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Massive FAA Part 61/91 Regulation Changes For Pilots Were Published Today

Is your flight review about to expire? Do you meet PIC recency of experience requirements? The FAA just published this SFAR to mitigate the impact of COVID-19.

The FAA Is Temporarily Changing A LOT Of Part 91 and 61 Regulations Due To COVID-19

Due to the extraordinary challenges of COVID-19, the FAA published this Special Federal Aviation Regulation (SFAR) today, providing relief for training, recency, checking, testing, duration, and renewal requirements for pilots under Part 61 and Part 91. This 93-page document covers all of the changes in detail, and we've read through it to highlight some of the biggest changes that might affect you. For a full list of requirements and regulation relief, read each relevant section.

Primarily, the FAA says, "an airman would have been required to be in close proximity to another individual, often in a small, confined space such as the flight deck of an aircraft or inside a simulator. As such, the airman would have had to increase the risk of transmission of the virus." Today's SFAR is dedicated to enabling the continuity of aviation operations that are critical to the Nation. The FAA recognizes the critical support that general aviation provides during the COVID-19 public health emergency, and that's why these provisions were published.


Do You Qualify?

Relief under today's SFAR applies to any operation that requires the pilot to hold at least a commercial pilot certificate. It supports 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. Additionally, this relief applies to some operations conducted by pilots exercising private pilot privileges, if they meet the following criteria:

  • The pilot must have 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 operation is incidental to business or employment.
  • The operation is in support of family medical needs or to transport essential goods for personal use.
  • The operation is necessary to fly an aircraft to a location in order to meet a requirement of this chapter.
  • The flight is to transport essential goods and/or medical supplies to support public health needs.
  • For flights conducted by private pilots under this relief, no one may be carried on the aircraft unless that person is essential to the purpose of the flight, such as when transporting doctors for the purpose of providing medical care.

This SFAR also extends to pilots conducting charitable medical flights for a volunteer pilot organization and flight attendant crewmembers, check pilots, and flight instructors under part 91, subpart K, and part 125.

Second-In-Command Qualifications

Eligible SICs now receive two additional grace months for completing the requirements of FAR 61.55(b), for a total of three grace months after the base month. This includes training and pilot time requirements to maintain currency.

Flight Reviews (BFRs)

Flight Reviews are required to be completed within 24 calendar months under FAR 61.56(c). The new SFAR adds three additional calendar months to this requirement provided the extension applies to active pilots and certain risk mitigations are met.

The three calendar month extension applies only to pilots who were current to act as PIC of an aircraft in March 2020 and whose flight review was due in March 2020 through June 2020. To mitigate any safety risk, the pilot must have logged at least 10 hours of PIC time within the twelve calendar months preceding the month the flight review was due. This flight time must be obtained in an aircraft for which that pilot is rated.


PIC Recency Of Experience

FAR 61.57 states the recency requirements for carrying passengers during day and night operations and operations under instrument flight rules (IFR). Today's SFAR only provides relief for instrument recency.

The FAA is extending the six calendar month requirement of FAR 61.57(c) by an additional three calendar months. This will enable a pilot to continue exercising instrument privileges, provided the pilot has performed the required tasks within the nine calendar months preceding the month of the flight, instead of the preceding six calendar months. Eligible pilots may exercise the relief in this SFAR through June 30, 2020. After that date, a pilot must be current in accordance with FAR 61.57(c).

PIC Proficiency Checks

New regulations about to FAR 61.58 for operations that require more than one pilot flight crewmember, or in a turbojet-powered aircraft. Two additional grace months have been given for completing the PIC proficiency checks required by FAR 61.58(a)(1/2). Eligible pilots are those pilots who are required to complete a proficiency check and whose base month falls within the time period of March 2020 through June 2020.

Part 91 and 125 Flight Crew Requirements

For both Part 91 and 125 crewmembers, check pilots, and flight instructors whose base month is in March, April, May, or June 2020, two additional grace months for completing recurrent testing, checking, and training requirements have been given.

Jason Pineau

There's A Lot More Too...

Click here to read to full SFAR release to see what else you might be eligible for. Flight schools and some aircraft-specific training requirements have been changed too.

What else can the FAA do to improve regulatory guidance due to the COVID-19 situation? Tell us in the comments below.

Swayne Martin

Swayne is an editor at Boldmethod, certified flight instructor, and an Embraer 145 First Officer for a regional airline. He graduated as an aviation major from the University of North Dakota in 2018, holds a PIC Type Rating for Cessna Citation Jets (CE-525), and is a former pilot for Mokulele Airlines. He's the author of articles, quizzes and lists on Boldmethod every week. You can reach Swayne at, and follow his flying adventures on his YouTube Channel.

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