Early last week the Federal Aviation Administration released guidance to pilots and air carriers in the form of a special FAR, providing relief as a result of the Coronavirus outbreak.
Among the changes, the FAA primarily addressed those regulations written under Part 61–an area which governs pilot certification and training. The changes come at a time when many airlines, charter companies, and commercial pilots have addressed concerns regarding compliance with regulatory training standards and currency requirements.
The unprecedented amendments to current rules have created a level of widespread confusion among those in the aviation community. Here are some of the most important highlights affecting pilots:
Who is Affected?
The FAA has emphasized that the main purpose of this sFAR is to provide relief specifically to “critical” operations effected by the coronavirus outbreak and those providing aid in this wake. The following pilot’s need be concerned:
Commercial Pilots & Airline Transport Pilots
“Any operation that requires the pilot to hold at least a commercial pilot certificate. This provision will support the continuity of essential commercial operations, which include aerial observation of critical infrastructure, aerial applications (e.g., crops), and private carriage of medical supplies and equipment, which are conducted under part 91, subpart K, and parts 125, 133, and 137.”
Private Pilots (Limited Relief)
“Pilots exercising private pilot privileges, provided the pilot has at least 500 hours of total time as a pilot of which 400 hours is as PIC and 50 of the PIC hours were accrued in the last 12 calendar months. The kinds of operations permitted are those that are:
- Incidental to business or employment,
- in support of family medical needs or to transport essential goods for personal use,
- necessary to fly an aircraft to a location in order to meet a requirement of this chapter, or
- a flight to transport essential goods and/or medical supplies to support public health needs.”
Flight Instructors
For flight instructors whose CFI certificate may be expiring between March 31 and May 31st, the instructor may continue to exercise certificate privileges so until June 30th of this year. This is to allow time for instructors to comply with renewal requirements being many FSDOs are closed due to the COVID-19 outbreak.
What Relief is Provided?
The extraordinary circumstances of the COVID-19 pandemic have detrimentally affected many aspects of aviation. As it is difficult to address every change here, pilot’s should reference the new rules to familiarize themselves with the changes. You can find a full version of the changes here.
Commercial operations are the primary beneficiaries of the new sFAR. For pilots who meet the prior stated criteria, a grace period has been allowed to complete currency and training requirements. Below are some of the most significant changes:
Airlines, Charter Companies, and Operators of large turbine aircraft
For Part 121, 135, and 125 operations; generally, a 4 month grace period has been applied to many required training activities. This means that, for pilots who qualify, they may continue to exercise their certificate’s privileges despite some currency criteria not being met. This comes in the form of the requirement for pilots to complete PIC Proficiency Checks or SIC Currency requirements.
Flight Review Requirement
For Private and Commercial/ATP pilots who meet the above criteria, a 3 month grace period has been allowed to complete the BFR so long as certain requirements are met. Not all pilots; however, may take advantage of this rule. It is only intended for commercial operators or for Private Pilots with at least 500 hours using it to exercise specific flight operations.
Instrument Experience Requirments
Similar to the Flight Review relief, a 3 month grace period has been allowed for applicable pilots who may lapse in their IFR currency. So long as specific requirements are met, they may continue to act as PIC under IFR.
Duration of Medical Certificates
First, Second, or Third class medical certificates that expires between March 31, 2020 and May 31, 2020 have been extended through June 30, 2020. Since many AME’s office’s are closed, this is to help ensure pilots may still excersize their priveleges until they can fulfill this requirement.
Written Knowledge Test Extension
Written tests typically expire after 24 calendar months. To help those who may be preparing for checkrides, the FAA has decided to extend this being that many examiners are not conducting practical tests due to social distancing measures. A 3 month grace period has been provided to written tests so long as they were completed between March 1, 2018 and June 30, 2018.
Others who may be Affected:
Changes have also been introduced for others who work in aviation:
Inspector Authorizations
Similar to those renewal rules provided for Flight Instructors, Inspector Authorizations (IA) have also received a 3 month extension to exercise inspection privilelges.
UAV Pilots
For pilots of small unmanned aircraft, an extension has been created to comply with Part 107 testing requirements. UAV pilots may continue to operate remote aircraft for up to six calendar months so long as certain requirements are met.
Dispatchers, Flight Attendants, and Flight Engineers
Written testing and currency requirements for these individuals has also been ammended under the new rule.
The provisions of this sFAR are quite limited. Many pilots should use care to ensure compliance before utilizing the provisions of the new regulation. For those who work in air carrier operations or are employed in an aviation capacity, be sure to consult with management if you are approaching the lapse of your currency. For pilots outside of this who wish to take advantage of the new rules, consult with a flight instructor or the FSDO to be sure you have a correct interpretation of the sFAR before exercising privileges.
The most important role pilots play in the cockpit is to ensure safety. As we all work together through these difficult times, making this a top priority is ever more important. Always remember that for pilots “legal currency” isn’t always “proficiency”. As always, practice good Aeronautical Decision Making.
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