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Pandemic relief scaled back in latest SFAR amendment

Editor's note: This article was updated October 16 to include links to flowcharts to help pilots determine if the amended SFAR applies to them.

The FAA has revised the special federal aviation regulation that has governed training and testing requirements during the coronavirus pandemic, extending by two months the validity of medical certificates and knowledge tests that were to expire between October 2020 and January 2021 and adding two months to flight review deadlines that would have passed during that period.

The new SFAR amendment that took effect October 1 and was published in the Federal Register on October 6 reflects the agency’s conclusion that “aviation activity continues to increase, and the industry is beginning to address the backlog of required training, checking and testing requirements. However, many of the challenges that existed when the FAA first issued the SFAR in April remain today as the public health emergency continues,” the FAA said on its website.

The SFAR amendment eliminates the expanded instrument currency “lookback” period previously allowed for pilots who met certain operational requirements, and no new relief was provided for flight instructors with certificates nearing expiration.

“Although we sought continued relief for instrument currency and flight instructor certificates, we appreciate the FAA's continued extensions of validity for medical certificates and knowledge tests. The FAA’s recognition of the importance of general aviation during COVID-19 restrictions and the increased infection rates across the country has allowed aircraft owners and operators the flexibility to continue to fly safely,” said Christopher Cooper, AOPA senior director of regulatory affairs. To help pilots track their compliance responsibilities during the pandemic, the FAA provided a table comparing their status under the original SFAR, amendment SFAR 118-1, and the latest amendment SFAR 118-2. AOPA encourages pilots to review it carefully before conducting flight operations.

According to the table, SFAR 118-2 grants pilots with flight reviews coming due between October 2020 and January 2021 a two-month grace period to complete their flight reviews, subject to eligibility and operational criteria. (For example, a pilot whose flight review ordinarily would be due in October 2020 would have until December 31, 2020, to complete it.) Note that the two-month grace period differs from the three-month grace periods the original SFAR and SFAR 118-1 had afforded earlier in the year.

SFAR 118-2 requires instrument pilots to follow the customary instrument experience requirements of FAR 61.57(c) to determine whether they may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR. Previously, SFAR provisions allowed a nine-month “lookback” period, instead of six months, for determining their status.

The validity of medical certificates expiring between October 2020 and January 2021 is extended by two calendar months. Note that this provision is a shorter extension of validity than was available under previous SFAR provisions amending FAR 61.23. However, a three-month validity extension is provided for the medical certificates of pilots who reside in or serve as a pilot of an aircraft in Alaska.

The validity of knowledge tests that would ordinarily expire between October 2020 and January 2021 has been extended by two calendar months.

Mechanic applicants whose testing period is set to expire in the October 2020 through January 2021 period will have a two-calendar-month extension.

In extending portions of the SFAR, the FAA said that although aviation activity was on the upswing, “many of the challenges that existed when the FAA first issued SFAR 118 remain today,” and that “airmen continue to have trouble complying with certain training, recency, checking, testing, duration, and renewal requirements.”

It acknowledged that the “training ecosystem” remained under strain.

“In addition, the FAA workforce and its designees have not fully returned to normal activity. As a result, airman qualifications could lapse because persons cannot access training or testing facilities or schedule events in a timely fashion or because FAA inspectors or designees are unavailable to conduct required tests, checks, or observations,” it said.

Dan Namowitz

Dan Namowitz

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 35-year AOPA member.
Topics: COVID19, Advocacy, Pilot Regulation

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