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FAA offers interpretation of solo endorsements

As we progress through flight training and achieve higher certificates and additional ratings, there is often a necessity for solo endorsements from a flight instructor to act as pilot in command of an aircraft while waiting to test for the certificate or rating.  A question that often arises in this context is how long the solo endorsement is valid. The regulations can be confusing, even misleading, in answering that question. A recent FAA interpretation provides some clarification. 

First-time student pilots are governed primarily by the regulations in 14 CFR Part 61, Subpart C, sections 61.81 through 61.95, which includes, among other things, restrictions how long solo flight and solo cross-country endorsements are valid.  For the most part, solo flight endorsements are not valid beyond 90 days and solo cross-country endorsements are generally valid only after an instructor has checked the student’s preparation for the particular flight and reviewed the current and forecast weather conditions for the time of the flight, necessarily meaning that duration of the endorsement is limited to the planned flight.  

In its recent interpretation, the FAA clarified that the solo flight time requirements and endorsements for pilots who hold a higher level pilot certificate and are seeking an additional category and/or class rating are contained in 14 CFR 61.63. That regulation does not limit the effectiveness of an instructor’s endorsement in time like is done for student pilots. The FAA explains that the express language of the subpart for student pilots “applies only to those persons who are seeking or hold a student pilot certificate.” The FAA goes on to clarify that “unlike solo endorsements for student pilots, § 61.31(d) does not contain any time limitation for the endorsement.” I recently spoke to a pilot in Alaska who had a multiengine solo endorsement from his flight instructor. The flight instructor was going to be out of the state for the winter months. The pilot was worried about having to find another instructor to give him a second solo endorsement to carry him through until his instructor got back. Not to worry. The good news is that the pilot does not have to worry about that solo endorsement running out.

Kathy Yodice

Kathy Yodice

Ms. Yodice is an instrument rated private pilot and experienced aviation attorney who is licensed to practice law in Maryland and the District of Columbia. She is active in several local and national aviation associations, and co-owns a Piper Cherokee and flies the family Piper J-3 Cub.

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