requirements. Fear-mongering has given the mistaken idea that “active” is only 8710 pilot recommendations – NOT!

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