SATCFI you may want to read this:
PART 61 FOQ
QUESTION: Per § 61.199(a), is it permissible for a flight instructor certificate to be reinstated (i.e., the flight instructor certificate has expired) on the basis of an applicant accomplishing an additional flight instructor rating practical test, even though the applicant was not tested on his existing flight instructor ratings? As for example, a person holds an expired flight instructor certificate (a certificate that was issued on or after November 1, 1975) with the following ratings: Airplane Single-engine, Airplane Multiengine, and Instrument-Airplane. The applicant is now requesting to renew his flight instructor certificate by accomplishment of a practical test for an additional flight instructor-Rotorcraft – Helicopter rating.
ANSWER: Ref. § 61.199(a); Yes, it is permissible for a flight instructor certificate to be reinstated on the basis of an applicant accomplishing an additional flight instructor rating practical test.
Answered by the FAA’s Donald P. Byrne, Assistant Chief Counsel, Regulations Division
July 14, 2000
Ms. Kathy Minner
Technical Specialist
Aviation Services Department
Aircraft Owners and Pilots Association
421 Aviation Way
Frederick, MD 21701-4798
Dear Ms. Minner:
This is in response to your letter dated February 4, 2000, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding § 61.199(a). Specifically, you are concerned about the reinstatement of expired flight instructor certificates and ratings.
As you point out in your letter, § 61.199(a) provides, in pertinent part, that the holder of an expired flight instructor certificate may exchange that certificate for a new certificate with the same ratings by passing a practical test for one of the ratings listed on the expired flight instructor certificate. (Emphasis added)
You also point out in your letter that the General Aviation Inspector’s Handbook provides, in pertinent part, that the holder of an expired flight instructor certificate may have all ratings on the certificate reinstated by satisfactorily completing a single practical test.
You think the General Aviation Inspector’s Handbook indicates that “any” practical test for a flight instructor certificate or rating would reinstate the expired flight instructor certificate and all the ratings on it. Based on that, you don’t think that the holder of an expired flight instructor certificate is limited to taking a practical for one of the ratings listed on the expired flight instructor certificate to reinstate it as provided for under § 61.199(a). Accordingly, you ask “may a flight instructor reinstate an expired flight instructor certificate by taking any practical test for a flight instructor certificate or rating, or must it be confined to one of those listed on the expired certificate as it seems to state in the regulation.” The answer to this question is discussed below.
§ 61.199(a) applies when the holder of an expired flight instructor certificate only seeks to have that certificate reinstated with the same ratings. It has been the policy of the Flight Standard Services (AFS-800), as articulated in the General Aviation Inspector’s Handbook, to allow the holder of an expired flight instructor certificate who seeks an additional rating to one of those listed on the expired certificate, to reinstate the expired flight instructor certificate, and all the ratings on that expired certificate, by taking, and passing, a practical test for the additional rating sought. As a result, the holder of an expired flight instructor certificate may have that certificate and all of the ratings listed on it reinstated by taking, and passing, any practical test for a flight instructor certificate or rating.
I hope this satisfactorily answers your question.
Sincerely,
/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division