Houston FSDO responds to the solo-endorsement question

What the inspector advised

• Once an instructor communicated that I could no longer fly solo, I should not continue solo flight under the August 2 endorsement.
• GEM Aviation's written communication provided a written instruction not to solo.
• For my Part 61 training, the inspector cited 14 CFR §61.89(a)(8).
• He cited the FAA's 2015 McHenry legal interpretation concerning instructor-imposed limitations and later endorsements of the same type.
• He explained that a later logbook entry could document suspension pending reevaluation and further authorization by an authorized flight instructor.
• He stated that I could work with the existing school or continue training with another school.

I replied that my 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 the guidance.

What the cited authority adds

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 provide the required make-and-model flight training and determine proficiency. McHenry explains that the amount of training may vary with the student's skill and experience, so it does not require all prior training to be repeated automatically.

A later endorsement addresses the student's Part 61 authorization. It does not compel GEM Aviation or any other school to rent or dispatch an aircraft. A direct response from this inspector to my September 3 follow-up remains pending.