Independent Instructors and the TSA

One day I received a letter from the TSA (Transportation and Security Administration). It seemed innocent enough - they wanted to have me call their offices to schedule an in person review of my flight instructor records. At first, I didn't really think anything of it since I keep pretty good records and had been instructing for quite a few years at the time, but for some reason something just didn't feel right, so I telephoned the AOPA legal services division to see if they had ever come across anyone receiving letters like this. They said that they have not, but they didnt think it would be anything to be concerned about since there have been rumors of Independent flight instructors being reviewed by the TSA.

Shortly after the attack on the World Trade Center in 2001, the TSA was formed and so were requirements for flight instructors.  Many of these requirements and procedures concern themselves with foreign citizens looking to get their pilot certificate or advanced ratings, however there are record-keeping requirements and a procedural nuance requiring all flight instructors to capture information from new students even as citizens of the United States.

I set up a date and time to meet with the TSA inspector at my local airport. There was a little bit of confusion, since I live in Indiana, but instruct out of Illinois based airports. The TSA agent said he was not able to come to an Illinois airport because it was out of his jurisdiction and we had to meet him in Indiana based airport, which I thought was strange, so I arranged to meet him at an airport in Indiana about 20 minutes from my home.

The meeting started off good.  He asked me if he could see my logbook to which I declined stating that I keep all of my records of students in a separate file. I showed him the file and the appropriate TSA sign-offs for all of my students.  He wanted to see the copies of my student's passports and I told him that I did not retain them since I didn’t want the liability if these records were lost or stolen.  He told me that it was required, but I challenged him to show me the requirement in the regulation.  He said he would get back to me, which he never did. He then asked to see my proof of my annual TSA training, so I did show him those, but I only had three past years of evidence. During the question and answer, one of the questions that he asked was on record-keeping requirements for the TSA, which I thought was 3 years, but that is actually for the FAA requirement for CFI record keeping, not TSA.... Which is 5 years.  He marked this in his ledger.  I told him that I had lost the other 2 years of evidence, but I certainly did take them and could probably provide evidence that I had paid for them through the American flyers program, which he had never heard of.  He also asked to see my initial training certificate which, luckily I had taped in the back page of my logbook many years ago when the TSA requirements started. I didn't think we needed to keep records of that, since the record keeping requirement was only 5 years for them.

The agent became a little agitated and proceeded to tell me that not complying with the TSA requirements could result in a $19k fine, but he was willing to let me off with a warning and that I needed to be reevaluated after 6 months. 

Six months came along with a phone call from the same TSA agent. I told him over the phone beforehand that I hadn't had any new students in the six months prior, but he wanted to meet anyway.  The second meeting was a waste of time. He asked for my logbook again and I declined again stating that I showed him all of my records already and they are still current.  I basically watched him fill out paperwork and we said our good bye, but not before he mentioned that he will be checking in with me in another 6 months. 

I then did some research and called the TSA offices downstate and was able to get a TSA Supervisor.  I politely mentioned to the TSA Supervisor that considering I do instruction for very few students that meet the requirements of 49 CFR 1552.3, I think the inspection requirements are a little unfounded.  The result of the conversation was that I submitted an affidavit to the TSA stating that I no longer provide any training as described in 49 CFR 1552.3 which includes training toward an initial pilot certificate, an instrument rating, or a multi-engine add on.

Admittedly, this was all done out of frustration, but in reality, I was at a point in my instructor career where I only had a few students that were going for ratings, and this gave me the opportunity to focus on specialized instruction and leave the instruction for ratings to the folks that do it all of the time and are likely a lot better than me at making sure all of the nuances of sending someone for a rating are met.  A fringe benefit was that I dropped student pilot training from my liability insurance and saw a drop in premiums.

The moral of this story is that the TSA is ramping up efforts to identify independent instructors and review their paperwork.  More often than not, I am sure the experience will be a good one, but for me it was a challenge.  The silver lining was that I was able to focus my efforts on a different side of instruction.

Com 3??

As an instructor, there are many times where you just want to mute the radios, or quickly shut off what's happening on the frequency. Most of the time with older radios your only option is to use the volume knob, or the switching panel to switch off the audio coming from the radios.

I've been using a new trick on some of the new Garmin switching panels, which is to press the COM3 button. Since most aircraft that I fly and don't have a COM3, the button is not wired to anything and it is a quick way to shut off all communications and all radios without messing with the volume knobs or the switching panel.

The Intermediate Fixes and Procedure Turns/Course reversals

I was asked about this IF business on approach charts.  Sometimes they are there and sometimes they arent.  Why bother putting them on the approach chart if they dont have any real significance?

I think that is precisely why they are on the chart - to denote them as a relatively insignificant point in space - and not to be confused with an IAF or FAF.

Take a look at the Kankakee RNAV 22 Approach (KIKK).  COYAP has both an IAF and IF depicted that way because COYAP has different functions depending upon where you start your approach.  If you use LUCIT for your IAF, COYAP becomes an IF (an Intermediate Fix is just a designation so that the pilot doesnt confuse it for a FAF, or IAF).  The LOC 36 into Lansing (KIGQ) gives a better depiction of when an IF is used.  In the Lansing example, your IAF is EON (Peotone), you have an IF of TOGOC (which is nothing more than a point that intersects the EON 065 Radial and the Localizer) and the FAF is WOKLA (Even though it says IAF on the chart, in the profile view, the Maltese cross signifies it as such).

Now, heading to COYAP from the north, we received a vector of something like 220 degrees, then direct COYAP a few moments later - which was like a 180 degree heading.  Do we really have to do the course reversal?  We are basically heading south and it is only about 20 degrees to get on course once you hit COYAP.  BUT, check out AIM 5-4-6 (e, 4) and AIM 5-4-9.  Basically, if there is a course reversal, or procedure turn depicted on the chart, you have to do it....  Unless... you are being radar vectored onto the final approach course (which probably wouldn't happen on the RNAV22 for IKK because there is no real extended center-line) OR it says No PT (and of course, the test question about timed approaches from a holding fix).  A lot of times, controllers give radar vectors to the ILS to get on the final approach course - that's why you can go straight in:  "Bonanza 1234, turn left heading 180, intercept the localizer, cleared for the approach".

If we started the approach from LUCIT, we wouldn't do the Procedure Turn.  If we started the Approach from EON (OR COYAP), we would.

Alternate GPS ON Switch?

I first read about this "switch" in an article published by a flight instructor that I respect - Darren Smith. One of his popular "top ten" lists consisted of things that can help the single pilot IFR pilot juggle the work load. The article can be found here

Im going to come right out and say that I don't think this is worth the effort and money...
... and I can only say that for myself, you may need to consider where you fly and how the IFR system works in your neck of the woods, but flying in the Chicago area can be tricky when given departures and arrivals.

When flying down to Carbondale, I usually file a known outbound fix - Peotone (EON) and then an inbound fix near Carbondale called Centralia (ENL). Most of the time I get it, and another part of the time, I get "proceed direct Carbondale." This is almost a 250 mile trip. Regardless, the time it takes me to click in EON, then ENL, then KMDH, is about 30 seconds. I dont think that is too long of a time to enter a flight plan. If it takes you longer, then I think time is better spent in practicing entering the flight plan.

Here is a case in point - On my way home from Carbondale, I flight plan for VNN, CGT KIGQ. I always get it. However, sometimes around KCMI, I will get a re-route for traffic flow in Chicago. Sometimes I will get PNT V69 JOT CGT KIGQ... Sometimes I just get JOT CGT KIGQ... Sometimes I get a "proceed direct". You have to be able to do this in the air.

Im not sure what the switch is going to save you.

Self Criticism

If I had a criticism about myself, I would say that I talk too little. Some instructors talk too much. One instructor I had didnt talk too much, but rather spoke at the wrong times.

As we were about to do a maneuver like landing practice, right as I was about to take corrective action the instructor would blurt out "add power" or "correct heading". I would compensate for the instructor making those comments by trying to make the correction a little earlier than I would have normally just so I could be ahead of the instructor - prompting more questioning.

So, I need to improve on verbalizing a little more. I like to see if the student will make the correction themselves, but I need to recognize that if the student is not making the correction after a couple of times, I need to speak up.

One of the things I don't do enough of is demonstrations. The first time or two a maneuver is introduced, it is demonstrated, but after a certain amount of practice that demonstration is usually a forgotten zap between the synapses of their brain.

Time and time again when working with a student, I will find myself continually coaching and verbally correcting, but once I do a demo, a break through normally happens. This not only gives the student a little break, but allows the instructor to fly a little bit. All kidding aside, it takes the pressure off of the student for a little while so that they can focus on what you are actually saying rather than responding like a robot and not really listening. A picture is worth a thousand words and when a student observes the correct way to perform a maneuver, it usually clicks.

Class G

My buddy sent me the following email just the other day:
"I could hear an RV taking off below me. He was startled when I announced my missed approach; he said "where did he come from?" I announced my position and intentions since Rockford switched me to UNICOM at CABKO. Did that RV pilot have legal VFR minimums-- the AWOS said 1 1/2 and 300'! The sectional shows class E--I think. Magenta shading."

I responded with:
I looked on skyvector.com and see what you are talking about with the magenta circle... This means that there is class G airspace from the surface up to 700 ft AGL, so technically, he could take off and stay clear of clouds with 1 mile of viz while below 700ft AGL, then he needs the usual cloud clearance and visibility once above 700ft since he will be in class E. This is a good example of why airports like KDNV, or even Clinton - KCWI have that funky class E Airspace to the surface - to protect arriving IFR aircraft from goof balls like that RV from taking off with out the proper cloud clearance (but then again, they probably dont give a crap and would anyway)...

RNAV 7 to Rochelle - KRPJ

A friend of mine flew to KRPJ this morning. AWOS advertised wind 010@5kts, 1 1/2 mile, broken 300'. He flew the RNAV 7 approach. The LNAV minimum for straight in is 1140 and 1 mile visibility.

He gives me the following additional information:
- MDH is 400 ft
- Field elevation 781'
- He went missed at 1200'

His concern was the MDA is 1140 but that 781' (Field Elevation) + 400 feet (MDH) is higher! He wanted to know if he could legally fly this approach to the MDA of 1140 and said that the ceiling requirement conflicts with the MDA and calculated MDH & FE figures.

I really haven't thought about looking at the MDH and field elevation to see if they add up to the MDA. Not sure why he did this, but it was a great catch! So we thought...

Taking a look at the approach chart, I saw what was happening. There is a little (400-1) designation next to the MDH figure which should be ignored. It is for military operations, but I really cant find any official information on what that means. Do military operations have higher minimums than civil aviation? If he wanted to do the math, he should have used 364 - the figure just to the left of the military minimum figure.

The MDA is also calculated from the TDZE of the runway which is 776 and not 781, so that kind of skewed the calculation even further.

I'm using Jeppesen charts right now and didn't see what he was seeing right away. After figuring it all out, I went back to my Jepps and couldn't even find that military MDH and visibility figure on the charts anywhere. I guess the military are probably bound by some regulation to use the government charts, so Jeppesen probably doesn't even bother with including them on their charts.

With all of the acronyms, its hard to keep MDA, MDH, DH, DA, La-de-da all straight. Frequent review of the charts and analysis of every little notation is important so that you don't get caught off guard in the clouds when workload is high.