U.
S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Pilot Training and Certification for Powered-Lift Operations Date: 11/21/24 AC No: 194-2 Initiated by: AFS-800 Change:
This advisory circular (AC) provides guidance to assist persons seeking to add an initial powered-lift category rating and specific type rating to their existing Federal Aviation Administration (FAA) pilot certificate in accordance with Special Federal Aviation Regulation (SFAR) 120, Powered-Lift: Pilot Certification and Training; Operations Requirements. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, and the document is intended only to provide information to the public regarding existing requirements under the law or agency policies.
R obert M. Ruiz for Lawrence Fields Executive Director, Flight Standards Service
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CONTENTS Paragraph Page
Chapter 1. Introduction1-1
1.1 Purpose of This Advisory Circular (AC)1-1
1.2 Audience1-1
1.3 Where You Can Find This AC1-1
1.4 Effective Date1-1
1.5 Related 14 CFR Parts1-1
1.6 Related Airman Certification Standards (ACS) (current editions)1-1
1.7 Definitions1-2
1.8 Background1-3
1.9 AC Feedback Form1-4
Chapter 2. Po wered-Lift Pilot Certification—General Provisions2-1
2.1 General2-1
2.2 Type Rating Requirements2-1
2.3 Applicability of the Type Rating Requirement to Military Pilots2-1
Chapter 3. Alte rnate Cross-Country Requirements3-1
3.1 Alternate Means to Log Cross-Country Time in Powered-Lift3-1
3.2 Commercial Applicants3-1
3.3 Instrument Applicants3-2
3.4 Private Pilot Applicants3-2
Chapter 4. Alte rnate Requirements for Practical Tests and Training in a Powered-Lift4-1
4.1 Required Equipment for Practical Tests in a Powered-Lift4-1
4.2 Required Flight Training Tasks4-2
Chapter 5. Alte rnate Eligibility Requirements for a Person Seeking an Initial
Powered-Lift Type Rating5-1
5.1 Practical Tests for Powered-Lift Category Rating and Type Rating5-1
5.2 Eligible Applicants5-1
5.3 Practical Tests Required for Persons Seeking an Initial Powered-Lift
Type Rating5-1
5.4 Pilot Privileges With a “VFR Only” Limitation5-2
5.5 Removal of “VFR Only” Limitation—Private Pilot5-2
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5.6 Removal of “VFR Only” Limitation—Other Than Private Pilot5-2
5.7 Practical Test Requirements to Remove the “VFR Only” Limitation5-2
5.8 Effect of Failure to Remove “VFR Only” Limitation5-3
5.9 Obtaining Additional Powered-Lift Type Ratings With “VFR Only” Limitation5-4
Chapter 6. Alte rnate Aeronautical Experience and Logging Requirements—
General Provisions6-1
6.1 Alternate Means to Obtain Ratings6-1
Chapter 7. Alte rnate Aeronautical and Logging Experience Requirements for a
Commercial Pilot Certificate With a Powered-Lift Category Rating7-1
7.1 Alternate Provisions for Test Pilots, FAA Test Pilots, Aviation Safety
Inspectors (ASI), and Instructor Pilots7-1
7.2 Alternate Provisions for Initial Cadre of Instructors7-7
7.3 Alternate Provisions for Pilots Trained in an Approved Training Program
at the CH7-14
Chapter 8. Alte rnate Aeronautical Experience and Logging Requirements for an
Instrument-Powered-Lift Rating8-1
8.1 Alternate Provisions for Test Pilots, FAA Test Pilots, Aviation Safety
Inspectors (ASI), and Instructor Pilots8-1
8.2 Alternate Provisions for Initial Cadre of Instructors8-5
8.3 Alternate Provisions for Pilots Trained in an Approved Training Program
at the CH8-10
Chapter 9. Alte rnate Requirements for Powered-Lift Without Fully Functioning Dual
Controls Used in Flight Training9-1
9.1 Alternate Requirements for Flight Training Using an Aircraft Without Fully
Functioning Dual Controls9-1
9.2 Required Training9-1
9.3 Practical Test9-4
9.4 Supervised Operating Experience (SOE) for a Powered-Lift With
Single Controls and a Single Pilot Station9-5
Chapter 10. Mi scellaneous Qualification Requirements10-1
10.1 Requirements for Pilots Serving as Second in Command (SIC)
in a Powered-Lift10-1
10.2 Training in a Powered-Lift that Requires Two Pilot Flight Crewmembers10-2
10.3 Second in Command Professional Development Program (SIC PDP)10-2
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10.4 Supervised Operating Experience (SOE) Requirements of § 61.6410-3
Chapter 11. Par t 91K Requirements to Serve as a Powered-Lift Pilot in a
Fractional Ownership Program11-1
11.1 Use of Powered-Lift in Part 91K11-1
11.2 Part 91K Crewmember Experience Requirements11-1
11.3 Pilot Operating Limitations and Pairing Requirement11-1
Chapter 12. Req uirements to Serve as a Powered-Lift Pilot Under Part 13512-1
12.1 Alternate Provisions for Persons Receiving Training Under a Part 135
Approved Training Program12-1
12.2 Certification Training Curricula12-3
12.3 Advanced Qualification Program (AQP)12-3
12.4 PIC Qualifications12-4
12.5 Applicability of Rules for Eligible On-Demand Operations12-4
Chapter 13. Req uirements for Part 141 Sschools13-1
13.1 Class Rating Requirements for Part 14113-1
13.2 Alternate Qualification Requirements for Chief Instructors, Assistant Chief
Instructors, and Check Instructors13-1
13.3 Alternate Qualification Requirements for Check Instructors for Checks and
Tests That Relate to Ground Training13-1
13.4 Alternate Means to Satisfy Flight Training Minimum Curriculum Content
Specified in Part 141 Appendices for a Powered-Lift Category Rating13-1
13.5 Alternate Cross-Country Requirements Applicable to Part 141
Approved Courses13-2
Chapter 14. Par t 91 Pilot Certification for Powered-Lift With Special
Airworthiness Certificates for Experimental Purposes14-1
14.1 Operating Limitations14-1
Appendix A. E xample EndorsementsA-1
Appendix B. L ist of Advisory Circulars Affected by 14 CFR Part 194B-1
v List of Tables Table 7-1. Alternate Provisions for a Commercial Pilot Certificate With a Powered-Lift
Category Rating: Test Pilots and Instructor Pilots7-4
Table 7-2. Alte rnate Provisions for a Commercial Pilot Certificate With a Powered-Lift Category Rating: Initial Cadre of Check Pilots, Chief Instructors, Assistant
Chief Instructors, and Training Center Evaluators (Initial Cadre Instructors)7-11
Table 7-3. Alte rnate Provisions for a Commercial Pilot Certificate With a Powered-Lift Category Rating: Persons Receiving Training Under a Part 135, 141, or 142
Approved Training Program7-16
Table 8-1. Alte rnate Provisions for an Instrument-Powered-Lift Rating: Test Pilots and
Instructor Pilots8-3
Table 8-2. Alte rnate Provisions for an Instrument-Powered-Lift Rating: Initial Cadre of Check Pilots, Chief Instructors, Assistant Chief Instructors, and Training
Center Evaluators (Initial Cadre Instructors)8-8
Table 8-3. Alte rnate Provisions for an Instrument-Powered-Lift Rating: Persons Receiving Training Under a Part 135, 141, or 142
Approved Training Program8-11
Table 12-1. Po wered-Lift Pilot-in-Command Qualifications12-4
1-1 CHAPTER 1. INTRODUCTION
1.1 Purpose of This Advisory Circular (AC). This AC provides guidance for applicants, pilots, evaluators, and instructors who seek to add an initial powered-lift category rating and specific type rating to their existing United States (U.S.) pilot certificate in accordance with Special Federal Aviation Regulation (SFAR) 120, Powered-Lift: Pilot Certification and Training; Operations Requirements. Pilots and certificate holders (CH) are encouraged to use this information as best practice methods for developing training programs scaled to specific powered-lift they operate. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, and the document is intended only to provide information to the public regarding existing requirements under the law or agency policies.
1.2 Audience. The primary audience for this AC is persons seeking to obtain an initial powered-lift category rating, a specific type rating, and/or an instrument-powered-lift rating to an existing pilot or flight instructor certificate (e.g., applicants, pilots, and flight instructors) and entities seeking to provide training to such persons (e.g., Title 14 of the Code of Federal Regulations (14 CFR) part 135 operators, part 141 pilot schools, and part 142 training centers). Designated Pilot Examiners (DPE), aviation safety inspectors (ASI), and other persons who conduct certification functions for pilots should familiarize themselves with this AC as well.
1.3 Where You Can Find This AC. You can find this AC on the Federal Aviation Administration’s (FAA) website at https://www.faa.gov/regulations_policies/advisory_cir culars and the Dynamic Regulatory System (DRS) at https://drs.faa.gov.
1.4 Effective Date. This AC is effective as of November 21, 2024.
1.5 Related 14 CFR Parts. The following are available at https://www.ecfr.gov:
• Part 61, Certification: Pilots, Flight Instructors, and Ground Instructors.
• Part 91 Subpart D, Special Flight Operations.
• Part 91 Subpart K (Part 91K), Fractional Ownership Operations.
• Part 135, Operating Requirements: Commuter and On Demand Operations and Rules Governing Persons On Board Such Aircraft.
• Part 141, Pilot Schools.
• Part 142, Training Centers.
1.6 Related Airman Certification Standards (ACS) (current editions). The following should be read in conjunction with this AC and are available at https://www.faa.gov/traini ng_testing/testing/acs:
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• FAA-S-ACS-2, Commercial Pilot for Powered-Lift Category Airman Certification Standards.
• FAA-S-ACS-3, Instrument Rating—Powered-Lift Airman Certification Standards.
• FAA-S-ACS-13, Private Pilot for Powered-Lift Category Airman Certification Standards.
• FAA-S-ACS-17, Airline Transport Pilot and Type Rating for Powered-Lift Category Airman Certification Standards.
• FAA-S-ACS-27, Flight Instructor for Powered-Lift Category Airman Certification Standards.
• FAA-S-ACS-28, Flight Instructor—Instrument Rating Powered-Lift Airman Certification Standards.
1.7 Definitions. The following definitions are only for the purposes of this AC and 14 CFR Part 194, Special Federal Aviation Regulation No. 120—Powered-Lift: Pilot Certification and Training; Operations Requirements.
1.7.1 Alternate Definition of Cross-Country Time (part 194, § 194.201). Notwithstanding the cross-country time definition in part 61, § 61.1(b), a person may log flight time in a powered-lift as cross-country time provided the time was acquired during a flight:
1. That includes a point of landing that was at least a straight-line distance of more than 25 nautical miles (NM) from the original point of departure; and
2. That involves the use of dead reckoning (DR), pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
1.7.2 Aviation Safety Inspector (ASI) (§ 194.103). A pilot employed by the FAA to conduct operations of a powered-lift for the purpose of establishing a type rating in that specific powered-lift under 14 CFR part 21, as appropriate.
1.7.3 Evaluator. For the purposes of this AC, an evaluator is considered:
• An ASI;
• A pilot examiner (other than administrative pilot examiners);
• An initial check pilot;
• A Training Center Evaluator (TCE);
• An Aircrew Program Designee (APD); or
• A chief instructor, an assistant chief instructor, or a check instructor of an approved part 141 pilot school or provisional school.
1.7.4 FAA Test Pilot (§ 194.103). A pilot employed by the FAA to conduct operations of a powered-lift for the purpose of FAA examination or inspection of a type design for which an application for type certification has been submitted under part 21.
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1.7.5 Instructor Pilot (§ 194.103). A pilot employed or used by a manufacturer of a powered-lift to conduct operations of the powered-lift for the purpose of developing a proposed training curriculum and providing crew training. This term is not the same as an authorized instructor.
1.7.6 M anufacturer (§ 194.103). Any person who holds, or is an applicant for, a type or production certificate for an aircraft. An amateur builder under part 21, § 21.191(g), a builder of a kit aircraft under § 21.191(h), or the holder of a restricted category type certificate (TC) is not considered a manufacturer for the purposes of part 21.
1.7.7 T est Pilot (§ 194.103). A pilot employed or used by a manufacturer of a powered-lift to conduct operations of the powered-lift for the purpose of research and development (R&D) and showing compliance with the regulations.
1.8 Background.
1.8.1 As a result of the rapidly changing technology and newly designed aircraft intending to fly in the National Airspace System (NAS), the FAA created regulations to account for the new category of aircraft. A portion of the regulatory changes include creating pilot training and certification requirements for a new aircraft category. Part 194 provides regulatory requirements for powered-lift pilot certification and operations. Prior to this regulation, the FAA did not have a feasible means to implement training and certification of pilots for a powered-lift category rating due to a lack of certificated aircraft and certified personnel to provide instruction. This new regulation establishes requirements for qualifying pilots in powered-lift by utilizing new and existing pathways for pilot training, checking, and testing in powered-lift under parts 61, 91, 135, 141, 142, and 194.
Additionally, SFAR 120 provides for alternate pathways for training and certification of pilots, as there is currently limited means to obtain experience in a powered-lift.
1.8.2 Currently, civilian pilots are unable to satisfy many of the aeronautical experience requirements in part 61 to obtain a Commercial Pilot Certificate with a powered-lift category rating and/or an instrument-powered-lift rating because there are no certificated powered-lift in civil operations in which they can obtain the necessary flight time. At the time of publication of this Final Rule, the only certificates with powered-lift category ratings were those issued to military pilots that attained their certificates through military competency under § 61.73. Additionally, there are currently no type-certificated civilian powered-lift; however, there are many manufacturers starting the production process.
1.8.3 When powered-lift are introduced to civil aviation, pilots will initially be unable to satisfy several of the aeronautical experience requirements for a Commercial Pilot Certificate with a powered-lift category rating and an instrument-powered-lift rating (such as pilot-in-command (PIC) flight time in powered-lift and cross-country experience in powered-lift) due to lack of qualified civilian pilots and instructors in powered-lift.
Further, the PIC logging requirements of § 61.51(e) currently present obstacles for a pilot who is not rated in a powered-lift to log PIC flight time in a powered-lift. Additionally, in light of the range limitations of current type-certification projects for powered-lift, and several planned projects, many powered-lift coming to market are not capable of
1-4 completing the prescribed cross-country aeronautical experience requirements for the Commercial Pilot Certificate and instrument rating. SFAR 120 facilitates pathways for pilots to obtain powered-lift ratings through alternate aeronautical experience and expanded logging provisions.
1.9 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.
2-1 CHAPTER 2. POWERED-LIFT PILOT CERTIFICATION—GENERAL PROVISIONS
2.1 General. Title 14 CFR part 194 maintains the regulatory framework of powered-lift as an independent aircraft category without any associated classes. The FAA expects that, initially, most pilots seeking to add a powered-lift category rating to their pilot certificate will already hold another category rating (i.e., airplane or rotorcraft) on their certificate.
In fact, as subsequently discussed, to utilize most of the alternate aeronautical experience requirements and logging provisions, pilots are required by part 194, § 194.215 to hold certain certificates and ratings. Permanent changes to 14 CFR part 61, as well as temporary alternate experience requirements in SFAR 120, work in tandem to provide methods for certification for all powered-lift pilots. The next several chapters outline the temporary and permanent changes that affect pilot training, checking, and testing in powered-lift.
2.2 Type Rating Requirements. To address the expected significant operational differences between each powered-lift, part 61, § 61.31(a) requires each person who acts as pilot in command (PIC) of a powered-lift to hold the associated type rating. Requiring pilots to hold type ratings for powered-lift establishes a higher level of safety by ensuring persons receive adequate training and are tested on the unique design and operating characteristics of each powered-lift. The Flight Standardization Board (FSB) will identify the unique characteristics of each powered-lift that require special training. Subsequently, the report should be utilized in conjunction with the appropriate powered-lift Airman Certification Standards (ACS) to conduct training and practical tests for a type rating, ensuring that an applicant is knowledgeable and capable of safely operating the unique powered-lift type.
2.3 Applicability of the Type Rating Requirement to Military Pilots.
2.3.1 Military pilots may continue to apply for Commercial Pilot Certificates with powered-lift category ratings and instrument-powered-lift ratings, and flight instructor certificates with powered-lift category ratings and instrument-powered-lift ratings, pursuant to the existing requirements in § 61.73, based on their military pilot qualifications.
2.3.2 However, to act as PIC of a civilian powered-lift, these military pilots are required to obtain a type rating on their pilot certificate for the applicable type of civilian powered-lift, as required by § 61.31(a). As required by § 61.195(e), those military instructors who have obtained or plan to obtain a flight instructor certificate with a powered-lift category rating and instrument-powered-lift rating through military competency may conduct flight training in a powered-lift only after obtaining a type rating on their pilot certificate for the powered-lift in which they want to conduct flight training.
3-1 CHAPTER 3. ALTERNATE CROSS-COUNTRY REQUIREMENTS
3.1 Alternate Means to Log Cross-Country Time in Powered-Lift.
3.1.1 Due to the expected disparity between powered-lift range capabilities, 14 CFR part 194 includes an alternate definition of cross-country time that reduces the general distance to log cross-country time in a powered-lift from more than 50 nautical miles (NM) to more than 25 NM. Specifically, to log flight time in a powered-lift as cross-country time, part 194, § 194.201 requires a point of landing that is at least a straight-line distance of more than 25 NM from the original point of departure and involves the use of dead reckoning (DR), pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
3.1.2 For applicants not qualified to act as pilot in command (PIC) in a powered-lift, § 194.213 requires all persons conducting cross-country flights to receive an endorsement from an authorized instructor or instructor pilot. Since applicants are not qualified to be PIC in a powered-lift, they will need an endorsement from the authorized instructor or instructor pilot stating that the applicant meets the alternate cross-country requirements. The applicant’s logbook must demonstrate to the evaluator that they have met the alternate cross-country requirements of part 194 in lieu of the standard 14 CFR part 61 regulatory requirements. Appendix A provides an example of each endorsement.
3.1.3 In addition to the cross-country definition, part 194 provides relief from specific cross-country requirements, dependent on the certificate sought, to address possible range capabilities, as previously discussed. Paragraphs 3.2 through 3.4 detail specific relief options for applicants.
3.1.4 To note, a pilot may satisfy either the traditional part 61 cross-country pathway or the alternate cross-country requirements set forth by part 194, as applicable, to meet the requisite cross-country aeronautical experience.
3.2 Commercial Applicants.
3.2.1 Under part 61, § 61.129(e)(3), applicants for a powered-lift rating are required to complete only two cross-country flights, one in daytime conditions and one in nighttime conditions, each including a total straight-line distance of more than 100 NM from the original point of departure. However, as many powered-lift are expected to be unable to comply with existing cross-country requirements, the alternate requirements in part 194 reduce the distance required for the cross-country flight to a total straight-line distance of more than 50 NM and add an additional cross-country flight with landings at a minimum of three points as a safety mitigation. Section 194.233(a)(3) requires that, other than the original point of departure, the third cross-country flight must be performed to different points than the first two cross-country flights at the distances specified. The third cross-country flight may be conducted during day or nighttime conditions. This additional cross-country flight will add to the applicant’s overall experience in the specific powered-lift in which the applicant is seeking their initial Commercial Pilot Certificate with powered-lift category rating.
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3.2.2 In lieu of complying with § 61.129(e)(3), § 194.233 allows an applicant seeking a Commercial Pilot Certificate in a powered-lift to complete the following cross-country flights:
1. One 2-hour cross-country flight in a powered-lift in daytime conditions that consists of a total straight-line distance of more than 50 NM from the original point of departure;
2. One 2-hour cross-country flight in a powered-lift in nighttime conditions that consists of a total straight-line distance of more than 50 NM from the original point of departure; and
3. An additional cross-country flight with landings at a minimum of three points, with one segment consisting of a straight-line distance of at least 50 NM from the original point of departure. This flight must include landings at different points than the points selected for the previous two cross-country flights.
3.3 Instrument Applicants. Section 61.65(f)(2)(ii) requires completion of one cross-country flight of 250 NM. In lieu of complying with this requirement, § 194.235 allows an applicant seeking an instrument rating in a powered-lift to complete two cross-country flights, each of which must involve a flight of 100 NM along airways or by directed routing from an air traffic control (ATC) facility. The other requirements in § 61.65(f)(2)(ii) still apply. Thus, each cross-country flight with the reduced 100 NM distance must be performed under instrument flight rules (IFR) when a flight plan has been filed with an ATC facility and must involve an instrument approach at each airport and three different kinds of approaches with the use of navigation systems. However, an applicant utilizing the alternate means under § 194.235 is not required to file a flight plan and perform the cross-country flight under IFR if the powered-lift is not certificated for instrument flight and the applicant holds either:
• An instrument-airplane rating,
• An instrument-helicopter rating, or
• An Airline Transport Pilot (ATP) Certificate with an airplane category rating or rotorcraft category and helicopter class ratings.
3.3.1 In lieu of complying with § 61.65(f)(2)(ii), § 194.235 allows an applicant seeking an instrument-powered-lift rating to complete the following cross-country flights two cross-country flights conducted with either an authorized instructor or an instructor pilot that involve a flight of 100 NM along airways or by directed routing from an ATC facility, include an instrument approach at each airport, and include three different kinds of approaches with the use of navigation systems.
3.4 Private Pilot Applicants.
3.4.1 Section 194.201 authorizes private pilot applicants to apply the alternate definition of cross-country time when seeking to comply with the cross-country flight training in § 61.109(e)(1). In addition, instead of completing one cross-country flight of over