Subject: Fwd: Re: CFI renewal ambiguity Return-Path: Subject: Re: CFI renewal ambiguity To: MARKBOYD@aol.com Mark, You are correct, "applicant" or "applications" is the intention and would have been better. We too often mix terms or use the same word in various and numerous context. "Student" should only be used for those that hold a student pilot certificate, but "student' obviously works well for someone receiving training as it was used in this case. There was no intent to exclude the possibility that the same person could prepare for advanced ratings or certificates. Allan Pinkston, AFS-640 (405) 954-6472 MARKBOYD@aol.com To: K Allan Pinkston/AMC/FAA@FAA 08/30/2002 01:55 cc: mjboyd@cse.ucsc.edu PM Subject: CFI renewal ambiguity K.Allan.Pinkston@faa.gov Dear Sir, I have a question about 61.197(a)(2)(i). I recently renewed my CFI by showing the examiner a record of five recommendations for practical tests where there were four passes. However, I had only recommended four students (one I had recommended for a private and passed, then a year I recommended him for an instrument and he failed). 61.197(a)(2)(i) says the instructor must have recommended five "students" not endorsed five applications. Was this the intent of the section? Or was the intent "applications," meaning (in the most extreme case) that an instructor with only one student could recommend him for a private ASEL, then private AMEL, then instrument ASEL, then commercial ASEL, then commercial AMEL, and if that one student passed at least 80% of these tests the instructor could renew? The FSDO inspector interpreted the section this way, but based on my other BFR and IPC and Wings activity, determined I would qualify under 61.197(a)(1)(ii) anyway as "in a position involving the regular evaluation of pilots," so in my case it made no difference. Perhaps using the word "applications" instead of "students" and "at least 80 percent of those applications were approved on the first attempt" would be more clear. Mark J. Boyd 602 Chestnut #1 Santa Cruz, CA 95060 (831) 425-2693 markboyd@aol.com