SOLO FLT VIOLATION. PLT CERTIFICATION.

Narrative

I AM A FLT INSTRUCTOR AND HAVE A STUDENT WITH WHOM I'VE BEEN WORKING OFF AND ON FOR SOME TIME. WE'VE BEEN WORKING TOGETHER FAIRLY STEADILY OVER THE LAST MONTH AS MY STUDENT IS APCHING HIS CHKRIDE SOON. TODAY; HE WAS IN THE MIDDLE OF HIS PREFLT WHILE I WAS INSIDE GETTING READY FOR OUR DUAL FLT. AN FAA REPRESENTATIVE LANDED AND RAMP CHKED HIM. THE REPRESENTATIVE ASKED TO SEE HIS MEDICAL; LICENSE; AND ACFT RECORDS. SHE THEN ASKED TO SEE HIS LOGBOOK; THOUGH HE WASN'T GOING SOLO. HE DID AND SHE POINTED OUT THAT HE WAS PAST HIS 90 DAY SOLO DATE. SHE THEN TOLD HIM HE WAS OK BECAUSE IT WAS AT THE END OF THE MONTH THAT THE 90 DAYS EXPIRED THAT HE WOULD HAVE A PROB. HE TOLD HER THAT HE WASN'T FLYING SOLO TODAY; BUT HE QUESTIONED HER INTERP OF THE 90 DAY SOLO ENDORSEMENT. SHE ASKED IF HE HAD FLOWN SOLO SINCE THE EXPIRED TIME AND THEN QUICKLY (BEFORE HE COULD ANSWER) SAID 'WAIT! IF YOU ANSWER 'YES' I'LL HAVE TO TAKE ACTION AGAINST YOU!' SO; HE DIDN'T ANSWER. SHE ASKED HIM TO COME INSIDE AND WHEN SHE SAW ME (KNOWING I WAS HIS INSTRUCTOR) INFORMED ME THAT I WAS IN VIOLATION AND ASKED ME TO PHOTOCOPY 2 SOLO ENTRIES WHICH OCCURRED ABOUT 2 WKS AFTER THE 90 DAY ENDORSEMENT EXPIRED. 1 FLT FOR .3 HRS; AND 1 FLT FOR 1.1 HRS. I DID THAT AND SHE THANKED ME AND STARTED TO LEAVE. SHE HAD TOLD MY STUDENT THAT THIS WAS JUST A WARNING AND THAT IT WOULDN'T AFFECT HIM IN ANY WAY; SO I ASSUMED ACTION WOULD BE TAKEN AGAINST ME. I ASKED IF I NEEDED A RECEIPT OF LETTER OF WARNING OR WHAT. SHE THEN SAID THAT NO ACTION WOULD BE TAKEN AGAINST ME; BUT THAT MY STUDENT MAY GET A LETTER OF REPRIMAND. SHE LEFT THEN RETURNED; AND ASKED ME TO PHOTOCOPY THE 90 DAY SOLO ENDORSEMENT. I DON'T KNOW IF THE FAA IS USING THIS AS A SCARE TACTIC (BECAUSE IT WORKED) OR IF THEY REALLY ARE GOING TO TAKE ACTION. I ADMIT THAT I MADE A MISTAKE BY NOT KEEPING BETTER TRACK OF HIS ENDORSEMENTS; BUT HE ONLY FLEW A TOTAL OF 1.4 HRS; 2 WKS PAST THE EXPIRATION DATE OF HIS ENDORSEMENT. I WRITE THIS IN HOPES OF AVERTING ANY ACTION AGAINST EITHER MYSELF OR MY STUDENT. I DON'T FEEL THAT IT WAS A BLATANT OR FLAGRANT VIOLATION THAT IT WAS A MISTAKE THAT WON'T HAPPEN AGAIN. I SEE NOW THAT I NEED TO STRESS THE STUDENT'S OWN LIMITATIONS. SUPPLEMENTAL INFO FROM ACN 295488: SHE NOTICED THAT THE ENDORSEMENTS WERE OVER THE 90 DAY CURRENCY REQUIREMENTS. SHE THEN ASKED ME IF I AHD SOLOED SINCE THEN. I STARTED TO ANSWER HER BUT SHE STOPPED ME AS I WAS ANSWERING HER AND TOLD ME IF I ANSWERED THAT I HAD SOLOED SINCE THEN; THAT SHE WOULD HAVE TO TAKE DISCIPLINARY ACTION AGAINST ME. I THEN SAID THAT; UPON WHAT SHE HAD TOLD ME; I WOULD HAVE TO ANSWER NO TO HER QUESTION.