Unexpected problem
‘In the meantime, I’ll just fly under sport pilot privileges’
By Tom Zecha
With MOSAIC, the expansion of many legacy aircraft qualifying to be flown under sport pilot privileges since October 22, 2025, has created an unexpected problem for some pilots.
The problem arises when a pilot re-applies for an FAA medical and their aviation medical examiner determines they can’t issue the medical in the office and must defer the application to FAA Aerospace Medical Certification Division (AMCD) in Oklahoma City.
At this point the pilot may think because their aircraft has four seats, and a maximum clean stall speed (VS1) of 59 KCAS or less, that they can just fly under the sport pilot privileges with their driver’s license until their medical application is adjudicated. Unfortunately, this assumption can lead that pilot into trouble as they would be in violation of FAR 61.23(c)(2)(ii), which states:
A person using a U.S. driver’s license to meet the requirements of paragraph (c) while exercising sport pilot privileges must—
(ii) Have been found eligible for the issuance of at least a third-class airman medical certificate at the time of his or her most recent application.
That pilot’s most recent application, which has been deferred to FAA AMCD, has not yet been found eligible for the issuance of a medical certificate. Therefore, the pilot cannot exercise sport pilot privileges.
How long will it take for a determination? Currently, an initial response from the FAA is running anywhere from 30 to 60 days, and that doesn’t necessarily result in a determination. If the FAA requests additional documentation or further review is needed, it could take three to six months or even longer. Being prepared with all necessary documentation at the scheduled FAA medical exam can shorten review and processing times dramatically.
Tom Zecha is director of the AOPA Pilot Information Center and aviation safety program manager.
