The FAA Office of Chief Counsel addressed this issue in a recent Legal Interpretation. Specifically, the Interpretation responded to the following questions posed to the FAA:
- What documentation is required by FAR 61.105 prior to conducting a private pilot practical exam when the applicant has gained the requisite knowledge through a home-study curriculum;
- What language is required on the FAR 61.103(d) and 61.35(a)(1) endorsement to take a knowledge test and practical exam; and
- What documentation is required by FAR 61.107 to conduct a private pilot practical exam.
With respect to the first question, the Interpretation observed that specific documentation is not required prior to conducting a private pilot practical exam when the applicant has prepared using home-study curriculum. It then supported this observation by stating that FAR 61.105(a) “does not set forth any documentation requirements for an applicant who has completed a home-study course on the aeronautical knowledge areas that apply to the aircraft category and class rating sought.”
In response to the second question, the Interpretation states “there are no specific language requirements, only an endorsement requirement.” It goes on to explain that “to meet the requirements of both section 61.103(d) and section 61.35(a)(1), an applicant must provide a logbook endorsement from an authorized instructor who either conducted the training or reviewed the applicant’s home study curriculum that applies to the aircraft rating sought, and the instructor must certify that the applicant (1) completed the appropriate ground-training or home-study course, and (2) is prepared for the applicable knowledge test.”
Finally, regarding question three the Interpretation says “[t]he regulation requires that the applicant receive and log both ground and flight training from an authorized instructor on the areas listed in the regulations. There is no requirement in the regulations that an instructor must state verbatim each area of study required by section 61.107(b) in the applicant’s logbook.”
Thus, an applicant doesn’t need any specific or particular “document” to take the knowledge or practical exam. However, the applicant will need the appropriate logbook endorsement, which, from my perspective, could be characterized as a “document.” Although the Interpretation doesn’t say it, I believe what the FAA is trying to say is that a particular form or format for the “document” is not required.
Similarly, although the actual endorsement doesn’t have to use particular language, it will need to sufficiently recite the areas of study covered during the applicant’s instruction to convince the examiner that the applicant has completed the required training. Apparently the instructor can use whatever language he or she thinks will be sufficient for the examiner. Probably better for an instructor to err on the side of longer, more detailed endorsements to make sure the applicant is covered.