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Update: Special rule sets limited conditions for extensions and deadlines during pandemicUpdate: Special rule sets limited conditions for extensions and deadlines during pandemic

Editor's note: This story was updated April 30 to clarify provisions of the special federal aviation regulation, some of which pertain to pilots regardless of their flight operations and others that limit flight operations to flights associated with fighting the coronavirus epidemic. AOPA is reviewing the SFAR and will provide further information.

The FAA issued a special federal aviation regulation (SFAR) that provides blanket extensions of medical certificates and airman knowledge tests that would have expired between March 1 and May 31 to all pilots regardless of the type of their flying. The SFAR also provides flight review and instrument currency extensions under very limited circumstances to get pilots back in the air to support the fight against the coronavirus pandemic. Flight instructor certificates that would have expired between March 31 and May 31 will have a blanket certificate extension until June 30, 2020.

Although the SFAR touches many areas of interest to pilots, for the many whose medicals, flight reviews, instrument currencies, and knowledge tests do not expire between March 1 and May 31, it will be business as usual for complying with the regulations.

The FAA emphasized that the SFAR’s main intent was to expand the “critical” aviation effort against the pandemic, which was declared a national emergency on January 31. That urgency was also the reason the FAA implemented the SFAR as a final rule without first allowing the customary period for public comment.

“The regulatory relief provided in this SFAR will enable the continuity of aviation operations that are critical during the COVID-19 outbreak, including operations that support essential services and flights that support response efforts,” says the final rule, adding that the rule extends relief intended to prevent individuals from suffering “unnecessary economic burdens due to circumstances related to the outbreak that are outside of their control.”

AOPA has begun a detailed review of the SFAR, which is titled Relief for Certain Persons and Operations during the Coronavirus Disease 2019 (COVID19) Outbreak, and will provide updates as more is understood about specific topics. While it appears several requests for extensions were granted, AOPA is concerned that some that were not included may reduce the ability of general aviation to help fight the COVID-19 pandemic, including extensions for aircraft maintenance requirements. AOPA is continuing to work with the FAA on those concerns.

The SFAR will be effective immediately upon expected publication in the Federal Register May 4. AOPA recommends that pilots who intend to fly under the extensions consult their insurance carrier or broker to verify that their coverage remains in effect.

“We appreciate the FAA’s work on this relief package,” said AOPA President Mark Baker. “There appear to be some useful provisions in the 94-page document, and we will address more of its details soon.”

Extensions applicable to all pilots (regardless of the type of flying) include:

  • Medical certificates. The FAA extended the validity periods of airman medical certificates that expire between March 31 and May 31 through June 30. However, the prohibition on operations during medical deficiency remains in effect.
  • Knowledge tests. Applicants whose knowledge tests expire between March and June will have their knowledge tests’ validity extended by three calendar months, making the applicants eligible for a practical test for a certificate or rating issued under Part 61 for those additional three calendar months.
  • Flight instructors. Flight instructor certificates, unlike pilot certificates, expire every 24 calendar months. The SFAR will extend the validity of flight instructor certificates that expired between March 31 and May 31 until June 30 in certain circumstances.

Provisions tied to specific types of flight operations include:

  • Flight reviews. The FAA is offering a three-calendar-month “grace period” for those whose flight review may expire between March 1 and June 30 if they meet the applicability requirements. A condition of eligibility for the extension is that the pilot must have been current in March 2020, logged at least 10 hours of pilot in command time within the 12 calendar months preceding the month the flight review was due, in an aircraft for which that pilot is rated. Also, eligible pilots must complete FAA Safety Team online courses totaling at least three Wings credits. The courses must have been completed in January 2020 or later to meet this requirement, according to the rule.
  • Recent flight experience, pilot in command. The FAA only provided relief for instrument recency. The SFAR extends to June 30 the requirement to be instrument current under FAR 61.57(c) for those who meet the applicability requirements. A pilot must have performed and logged, within the nine calendar months preceding the month of the flight, six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. An additional eligibility requirement is that the pilot must have logged, in the preceding six calendar months, three instrument approaches in actual weather conditions, or under simulated conditions using a view-limiting device. Pilots who are unable to meet the instrument experience requirements before June 30 may still reestablish recency in accordance with FAR 61.57(d), but the number of months available to attain the instrument experience before having to take an instrument proficiency check “will depend on when the person last established instrument recency” in accordance with the regulation.

If you choose to extend your flight review or instrument currency under the SFAR, you should review the applicability requirements and limitations that are based on the grade of pilot certificate you hold, the intended operation, and for private pilots, other requirements.

In other provisions, the SFAR gives U.S. military and civilian personnel who were assigned outside the United States in support of U.S. armed forces operations and returned to the United States from deployment in October 2019 through March an additional three months beyond the six months allowed to comply with flight instructor and airframe and powerplant mechanic inspection authorization requirements, or complete the appropriate practical test, within six calendar months after returning to the United States.

The SFAR grants to airframe and powerplant mechanics with inspection authorization who were not able to meet the first year (even-numbered year) renewal requirements by March an additional three months (April to June) to complete one of the listed activities to meet the first year renewal requirements.

Dan Namowitz

Dan Namowitz

Associate Editor Web
Associate Editor Web Dan Namowitz has been writing for AOPA in a variety of capacities since 1991. He has been a flight instructor since 1990 and is a 30-year AOPA member.
Topics: Advocacy, Airman Regulation, Aviation Industry

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