Recently, a reader named Valerie Lynn Booth left a comment in the online edition of this column, where she shared some impressive enthusiasm – and one errant thought that deserves correction. (Thanks so much for reading and writing, Valerie.)
Valerie’s misinterpretation of a complicated rule is common. As she wrote it, ”FAA takes a dim view of learning to fly at a flying club at federally obligated airports.”
I can completely understand how people might get this impression. As with all things FAA, its documentation on any given topic can be hard to find and even harder to decipher. But I assure you, it is perfectly okay to learn to fly as a member of a flying club.
The FAA has no rule, regulation, order, or policy statement that would prevent you, or anyone else, from learning to fly at the flying club you choose to call home. In fact, as a flying club member you can earn your certificates and ratings all the way through ATP in an aircraft owned or leased by your flying club. You could even do that training in an experimental aircraft.
Flying clubs and their members have an enormous amount of flexibility available to them.
But as with all things aviation, there’s more to it than that. So in the interest of clarity and accuracy, let’s get into the weeds a bit for the benefit of all concerned.
Valerie’s use of the term “federally obligated airports” is important. A privately owned field that hasn’t taken federal money to make improvements is not a federally obligated airport. Even if it’s open to the public and hosts a flight school, a flying club, a maintenance shop, and a restaurant with a bar and a popular karaoke night. Whether it’s rolling in massive profits, or just barely getting by, it makes no difference. If the airport hasn’t accepted federal dollars, itt operates outside the guidance and mandates of the bible FAA Order 5190.6B, The Airport Compliance Manual.
Where the compliance manual does come into play is at those airports where federal dollars have been spent. As you might imagine that money comes with strings, and those strings are known as “grant assurances.” Essentially the deal is, you take our money, you operate as we require you to.
The Airport Compliance Manual is not a casual read. It’s big. Fortunately for those of us who are interested in flying clubs we can limit our focus to Chapter 10, Reasonable Commercial Minimum Standards. This section is only five pages long, three of which make up a sample document of club rules and regulations.
The basics include these two important points. The FAA defines a flying club as a nonprofit entity, which is organized for the express purpose of providing its members with aircraft for their personal use and enjoyment only. There’s a second point that also provides some important insight. “A flying club qualifies as an individual under the grant assurances.”
Digging deeper into other FAA documents we find that Valerie is right to a degree. A flying club cannot provide flight instruction. It just can’t. It can’t advertise that it provides flight instruction, and it can’t put a sign up outside the hangar that reads “Learn to fly here.” The club is a nonprofit entity that is barred from providing commercial services to the public at large, as flight schools can and do.
Now this is where it gets a little weird. Members can learn to fly using the club aircraft if they wish to. They can earn advanced ratings in the club aircraft. And they can seek instruction from any instructor they choose, whether that instructor is a club member or not.
This works because the flying club member is in effect acting as an owner. They’re individuals who have joined economic forces with others to reduce the cost of accessing an aircraft by forming a club. Like all aircraft owners and pilots (including student pilots) they have specific privileges and limitations. Learning to fly as a member of a flying club is absolutely, positively, without a doubt, allowed by the FAA, even at an airport that must comply with grant assurances.
The key is that the member initiates the process, securing the aircraft and hiring an instructor. Neither the club or the instructor have offered the aircraft for use. That’s important. The club cannot and should not ever compete with a flight school, or present itself as offering the same services as a flight school.
This matters to you and me and GA as a whole as much as it does to the FAA. What if we’re nearby an airport that doesn’t have a flight school? Does that mean nobody in town can learn to fly? No. Anyone can form a flying club that conforms with FAA rules, buy or lease an airplane, and start enjoying the benefits of being an individual pilot who seeks no profit from their flights in the club aircraft. And yes, the members of that club can use the flying club aircraft to learn to fly without running afoul of the feds.
Having said all that, if your flying club is based at an airport where there is a flight school, or multiple flight schools, it would behoove the club to foster a mutually beneficial relationship between the various entities. The flight school can perform intro flights, primary training, flight reviews, advanced training, and many other services the club may decide fall outside their basic goals.
There’s nothing wrong with the club directing prospective members to the school for training, just as there is nothing wrong with the school offering to connect students to the club when they finish earning their ticket.