• U.S. citizens who are receiving flight training
  You must prove citizenship before beginning primary, instrument, or multiengine training in an aircraft under 12,500 pounds.
   
• Resident aliens (green-card holders)
  You must receive TSA clearance before beginning primary, instrument, or multiengine training in an aircraft under 12,500 pounds.
   
• Visa holders
  You must receive TSA clearance before beginning primary, instrument, or multiengine training in an aircraft under 12,500 pounds.
   
  • Visa information

   

What's New

March 4, 2005
TSA made several improvements to the registration process at both the alien flight student program provider and student Web pages. This new information affects all categories of candidates and also provides instruction for flight training providers located outside the United States.

January 5, 2005
TSA has provided additional clarification on the definition of "flight training" for aircraft with an MTOW of 12,500 pounds or less; it now only includes flight training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating.

November 15, 2004
TSA issued recent guidance to further clarify the 60-day exemption for aliens. Aliens who currently hold a pilot certificate and who begin training for a new certificate or rating prior to December 20, 2004, do not need to comply with the rule.

October 29, 2004
TSA has determined that airships, balloons, and gliders pose a minimal threat to aviation and national security and has granted an exemption for those schools that provide, and individuals who apply for, instruction in the operation of airships, balloons, or gliders. This exemption also exempts schools that only provide instruction in airships, balloons, and gliders from the security awareness training requirement.

Outline of Rule

On September 21, 2004, the Transportation Security Administration (TSA) issued an "interim final rule" on flight training for aliens and other designated individuals. As currently written, the rule requires every person to prove his or her citizenship status (including U.S. citizens) prior to undertaking flight training for the issuance of a new certificate or rating or the addition of a certificate or rating (does not include recurrent training), in an aircraft weighing 12,500 pounds or less. Additionally, foreign flight students must complete a background check process with TSA.

This rule also requires flight schools and flight instructors to provide security awareness training to each ground and flight instructor and any other employee who has a direct contact with a flight school student (regardless of citizenship or nationality) and to issue and maintain records of this training.

What the Rule Means to:

U.S. citizens who are receiving flight training

1. U.S. citizens (whether by birth or naturalization) beginning training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating, on or after October 20, 2004 in an aircraft weighing less than 12,500 pounds must present the flight school or flight instructor with evidence of U.S. citizenship. Evidence must be shown by one of the following:
   1. Valid unexpired U.S. passport.
   2. Original birth certificate of the United States, American Samoa, or Swains Island, and government-issued picture ID.
   3. Original certification of birth abroad with raised seal (Form FS-545 or DS-1350) and government-issued picture ID.
   4. Original certificate of U.S. citizenship with raised seal (Form N-560 or N-561), or a   Certificate of Repatriation (Form N-581), and government-issued picture ID.
   5. Original U.S. naturalization certificate with raised seal (Form N-550 or N-570) and a government-issued picture ID.
2. The instructor must then comply with one of the following two options:
   1. Make an endorsement in both the instructor's logbook, or other record used by the instructor to record flight student endorsements, and the student's logbook with the following:
      "I certify that [insert student's name] has presented me a [insert type of document presented, such as a U.S. birth certificate or U.S. passport, and the relevant control or sequential number on the document, if any] establishing that [he or she] is a U.S. citizen or national in accordance with 49 CFR 1552.3(h). [Insert date and instructor's signature and CFI number.]"
   2. Keep a copy of the documents used to prove citizenship for five years.
3. Flight training may begin after the documents have been reviewed and either the logbook endorsement is made or copies are obtained by the instructor.

Resident aliens (green-card holders)

Resident aliens who begin training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating, after December 20, 2004, must notify TSA of their intent to begin flight training. The notification process is as follows:

1. The applicant registers on TSA's Web site, www.flightschoolcandidates.gov, at which point they will be given a username and password via e-mail. After receiving the e-mail, the student logs in to the site and submits the following:
   • Full name, gender, current address and five-year address history, date and country of birth, and citizenship information.
   • TSA identification number (not provided to candidate — only seen by TSA).
   • Passport and visa information — Foreign applicants are required to have a passport.
   • Training details — Basic information including the name of the school, type of aircraft, and pilot certificate or rating sought.
   • Fingerprints — Free fingerprinting forms are available by calling the American Association of Airport Executives at 703/797-2550. You may opt to receive the fingerprinting forms via express or overnight mail for a charge. Additionally, a prepaid return envelope may also be provided for a charge. Candidates' fingerprints must be collected by, or under the supervision of, a U.S. federal, state, or local law enforcement agency; by U.S. government personnel at a U.S. embassy or consulate that possesses appropriate fingerprint collection equipment and personnel certified to capture fingerprints; or by another entity approved by the Federal Bureau of Investigation (FBI) or TSA, including airports that possess appropriate fingerprint collection equipment and personnel certified to capture fingerprints. A list of domestic and international fingerprinting locations is available at www.tsc-csc.com/printoffices/. The prints can be taken either electronically or by the provided forms. After they are completed, the prints are sent back to AAAE, who then forwards a copy to TSA. Additional instructions can be found on TSA's Web site at https://www.flightschoolcandidates.gov/fp_instr.html.
   • $130 application processing fee — The fee must be paid by credit card on the TSA's Web site.
   • Photo — TSA recommends taking the photo after the candidate and flight school receive the final e-mail confirming the candidate's eligibility to take flight training, at which point it can either be uploaded to TSA's Web site or faxed to 703/542-1221.
2. A final determination of the candidate's eligibility status is not required prior to the start of flight training in aircraft below 12,500 pounds maximum gross takeoff weight. However, TSA will send an e-mail confirming receipt of the fingerprints and fee, which does need to be received by the candidate and flight school before training is started. The photo should be taken and sent to TSA after this final e-mail is received. If TSA determines the student is a security threat, the school or instructor will be notified, and training is to be stopped immediately.

Visa holders

Visa holders who begin training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating after December 20, 2004, must notify TSA of their intent to begin training. The notification process is as follows:

1. The applicant registers on TSA's Web site, www.flightschoolcandidates.gov, at which point they will be given a username and password via e-mail. After receiving the e-mail, the student logs in to the site and submits the following:
   • Full name, gender, current address and five-year address history, date and country of birth, and citizenship information.
   • TSA identification number (not provided to candidate — only seen by TSA).
   • Passport and visa information — Foreign applicants are required to have a passport.
   • Training details — Basic information including the name of the school, type of aircraft, and pilot certificate or rating sought.
   • Fingerprints — Free fingerprinting forms are available by calling the American Association of Airport Executives at 703/797-2550. You may opt to receive the fingerprinting forms via express or overnight mail for a charge. Additionally, a prepaid return envelope may also be provided for a charge. Candidates' fingerprints must be collected by, or under the supervision of, a U.S. federal, state, or local law enforcement agency; by U.S. government personnel at a U.S. embassy or consulate that possesses appropriate fingerprint collection equipment and personnel certified to capture fingerprints; or by another entity approved by the Federal Bureau of Investigation (FBI) or TSA, including airports that possess appropriate fingerprint collection equipment and personnel certified to capture fingerprints. A list of domestic and international fingerprinting locations is available at www.tsc-csc.com/printoffices/. The prints can be taken either electronically or by the provided forms. After they are completed, the prints are sent back to AAAE, who then forwards a copy to TSA. Additional instructions can be found on TSA's Web site at https://www.flightschoolcandidates.gov/fp_instr.html.
   • $130 application processing fee — The fee must be paid by credit card on the TSA's Web site.
   • Photo — TSA recommends taking the photo after the candidate and flight school receive the final e-mail confirming the candidate's eligibility to take flight training, at which point it can either be uploaded to TSA's Web site or faxed to 703/542-1221.
2. A final determination of the candidate's eligibility status is not required prior to the start of flight training in aircraft below 12,500 pounds maximum gross takeoff weight. However, TSA will send an e-mail confirming receipt of the fingerprints and fee, which does need to be received by the candidate and flight school before training is started. The photo should be taken and sent to TSA after this final e-mail is received. If TSA determines the student is a security threat, the school or instructor will be notified, and training is to be stopped immediately.

Visa information

The requirements for obtaining any visa are separate from the requirements of the TSA alien flight training rule.

According to INS regulations, Title 8 of the Code of Federal Regulations, Section 214.2(b)(7), any alien who is permitted to enter the United States on a B-1 or B-2 visitor's status visa is prohibited from enrolling in a course of study. Such an alien must an either obtain an F-1 or M-1 non-immigrant visa from a consular officer abroad and seek readmission to the United States, or apply for and obtain a change of status under section 248 of the Act and 8 CFR part 248. The alien may not enroll in the course of study until the Service has admitted the alien as an F-1 or M-1 nonimmigrant or has approved the alien's application.

Part 141 Flight Schools. Only FAA Certificated Part 141 and/or 142 schools that are approved and participating in the Student and Exchange Visa Information Service (SEVIS) program are authorized to issue an I-20 form to a prospective student upon their enrollment into a course, which the prospective student needs to request the change of status and receive the subsequent Student Visa.

Part 61 Flight Schools and Independent Flight Instructors. Part 61 flight schools and independent flight instructors may train a foreign national if that alien is a Legal Permanent Resident or in a work status (H-type visa) with extended stay privileges or a refugee in Asylum status with appropriate DHS documentation. They also may train a foreign national on an F-1 (academic visa) provided that the student is still enrolled and attending the college or university as shown on the F-1 and the student has notified SEVIS of the additional training being received at a non-SEVIS approved school.

Alien candidates who are coming to the United States to start flight training, and need information on obtaining a visa, should first contact the flight school where they intend on taking their flight training to get detailed procedures. In many cases, the flight school already has procedures in place to help a candidate obtain his or her visa. More information for obtaining a visa is available from the U.S. Department of State.

Flight schools and flight instructors

Training of U.S. citizens

1. Each flight training provider is required to determine U.S. citizenship before training is started for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating (does not include recurrent training). This only applies to people beginning training after October 20, 2004. Evidence may be shown by one of the following:
   1. Valid, unexpired U.S. passport.
   2. Original birth certificate of the United States, American Samoa, or Swains Island, and government-issued picture ID.
   3. Original certification of birth abroad with raised seal (Form FS-545 or DS-1350) and government-issued picture ID.
   4. Original certificate of U.S. citizenship with raised seal (Form N-560 or N-561), or a Certificate of Repatriation (Form N-581), and government-issued picture ID.
   5. Original U.S. naturalization certificate with raised seal (Form N-550 or N-570) and a government-issued picture ID.
   6. Flight training of federal employees including military personnel: Pursuant to a contract between a federal agency and a flight school, the agency must submit a written certification to TSA as to its employee's U.S. citizenship or nationality and government-issued credentials or other federally issued picture ID.
   7. Flight training of foreign military pilots endorsed by the Department of Defense to receive flight training in the U.S. (DoD endorsees): The individual must present a written statement acceptable to the TSA from the U.S. Department of Defense attachι in the individual's country of residence and a government-issued picture ID to the flight school.
2. The instructor must then comply with one of the following two options:
   1. Make an endorsement in both the instructor's logbook, or other record used by the instructor to record flight student endorsements, and the student's logbook with the following:
      "I certify that [insert student's name] has presented me a [insert type of document presented, such as a U.S. birth certificate or U.S. passport, and the relevant control or sequential number on the document, if any] establishing that [he or she] is a U.S. citizen or national in accordance with 49 CFR 1552.3(h). [Insert date and instructor's signature and CFI number.]"
   2. Keep a copy of the documents used to prove citizenship for five years.
3. Flight training can begin after the documents have been reviewed and either the logbook endorsement is made or copies are obtained by the instructor.

Training of aliens (both green-card and visa holders)

1. Any flight school or instructor wanting to provide training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating, (does not include recurrent training) to a foreign national must first register with the TSA at www.flightschoolcandidates.gov/fsindex.html.
2. When the applicant registers with TSA and chooses their flight school (or name of independent instructor), the flight school or instructor will be sent an e-mail confirming the student's request.
3. Immediately after the student reports for training, a digital (or digital version of a traditional) photo must be taken. The photo is uploaded when TSA instructs the flight training provider to do so.

Record-keeping requirements

The flight training provider must keep a record of the following for five years for each foreign applicant:

• The photograph of the candidate.
• A copy of the approval sent by the TSA confirming the candidate's eligibility for flight training. (This approval is the final determination sent to the candidate and flight training provider via e-mail after the candidate has applied for flight training with the TSA, paid the $130 fee, and submitted fingerprints.)
• Candidate's full name, gender, and date of birth.
• Candidate's ID number created by the TSA.
• Copy of candidate's valid, unexpired passport and visa (including all information listed in Step 4 of the AFSP Candidate Help Page at https://www.flightschoolcandidates.gov/student_help.htm#PERIDS.
• Copy of all previous passports and visas held by the candidate and all the information necessary to obtain a passport and visa.
• Candidate's country of birth, current country or countries of citizenship, and each previous country of citizenship, if any.
• Candidate's requested dates, type, and location of training (for more details, see Part 2 of the AFSP Candidate Help Page at https://www.flightschoolcandidates.gov/student_help.htm#APP).
• Candidate's current U.S. pilot certificate and certificate number (if any).
• Candidate's current address and phone number and each address for the previous five years.
• Copy of receipt confirming that the $130 was paid (printable from TSA Web site after candidate makes payment).
• For DoD endorsees, a copy of the required written statement and picture ID.

Steps in TSA registration process

1. Candidate Notifies Flight School. The flight training candidate should provide advanced notice to the flight school that he or she intends to start flight training.
2. Flight School Registers. After the candidate notifies the flight school of their intent to start flight training, the flight school needs to register online with TSA at https://www.flightschoolcandidates.gov/fsindex.html. After accessing the ASFP provider Web page, scroll down the page to select "new account." After registering, for flight schools in the United States, a user ID will be immediately provided and a password will be sent later via e-mail. For flight schools outside the United States, follow the instructions provided at the provider registration Web page.
3. Candidate Creates Login. The candidate is required to create a login account at https://www.flightschoolcandidates.gov. A user ID is provided immediately after submitting the required information, and a password is sent via e-mail. (Time may vary on receiving the password — possibly 24 to 48 hours).
4. Candidate Applies for Training. After receiving his or her password, the candidate will be instructed to change it. The candidate then logs into the TSA student registration page at https://www.flightschoolcandidates.gov and continues the application process. As a part of this process, the candidate will need to select his or her flight training provider — this requires the flight school's course ID number, course name and description, aircraft type, and the start and end dates for the flight training. If the flight school is already registered with TSA, it might be helpful if the candidate brings his or visa and registers at the flight school. This will allow the flight school to upload your required documents to TSA and also to make copies for the flight school's record-keeping requirements. Upon completion of the application, the candidate will be prompted to click on the "validate and submit" icon. If any errors appear in the application, the candidate will be instructed to make any necessary corrections or complete any missing information. After making any changes, the candidate clicks on "submit application." Furthermore, after submitting the application, and for the application to proceed further, the candidate must select "I agree" or "I disagree" after reviewing important information regarding his or her application.
5. Flight School Takes Photo. Upon arrival of the candidate to the flight school, the flight school takes a photo of the candidate and sends it to TSA.
6. Flight School Acknowledges Training Request. The flight school will be sent an e-mail from TSA requesting confirmation of the candidate's training request after the candidate's request has been submitted.
7. Candidate Instructed to Pay Fee. Once the flight school confirms the candidate's request, the candidate will be e-mailed instructions to pay the $130 processing fee (credit card only).
8. Flight School and Candidate Receive Preliminary TSA Decision. Upon receiving the payment, TSA e-mails both the candidate and the flight school a "preliminary decision" that confirms the application and fee have been received. If the preliminary decision is not received within seven business days, contact the TSA Help Desk at 703/542-1222.
9. Candidate Instructed to Submit Fingerprints. If the preliminary decision is favorable, the candidate will receive instructions for submitting fingerprints. If the decision is not favorable, the candidate will be provided details regarding any information that may be missing from their registration. For more details on how to get fingerprints taken, click here.
10. Flight School and Candidate Receive TSA Confirmation. TSA will send an e-mail confirming receipt of the fingerprints and fee, which does need to be received by the candidate and flight school before training is started.
11. Final Determination is Made by TSA. TSA will make a final determination as to the candidate's eligibility to receive flight training (training may have already started) and will notify the flight school and candidate of its decision.

TSA Clarifications About the Rule

FSDO Validation of Provider Registration/Identification

Flight instructors in the United States are not required to visit their local FSDO to validate their identification after submitting their registration to the TSA. Once the registration has been submitted to TSA, the flight instructor will be assigned a user name and later sent a password from TSA via e-mail. For flight training providers outside the United States, validation must be provided through an International FSDO Office (IFO). For complete details, visit the Alien Flight Student Program provider Web site.

Enforcement of Security Awareness Training compliance

According to the TSA rule, flight school employees (and flight instructors) not in compliance may be subject to civil penalties under federal regulations. TSA may also deal with violators by issuing verbal warnings and/or written notices. TSA considers each day a person operates in violation to the requirements of the rule an additional occurrence subject to penalty.

Security Awareness training — Inactive instructors

TSA has clarified the applicability of the Security Awareness Training. Current and active instructors must take the training by January 18, 2005. However, current and inactive instructors are not required to take the training, but it is recommended. Expired instructors are not required to complete the training.

Definition of Flight Training

The TSA has further interpreted the definition of "flight training" to only apply to training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any level), or instrument rating (does not include recurrent training).

This rule does NOT apply to flight reviews or proficiency checks:

TSA interprets the definition of "recurrent training" to NOT include any flight review, proficiency check, or other check whose purpose is to review rules, maneuvers, or procedures, or to demonstrate a pilot's existing skills.

This rule does NOT apply to flight training in airships, balloons, or gliders:

TSA has granted an exemption for those schools that provide, and individuals who apply for, instruction in the operation of airships, balloons, or gliders. This exemption also exempts schools that only provide instruction in airships, balloons, and gliders from the security awareness training requirement.

Flight students enrolled prior to October 20, 2004, are not subject to the requirements of this rule:

TSA has clarified that flight students who are enrolled in such flight training prior to October 20, 2004, are not subject to the regulation. However, once the student completes training for that particular certificate, he or she must comply with the applicable requirements if they begin training for an additional certificate or rating.

All Flight Instructors — Flight School Security Awareness Training

Overview

This rule mandates an initial and recurrent "security awareness training program" for each flight school employee, which includes instructors, independent flight instructors, ground instructors, and any other employee that has a direct contact with a flight school student regardless of whether they are training foreign students.

Active CFIs must receive the initial security awareness training by January 18, 2005. CFIs who have current certificates but are not involved in teaching are encouraged to take the free training, while CFIs whose certificates have expired are encouraged, but not required, to take the training. Employees hired after January 18, 2005, must receive the training within 60 days of being hired. Schools must maintain a record of this training for one year after the employee leaves the school. These records are subject to TSA and FAA audit.

Documentation of this training is available upon completion of TSA's online training. Many people have been unable to print the Flight School Security Awareness (FSSA) training completion certificate at the end of the training module. The technical problem with the module is complex and does not lend itself to a universal solution. Therefore, the following forms have been provided for individuals to be able to document their completion of the TSA required FSSA training. The documentation requirements are slightly different, depending on whether you are an independent CFI [Word document | PDF document] or a CFI/employee of a flight school [Word document | PDF document]. For those who are still unable to print a certificate using this method, an endorsement may be made in that person's logbook or other record to show compliance with the training. It is imperative that the same wording provided on these certificates is used when making this endorsement.

Flight schools, including freelance flight instructors, who fail to comply with the rule's requirements may be subject to enforcement action.

Initial security awareness training

A flight school may use either the initial security awareness training program offered by TSA or an alternative initial training program offered by a third party or designed by the flight school itself.

TSA's initial online security awareness training program is available through the TSA at http://download.tsa.dhs.gov/fssa/training/.

TSA notes that many flight schools currently conduct some form of security awareness training for their employees. If the training used by a flight school meets the criteria for an alternative initial security awareness training program in this rule, and the flight school has documentation that meets the record-keeping requirements in this rule for each employee who has received such training, TSA may consider the flight school to be in compliance with the initial security awareness training requirements of the rule. However, the flight school still must comply with the recurrent training requirements in the rule. A flight school is not required to submit its alternative initial security awareness training program to TSA for approval before the flight school uses the program to comply with the rule. Rather, TSA officials may audit a flight school's alternative training program when inspecting the flight school.

TSA notes that a flight school may have its employees receive computer-based security awareness training on an individual basis or may use an instructor to conduct the training to a group of employees. If a flight school elects to use an instructor to conduct the training for its employees, the flight school must first ensure that the instructor has successfully completed the initial flight school security awareness training program offered by TSA or an alternative initial training program that meets the criteria discussed above.

Recurrent security awareness training

This rule requires a flight school to ensure that each flight school employee receives recurrent security awareness training each year in the same month as the month in which the flight school employee received initial security awareness training. For example, if a flight school employee received initial security awareness training in April 2004, he or she must receive recurrent security awareness training in April 2005.

TSA will not provide a recurrent security awareness training program. Thus, a flight school will be required either to design its own recurrent security awareness training program or use a program designed by a third party. At a minimum, a recurrent training program must contain information regarding any new security measures or procedures implemented by the flight school, such as the installation of fencing, new uniforms or identification for employees, or the implementation of new entry procedures. A recurrent training program also must contain information regarding any security incidents at the flight school, and any lessons learned as a result of such incidents. For example, if any of the flight school's aircraft were broken into or stolen, the recurrent training program must discuss the incident and any measures the flight school has taken to address the incident or prevent such incidents in the future.

TSA will provide information concerning any unclassified security events or issues at flight schools or GA facilities over the previous year. Flight schools should use that information as part of their recurrent training program.

A recurrent training program also must contain any new threats posed by or incidents involving general aviation (GA) aircraft. TSA will post information regarding general threats posed by GA aircraft and major incidents involving GA aircraft on the TSA GA Web site at http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.tsa.gov/public/display?theme=180. A flight school must use that information in its recurrent training program. Finally, a recurrent training program must contain any new TSA guidelines or recommendations concerning the security of GA aircraft, airports, or flight schools. This information also will be available on the TSA GA Web site.

This rule requires a flight school to issue a document to each flight school employee when the employee receives initial security awareness training and each time the employee receives recurrent security awareness training. This requirement will enable TSA inspectors to verify that each flight school employee has received the required security awareness training each year.

The document issued to the employee must contain the employee's name and a distinct identification number for the employee to enable both the flight school and TSA inspectors to track each employee's security awareness training. (TSA does not provide distinct identification numbers. According to TSA, the flight school should develop their own numbering system for tracking employees. For TSA's online security awareness training, the printable training certificate should be supplemented with word "Initial" and the employee's distinct identification number provided by the flight school). The document also must indicate the date on which the flight school employee received the security awareness training; the name of the instructor who conducted the training, if an instructor conducted the training; a statement certifying that the flight school employee received the security awareness training; the type of training received, whether initial or recurrent; and if the flight school uses an alternative initial training program, a statement certifying that the program meets the criteria in 49 CFR 1552.23 (c).

Finally, the flight school employee and an authorized official of the flight school must sign the document.

Record keeping

This rule also requires a flight school to establish and maintain the following records for one year after an individual no longer is a flight school employee: (1) a copy of the document issued to the employee when he or she received initial training and each time he or she received recurrent training; (2) a copy of the alternative initial security awareness training program, if the flight school used in the past or currently uses an alternative program instead of the TSA program.

Inspection requirements

This rule requires a flight school to allow officials authorized by TSA and the FAA to inspect the records required under this section. TSA officials will be conducting inspections of flight schools to ensure that they are complying with this rule. Flight schools that are not in compliance may be subject to civil penalties under 49 U.S.C. 46301 and 49 CFR part 1503.

Alternative initial training program

If a flight school decides to use an alternative initial training program, the program must, at a minimum, meet the following criteria.

First, it must require active participation by the flight school employee receiving the training. Studies have shown that individuals retain information better when they receive the information in an interactive format than when they receive the information passively (for example, by merely listening to a lecture). Thus, the TSA initial training program is interactive, and TSA believes that any alternative initial training program must be as well.

Second, any alternative initial training program must provide situational scenarios that require the employee to assess specific situations and determine appropriate courses of action. For example, the program could give an employee a specific situation or set of circumstances involving behavior by a flight school student and ask the employee if the behavior is suspicious and, if so, what the employee should do in response, such as inform a supervisor, contact the TSA General Aviation Hotline (866/GA-SECURE), or notify local law enforcement.

Third, any alternative initial training program must enable an employee to identify the proper uniforms and other identification (if any are required at the flight school) for employees at that flight school or other persons authorized to be on the grounds of that flight school. The training also must enable an employee to identify suspicious behavior. Suspicious behavior may include: excessive or unusual interest in restricted airspace or restricted ground structures, such as repeated requests to fly over nuclear power plants; unusual questions or interest regarding aircraft capabilities; aeronautical knowledge inconsistent with the student's existing airman credentialing; sudden termination of the student's instruction; loitering on the flight school grounds for extended periods of time; and entering "authorized access only" areas without permission.

An alternative program also must enable an employee to identify suspicious circumstances regarding aircraft, including unusual modifications to aircraft, such as the strengthening of landing gear, changes to tail number, stripping the aircraft of seating or equipment; damage to propeller locks or other parts of an aircraft that is inconsistent with the pilot training or aircraft flight log; and dangerous or hazardous cargo loaded into an aircraft.

Fourth, an alternative program must provide an employee with appropriate responses for the employee to make in specific situations. Appropriate responses include: taking no action, if a situation does not warrant action; questioning an individual, if his or her behavior may be considered suspicious; informing a supervisor, if a situation or an individual's behavior warrants further investigation; calling the TSA General Aviation Hotline; or calling local law enforcement, if a situation or an individual's behavior could pose an immediate threat. Thus, an alternative program, in complying with these requirements and the interactive requirement discussed above, could give an employee a specific situation, ask the employee to respond, and then provide the appropriate response (or responses, if more than one response could be appropriate) and some discussion of why that response is appropriate.

Finally, an alternative training program must contain any other information relevant to security measures or procedures at the flight school, including applicable information in the TSA Information Publication Security Guidelines for General Aviation Airports. For example, if a flight school requires aircraft to have propeller locks after a certain time or has access codes for certain areas of the flight school grounds, that information must be included in the alternative training program.

"Flight school employee" is defined as a flight instructor or ground instructor certificated under 14 CFR part 61, 141, or 142; a chief instructor certificated under 14 CFR part 141; a director of training certificated under 14 CFR part 142; or any other person employed by a flight school, including an independent contractor, who has direct contact with a flight school student.

This definition includes an independent or solo flight instructor certificated under 14 CFR part 61. Thus, an independent or solo flight instructor, who would be considered a "flight school" under the definition of that term in Sec. 1552.1(b), must receive security awareness training in accordance with this subpart.

TSA believes that this rule should apply only to those employees who have direct or substantial contact with students, and thus are more likely to observe suspicious behavior, rather than those employees, such as grounds maintenance staff, who may spend little time at a flight school or have no contact with students. TSA also believes that requiring security awareness training for such employees would impose a substantial burden on flight schools while providing little added security. Thus, TSA has limited the definition to employees who have direct contact with a flight school student. This definition includes administrative personnel who accept payment from a flight school student or process a student's paperwork. TSA believes that such personnel are well situated to observe any suspicious behavior or circumstances in a student's payment or identification information.

Questions and Answers

General

Question: Are flight instructors in the United States required to visit their local FSDO in order to validate their TSA registration and personal identification?

Answer: No, flight instructors in the United States are not required to visit their FSDO for this. Once the flight instructor submits his/her registration to TSA, a user name will be provided immediately and a password will later be sent from TSA via e-mail.

Question: How do flight training providers outside the United States verify their registration with TSA?

Answer: For providers outside the United States, you will need to validate with an International FSDO Office (IFO). For complete details, please visit the flight training provider Web site.

Question: What is the definition of flight training as it pertains to this rule for the purposes of needing to undergo citizenship verification?

Answer: The TSA has further interpreted the definition of "flight training" for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any certificate level — i.e., does not apply to MEI), or instrument rating (does not include recurrent training).

Question: Do the requirements for citizenship verification apply for flight reviews, aircraft checkouts, or instrument proficiency checks?

Answer: NO, TSA has interpreted the definition of "recurrent training" to NOT include any flight review, proficiency check, or other check required by 14 CFR § 61.57 or § 61.58 whose purpose is to review rules, maneuvers, or procedures, or to demonstrate a pilot's existing skills. The TSA has further interpreted the definition of "flight training" for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational, sport pilot, private pilot certificate, multiengine rating (at any certificate level — i.e., does not apply to MEI), or instrument rating (does not include recurrent training).

Question: Do the requirements for citizenship verification apply to flight training in airships, balloons, or gliders?

Answer: NO, TSA has granted an exemption for those schools that provide, and individuals who apply for, instruction in the operation of airships, balloons, or gliders. This exemption also exempts schools that only provide instruction in airships, balloons, and gliders from the security awareness training requirement.

Question: Do the requirements for citizenship verification apply to anyone enrolled in training prior to October 20, 2004?

Answer: NO, anyone who began their flight training for their initial certificate, such as private or recreational, prior to October 20, 2004, is not subject to the citizenship verification requirements of this rule. TSA has clarified that persons who are enrolled in flight training prior to October 20, 2004, are not subject to the regulation. However, once the person completes training for their private or recreational, he/she must comply with the applicable requirements if they begin training for a multiengine or instrument rating.

U.S. Citizens

Question: It is my understanding that the logbook endorsement requirement for U.S. citizens should be done anytime an instructor/flight school is presented with a new student who received a logbook endorsement from a different school and/or location. But for students who remain at one flight school throughout their training, and are known by all the instructors, a recurring endorsement is not necessary. Is this correct?

Answer: Yes, this is a correct interpretation. Think of the endorsement as a replacement of the copy of the proof of citizenship. If you had a copy of my birth certificate from private training, and now I want to do an instrument rating, no need to run a new Xerox copy just because I'm doing a new rating.

Aliens

Question: I am pursuing a U.S. pilot certificate based on my foreign license. Am I required to comply with the TSA rule?

Answer: No, TSA has clarified that getting a U.S. certificate based on a foreign license does not apply to the requirements of the rule.

Question: Does the TSA rule also apply to U.S. flight instructors giving instruction in foreign countries for a U.S. certificate or rating?

Answer: Yes, the TSA rule does apply to this situation.

Question: What about an alien who goes through the required verification, including fingerprinting, to receive training? They complete their training and then later pursue additional training at a different flight school. Other than registering with TSA and the new flight school, must the candidate complete all of the requirements again (fingerprinting, etc.) or can they simply show proof that this was completed once when they register for the new training?

Answer: With respect to an alien who goes on to do another certificate or rating, either at the same school or a different one, the application to TSA must be made. The fingerprints do not have to be taken again, because TSA keeps them on file. However, the threat assessment and fee are still carried out.

Question: Can an alien candidate register without a passport?

Answer: You are generally required to have a passport, but there are some people with very special circumstances who cannot obtain a passport. TSA will handle these situations on a case-by-case basis.

Question: Is an alien required to have a visa? I have heard of aliens who have registered with TSA without a visa or green card. (Example: Some Europeans are allowed to stay in the United States for 90 days without a visa.)

Answer: "Visa" is not a required field, more of an "if applicable." TSA does realize there are some instances in which students are not required to and will not possess a visa.

Question: Does the TSA have any international locations for processing fingerprints?

Answer: In March 2005, TSA announced that certain international locations have been selected to process fingerprints for alien candidates. A list of participating airports is available at www.tsc-csc.com/printoffices/.

Security Awareness Training

Question: I am having a problem printing TSA's security awareness training certificate after I completed their online course; what should I do?

Answer: You may obtain a certificate from AOPA [independent CFI (Word document | PDF document); CFI/employee of a flight school (Word document | PDF document)] and keep this for proof of complying with the security awareness training requirement. You may also elect to endorse your logbook or other permanent records with the wording provided on the certificate that applies to you.

Question: Is a flight instructor who is not actively instructing required to take the initial security awareness training by January 18, 2005, and then continually undertake the recurrent training if they remain inactive?

Answer: TSA has clarified the applicability of the security awareness training. Current and active instructors must take the training by January 18, 2005. However, current and inactive instructors are not required to take the training, but it is recommended. Expired instructors are not required to complete the training.

Question: TSA's security awareness training document is required to have a distinct identification number and also indicate whether or not the training is initial or recurrent. Neither of these is provided on the TSA security awareness training certificate. What should I do?

Answer: After rechecking the rule and with our Chief Counsel's Office, here's what we have regarding the identification number:

Under 1552.25(a), a flight school must issue a document to each flight school employee each time the employee receives training (initial and recurrent). Paragraph (a)(1) requires the document to contain the employee's name and a distinct identification number.

The purpose is for TSA auditors to be able to better track/identify employees who have received the training. TSA does not provide the identification number. The flight school should make up a numbering system for employees or use any employee numbering system that the school already uses to identify employees.

The school is also free to note initial or recurrent training on the certificate for their record-keeping purposes.

Question: With regards to the security awareness training, can you please tell me if the TSA's online training at http://download.tsa.dhs.gov/fssa/training/ can be used again for recurrent training? After reviewing the introduction to the online training, there is no mention that the course is only for initial training. I know we previously discussed that the training certificate does not indicate "initial" or "recurring." According to the interim rule, TSA will not provide recurring training — but can this course be used for it?

Answer: It is not the intent of TSA for the initial training to be used repeatedly. The requirements for recurrent training differ greatly from initial (they are much less centered on the awareness portion, and more on actual security events or changes to procedures at the airport or facility), as laid out in 49 CFR 1552.23. There is nothing to prevent a training provider from using the initial program as part of recurrent, but completing that only would not fulfill the requirements for recurrent training under 1552.23 because of the difference in content requirements for initial and recurrent.