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TSA Clarifies/Updates "Recurrent Training" Requirements For Alien Flight Training

By Reigel & Associates, Ltd.

In a recent Interpretation, the TSA clarified the activities that are not considered recurrent training. As a result, alien flight training students will now be able to receive the following types of flight training without having to first submit to a Category 4 Security Threat Assessment ("STA"):

• Instrument Proficiency Check;

• Heads Up Display (HUD) Training;

• Enhanced Vision System (EVS) Qualification;

• Line Oriented Flight Training (LOFT);

• Operator Specific Proficiency Checks;

• Landing Currency;

• Category I / II Qualification;

• Special Airport Qualifications;

• Examiner Training; and

• Differences Training

The Interpretation is based upon the TSA's determination that these types of flight training "are not described as recurrent training in Federal Aviation Administration (FAA) regulations; they are not training, rather they are checks or tests; or they do not affect the validity of the certificate(s) and/or the qualifications of a type rating."

The Interpretation also includes a change to the STA process "to permit recurrent training candidates who have undergone a successful STA within the previous year to begin recurrent training without waiting for the results of the new STA once TSA accepts all documentation." Each student will still need to undergo a new STA, including submission of documents and payment of fees, but if the training provider ensures that a proper STA submission has been made, the student will be able to begin recurrent training prior to receiving the results of the STA.

The TSA's clarification and change in procedure will certainly make the process of training alien students more efficient for flight schools and for their alien flight training students. It is nice to see the TSA actually do something that makes sense and will actually help the aviation industry. Hopefully the TSA will take this same approach as it reviews security at general aviation airports. Keep your fingers crossed!

Full post as published by Aviation Law Discussions on September 16, 2010 (boomark / email).