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FAA GUIDANCE AND REGULATORY STATUS

What the FAA sources clarify

These FAA sources address the status of my solo authorization after 's communicated withdrawal, later endorsements, and logbook limitations. They do not decide motive or require an aircraft operator to permit dispatch.

01

CFI safety discretion

'S POSITIONGEM Aviation'S POSITION

I do not dispute a CFI's authority and responsibility to decline a particular solo flight based on safety or to reassess a student's proficiency. In his formal withdrawal, cited 14 CFR §61.87(c)(2) and attributed his decision to his recent evaluation of my proficiency and safety.

See EX-022
02

Existing endorsement status and documentation

FAA GUIDANCE

An FAA Aviation Safety Inspector advised that, once the withdrawal was communicated, I should not continue solo flight under the August 2 endorsement. He also explained that a subsequent logbook entry could document the suspension pending reevaluation and further authorization.

EX-015EX-022EX-023
03

GEM Aviation's aircraft-dispatch decision

GEM Aviation'S POSITION

I do not dispute GEM Aviation's authority to refuse dispatch of its aircraft. GEM Aviation stated that it would not schedule or dispatch a GEM Aviation aircraft to me for further solo flight.

See EX-015
FAA GUIDANCE

September 3 response from the Houston FSDO

Thomas R. Sherrill Jr., an FAA Aviation Safety Inspector with the Houston FSDO, responded to my request on September 3, 2026. He explained that when an instructor communicates that a student may no longer fly solo, the student should not continue solo flight under the prior endorsement. He noted that GEM Aviation's written communication made the restriction a written instruction.

For Part 61 training, he cited 14 CFR §61.89(a)(8). He also cited the FAA's 2015 McHenry Legal Interpretation, which states that instructor-imposed limitations remain effective until they expire or are superseded by a later endorsement of the same type.

He explained that the suspension could be documented through a later logbook entry stating that solo privileges are suspended pending reevaluation and further authorization by an authorized flight instructor. He also stated that I could work with the existing school or continue training with a different school.

I replied that my GEM Aviation training was conducted under Part 61, acknowledged that I should not exercise solo privileges under the August 2 endorsement, and stated that I would follow that guidance.

Read the September 3 updateRead the FAA email exhibitTimeline entry
FAA GUIDANCE

The cited authority substantially addresses the Part 61 question

The inspector did not respond directly to my follow-up question. However, the McHenry interpretation he cited states that a properly qualified flight instructor may issue or reissue a solo endorsement, and may revise existing limitations, after satisfying the applicable training, proficiency, and endorsement requirements.

A new instructor must independently conduct the required flight training in the make and model and observe the student to determine proficiency. McHenry also explains that the amount of training may vary with the student's skill and experience. It does not require every new instructor to repeat all prior training automatically.

This addresses the student's Part 61 authorization. It does not require a particular flight school to rent or dispatch its aircraft. Even if another qualified instructor issued a new endorsement, GEM Aviation would retain control over whether its aircraft was made available.

A direct response from this inspector to my September 3 follow-up remains pending. The cited legal interpretation nevertheless supplies substantive guidance on the broader Part 61 procedure.

Read the McHenry Legal Interpretation Read 14 CFR §61.87 Read 14 CFR §61.195

Official reference material

These links provide the underlying federal requirements and FAA interpretation. This site reports their guidance but does not offer an adjudication or enforcement conclusion.