One common question we get from both new and established flying clubs is: Are we allowed to provide instruction to students? We have written numerous articles on the topic, and the answer typically leans towards “yes”, but with important considerations.
There are a few different aspects to consider. First, there is no regulation from the FAA regulation on how a flying club must operate. What we do have is FAA order 5190.6B. This is the Airport Compliance Manual. You are probably thinking, I didn’t see this document during my pilot training, and it is not in my FARAIM book. Well, that’s because this document is provided for Airport sponsors (managers) when they accept federal funding from the U.S. Government. To find relevant information for flying clubs when opening the manual, go to section 10.6. This is the information that the FAA provides regarding flying clubs. Airport sponsors must follow these regulations if they have received federal funding.
Sometimes, flying clubs can create tension with other businesses on the field, as well as airport managers. Afterall, a flying club can seem like competition if it is attracting potential customers from a flight school. This could be a problem. One of the reasons AOPA always recommends creating a solid relationship with your airport manager is to educate and inform them of the benefits your partnership offers. A flying club helps the airport make money through fuel, maintenance, hangars, tie downs, food, and creates business on the field. Keep in mind, flying clubs exist to provide a more accessible way for people to fly. From both sides, we can see why a for-profit club on the field could be upsetting to a flight school, which must follow commercial standards set by the FAA.
Below is what the FAA says regarding a club and flight instruction.
A flying club may permit its aircraft to be used for flight instruction (1) in a club-owned aircraft as long as both the instructor providing instruction and person receiving instruction are members of the club owning the aircraft, or (2) when the instruction is given by a lessee based on the airport who provides flight training and the person receiving the training is a member of the flying club. In either circumstance, a flight instructor may receive monetary compensation for instruction or may be compensated by credit against payment of dues or flight time; however, that individual may not receive both compensation and waived or discounted dues or flight time concurrently. The airport sponsor may set limits on the amount of instruction that may be performed for compensation.
You can see that a flying club member can receive flight training in a club aircraft. However, an airport sponsor could limit the amount of instruction that may be performed for compensation. The FAA does not define this regarding the sponsor. This could be way that the FAA can protect the airport sponsor.
Now look here…
A flying club qualifies as an individual under the grant assurances and, as such, has the right to fuel and maintain the aircraft with its members. The airport owner has the right to require the flying club to furnish documents, such as insurance policies and a current list of members, as may be reasonably necessary to assure that the flying club is a nonprofit organization rather than an FBO or other commercial entity.
All flying clubs desiring to base their aircraft and operate at an airport must comply with the applicable provisions of airport specific standards or requirements. However, flying clubs will not be subject to commercial FBO requirements provided the flying club fulfills the conditions contained in the stated airport standards or requirements satisfactorily.
The first sentence in this paragraph is important: “A flying club qualifies as an individual under grand assurances and, as such, has the right to fuel and maintain the aircraft with its members.” What this means is that a flying club must be treated as an individual at an airport. A flying club does not have to follow commercial standards like a flight school must adhere to.
From an FAA standpoint, the answer is yes, you could provide flight instruction. This can be a private flight instructor or a flight instructor in the club. The flying club can pay the flight instructor in flight time or monetary payment, but not both. Additionally, a flying club that mandates its students use a particular flight instructor, must conduct a 100-hour inspection. It might be best to allow people to choose any flight instructor they want. Even though AOPA still always recommends a 100-hour inspection, it’s important to understand that fostering a solid relationship with an airport sponsor is extremely important for a flying club. To go down the path of dealing with the FAA and an airport could take an extremely long time and you could lose interested members of your club. Not offering primary instruction to student pilots could keep other airport tenants, such as the flight school, happy. You might consider allowing people to train exclusively for an instrument rating or commercial flight training-something to think about. Now, let’s say a flying club is based on a private airport, but is still open for public use and does not accept federal funding. All bets are off and the airport can reject a club if they want.
The final consideration is how this decision could impact insurance premiums. Allowing flight training often leads to a premium increase of 20% or more, due to the added risk of less experienced pilots in the club aircraft. The students have a much higher risk profile. The number of students in a club can also play a role. However, not allowing student pilots in the club could limit your pool of potential members, as fewer people would be interested in joining. Students tend to fly more frequently, which keeps club aircraft in use and helps the club financially.
So yes, a club can offer instruction, but the key takeaway is that you need to establish and foster a positive relationship with your airport manager. It is worthwhile to maintain a good relationship with the flight school. Some flight schools may be able to provide instructors for your club, which will benefit both the flight school and your flying club. As a flying club, we want to set an example for the community, ensuring that flying remains accessible for everyone while operating fairly.
