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Does a CFI need TSA approval to provide endorsement training to non-US citizens, such as the complex, high performance and tailwheel endorsements laid out in 14 CFR 61.31?

Recurrent training is exempt from TSA approval, however training for an endorsement isn't recurrent because it doesn't have to happen again. And it includes training in an aircraft, which usually requires TSA approval.

Some places such as AOPA suggest all of 61.31 is exempt:

He/she is seeking recurrent training, such as a flight review, instrument proficiency check, or flight training listed under 14 CFR 61.31

But the TSA only suggests that 61.31(g) is covered:

High Altitude Training (HAT) 14 CFR Part 61.31(g) - Type rating requirements, additional training, and authorization requirements.

If only 61.31(g) is exempt then only high altitude endorsement training is exempt, and TSA approval is required for complex, high performance and tailwheel. Is that accurate?

Government references are highly appreciated.

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Assuming the crux of this question is about the need for TSA clearance for the training then the answer can be found in the FAQ section of the flight school candidate website under the question; When is a flight student exempt from the requirement to undergo a TSA security threat assessment?

You will see a table with some exemptions including the 14 CFR §61.31(g) exemption. The table is prefaced with the statement;

Other training activities that do not require notification to TSA are exempt only if the candidate holds an FAA stand-alone Pilot certificate

In other words a pre-existing FAA pilots license acts as some what of a verification and you do not need to be re-verified.

Interestingly only 14 CFR §61.31(g) is exempt so presumably only the high altitude sign off can be obtained under this exemption the rest of 14 CFR §61.31 does not fall under it. I would say the AOPA site is incomplete in their information. A CFI may provide training for 14 CFR §61.31(g) without TSA authorization but if the student is seeking training on any other endorsements under 14 CFR §61.31(g) then they must get cleared by the TSA.

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  • $\begingroup$ So, what do CFI's currently do? Do they provide the training for a complex endorsement if a current / valid pilots license is provide? Or do they re-initiate TSA checks? What is the current industry practice in these cases? $\endgroup$ – chup Nov 8 '19 at 13:26
  • $\begingroup$ @chup The regulations would prevent them from providing training for a complex endorsement until such a time as all TSA paperwork is sorted. If you can prove you have been cleared by the TSA or the flight school clears you, you can train. Its also important to stress that it must be an FAA Issued license $\endgroup$ – Dave Nov 8 '19 at 13:30
  • $\begingroup$ Thank you for all the insight I really appreciate it. Given that a cfi and a flight school are both flight schools, do you know where the regs state that if the flight school I work at clears it, I can train? $\endgroup$ – chup Nov 8 '19 at 16:08
  • $\begingroup$ @chup do you work at a US flight school are you legal to work in the US? (this likely changes things). I would think that both a flight school and/or CFI can submit the paperwork but ultimately as the PIC the CFI is the last decider. $\endgroup$ – Dave Nov 8 '19 at 16:52
  • $\begingroup$ Person has current valid pilot certificate, Flight school says person is good to instruct for complex endorsement. Complex endorsement is not on the list here: flightschoolcandidates.gov/home. So how is it safe to provide that instruction? $\endgroup$ – chup Nov 8 '19 at 18:38
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As far as I can see you don't need TSA approval for any of the 61.31 endorsements because they don't meet the TSA's definition of "flight training" that they clarified in a letter to AOPA:

“Flight training” is defined in 49 CFR 1552.1(b) as “instruction received from a flight school in an aircraft or aircraft simulator.” TSA interprets this definition to include only that training that a candidate could use toward a new airman’s certificate or rating.

Endorsements are neither certificates nor ratings. All the flight training events that do require TSA approval - initial, instrument, multi-engine and type ratings - do result in another certificate or rating.

As for why the TSA specifically calls out 61.31(g), I suspect that whoever put together the FAQ didn't pay attention or just didn't think that other endorsements were relevant. I can't find any other document or source where the TSA calls out the high-altitude endorsement specifically, or even mentions the other endorsements. If they really insisted on approving tailwheel training I'd expect to find some references easily, if only because AOPA and EAA would have kicked up a fuss by now.

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