INSTRUCTOR PLT CONDUCTED SPIN PRACTICE WITHOUT HE OR HIS STUDENT WEARING REQUIRED PARACHUTES.

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I WAS INSTRUCTING A STUDENT ON STALLS AND PROCEEDED TO INTRODUCE SPIN TRAINING. RECENTLY THE VALIDITY OF TEACHING A STUDENT PLT (WITHOUT PARACHUTES) SPINS HAS COME TO LIGHT IN THE NE FSDO REGION. HAVING GRADUATED FROM XX COLLEGE; WHICH HAS AN AEROBATIC PROGRAM; I REALIZE THE IMPORTANCE OF MAKING STUDENTS AWARE OF SPINS. UNDER 91.307 IT INDICATES THAT THE USE OF PARACHUTES DOES NOT APPLY TO 'SPINS....REQUIRED BY THE REGS FOR ANY CERTIFICATE OR RATING BY A CFI.' IN THE NE FSDO REGION; APPARENTLY THIS IS INTERPRETED AS ONLY REGARDING THOSE BEING TRAINED FOR THEIR CFI'S. IF SPINS ARE TAUGHT TO ANYONE ELSE; A PARACHUTE MUST BE WORN. HAVING CALLED AOPA; THEY INDICATE THAT 'ANY CERTIFICATE OR RATING' ALSO INCLUDES STUDENTS; PVT PLTS; AND COMMERCIAL APPLICANTS. THIS REG SHOULD BE BETTER CLARIFIED BECAUSE I FIND THIS TYPE OF TRAINING VERY VALUABLE. MY STUDENTS ALSO FIND IT BENEFICIAL AS IT GIVES THEM MORE CONFIDENCE IN STALLS AND HOW TO RECOVER IF THEY INADVERTENTLY FIND THEMSELVES SPINNING. A PRECEDENT HAS BEEN MADE HERE IN THE NE WHERE A CFI RECEIVED A 'SUSPENSION PENDING VIOLATION' NOTIFICATION. THIS TYPE OF TRAINING IS VALUABLE AND; I BELIEVE; NECESSARY; AND SHOULD NOT BE RESISTED AS IT IS PERCEIVED HERE IN THE REGION OF THE PORTLAND; ME; FSDO.