AC 194-2

Advisory circular · Pilot Training and Certification for Powered-Lift Operations

Approved
November 21, 2024
Last reviewed
November 8, 2024
Family
AC 194-2 · 1 version
14 CFR parts
60, 61, 135, 141, 142

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 35–46

8-8 Table 8-2. Alternate Provisions for an Instrument-Powered-Lift Rating: Initial Cadre of Check Pilots, Chief Instructors, Assistant Chief Instructors, and Training Center Evaluators (Initial Cadre Instructors)

CURRENT

FLIGHT TIME REQUIREMENTS (§ 61.65(f))

ALTERNATE PROVISIONS FOR

INITIAL CADRE OF CHECK PILOTS,

CHIEF INSTRUCTORS,

ASSISTANT CHIEF INSTRUCTORS, AND TCEs* (initial cadre instructors, herein referred to as applicants) *To use the alternate provisions below, the flights must be conducted by an instructor pilot in a type-certificated powered-lift at the manufacturer, and the applicant must be authorized by the Administrator to serve as an initial check pilot, a chief instructor, an assistant chief instructor, or a TCE for the purpose of initiating training in a powered-lift under an approved training program under part 135, 141, or 142, as appropriate. Refer to § 194.229(a).

Cross-Country Time as PIC 50 hours of cross-country time as PIC, of which 10 hours must have been in a powered-lift.

An applicant who is not rated in the powered-lift may log PIC flight time in the powered-lift toward the 10-hour cross-country time requirement for flights that are conducted in accordance with a manufacturer’s training curriculum if the applicant is:

(1) The sole manipulator of the controls,

(2) Manipulating the controls of the powered-lift with an instructor pilot on board, and

(3) Performing the duties of PIC.

Refer to § 194.229(c).

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CURRENT

FLIGHT TIME REQUIREMENTS (§ 61.65(f))

ALTERNATE PROVISIONS FOR

INITIAL CADRE OF CHECK PILOTS,

CHIEF INSTRUCTORS,

ASSISTANT CHIEF INSTRUCTORS, AND TCEs* (initial cadre instructors, herein referred to as applicants) Instrument Time on the Areas of Operation Listed in § 61.65(c) 40 hours of actual or simulated instrument time in the areas of operation listed in § 61.65(c), of which 15 hours must have been received from an authorized instructor who holds an instrument-powered-lift rating, and the instrument time includes:

An applicant may receive 15 hours of instrument training on the areas of operation listed in § 61.65(c) from an instructor pilot (rather than an authorized instructor) if:

(1) The training is conducted in accordance with the manufacturer’s training curriculum, and

(2) The applicant receives an endorsement from an instructor pilot certifying satisfactory completion of the curriculum.

Refer to § 194.229(b)(1).

(1) 3 hours of instrument flight training from an authorized instructor in a powered-lift that is appropriate to the instrument-powered-lift rating within 2 calendar months before the date of the practical test.

An applicant may accomplish the practical test preparation from an instructor pilot (rather than an authorized instructor).

Refer to § 194.229(b)(2).

(2) Instrument flight training on cross-country flight procedures, including one cross-country flight in a powered-lift with an authorized instructor that is performed under IFR, when a flight plan has been filed with an ATC facility, that involves:

• A flight of 250 NM along airways or by directed routing from an ATC facility;

• An instrument approach at each airport;

and

• Three different kinds of approaches with the use of navigation systems.

An applicant may complete the cross-country flight with an instructor pilot (rather than an authorized instructor).

Instead of completing one cross-country flight of 250 NM, an applicant may complete two cross-country flights, each of which must involve a flight of 100 NM along airways or by directed routing from an ATC facility.

Refer to §§ 194.229(b)(4) and 194.235(a).

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8.3 Alternate Provisions for Pilots Trained in an Approved Training Program at the CH. Newly rated initial cadre instructors for an operator, a pilot school, or a training center (i.e., part 135 check pilots, part 141 chief instructors or assistant chief instructors, or part 142 TCEs who have been trained and certified at the manufacturer) will be proficient in the proposed training curriculum under their respective part because of their involvement in developing the proposed training program. This involvement will enable them to be in the best position to provide training to pilots enrolled in their respective CH’s training program under part 135, 141, or 142. The initial cadre of flight instructors will become fully qualified to serve in their designated function and receive a permanent LOA from the Administrator to subsequently conduct the training. Because these pilots will now be authorized instructors (i.e., meet the requirements for instructors under their respective part), the pilots who will receive training under an approved training program do not require the same breadth of relief that instructor pilots, test pilots, and the initial cadre instructors need. Rather, the only relief necessary for pilots at an approved training program is that of flight simulation training device (FSTD) credit, and the cross-country relief in § 194.235 extended to all applicants. Also, § 194.243 allows for initial training toward part 61 pilot certificates not normally accomplished at a part 135 CH, which would require the trainer to hold a flight instructor certificate. See Chapter 11, Part 91K Requirements to Serve as a Powered-Lift Pilot in a Fractional Ownership Program, and Chapter 12, Requirements to Serve as a Powered-Lift Pilot Under Part 135, for additional information.

8.3.1 U se of Full Flight Simulator (FFS) . As specified in § 194.231(c), an applicant may credit up to 4 hours obtained in a Level C or higher FFS toward the requirement to obtain 10 hours of cross-country time as PIC in a powered-lift if:

• The FFS represents the powered-lift category,

• The applicant was performing the duties of PIC, and

• The flight simulates a cross-country flight and includes the performance of instrument procedures under simulated instrument conditions.

8.3.2 Instrument Training on the Areas of Operation Listed in § 61.65(c). Pursuant to § 194.231(b), applicants who do not meet the cross-country aeronautical experience requirements specified in § 61.65(f)(2)(ii) may be considered eligible for an instrument rating if they complete the cross-country requirements listed in § 194.235, which may be completed with an authorized instructor. These requirements are detailed in Chapter 3.

8-11 Table 8-3. Alternate Provisions for an Instrument-Powered-Lift Rating: Persons Receiving Training Under a Part 135, 141, or 142 Approved Training Program

CURRENT

FLIGHT TIME REQUIREMENTS (§ 61.65(f))

ALTERNATE PROVISIONS FOR

PERSONS RECEIVING TRAINING UNDER A PART 135, 141, OR 142 APPROVED TRAINING PROGRAM* (herein referred to as applicants) *To use the alternate provisions below, the applicant must receive training at an approved training program under part 135, 141, or 142 for the purpose of obtaining a powered-lift category rating.

Cross-Country Time as PIC 50 hours of cross-country time as PIC, of which 10 hours must have been in a powered-lift.

An applicant may credit up to 4 hours obtained in a Level C or higher FFS toward the requirement to obtain 10 hours of cross-country time as PIC in a powered-lift if:

(1) The FFS represents the powered-lift category,

(2) The applicant was performing the duties of PIC,

(3) The flight simulates a cross-country flight and includes the performance of instrument procedures under simulated instrument conditions, and

(4) The flights are conducted in accordance with an approved training program under part 135, 141, or 142.

Refer to § 194.231(c).

Instrument Time on the Areas of Operation Listed in § 61.65(c) 40 hours of actual or simulated instrument time in the areas of operation listed in § 61.65(c), of which 15 hours must have been received from an authorized instructor who holds an instrument-powered-lift rating, and the instrument time includes:

No alternative.

(1) 3 hours of instrument flight training from an authorized instructor in a powered-lift that is appropriate to the instrument-powered-lift rating within 2 calendar months before the date of the practical test.

No alternative.

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CURRENT

FLIGHT TIME REQUIREMENTS (§ 61.65(f))

ALTERNATE PROVISIONS FOR

PERSONS RECEIVING TRAINING UNDER A PART 135, 141, OR 142 APPROVED TRAINING PROGRAM* (herein referred to as applicants)

(2) Instrument flight training on cross-country flight procedures, including one cross-country flight in a powered-lift with an authorized instructor that is performed under IFR, when a flight plan has been filed with an ATC facility, that involves:

• A flight of 250 NM along airways or by directed routing from an ATC facility;

• An instrument approach at each airport;

and

• Three different kinds of approaches with the use of navigation systems.

Instead of completing one cross-country flight of 250 NM, an applicant may complete two cross-country flights, each of which must involve a flight of 100 NM along airways or by directed routing from an ATC facility.

Refer to §§ 194.231(b) and 194.235(a).

9-1 CHAPTER 9. ALTERNATE REQUIREMENTS FOR POWERED-LIFT WITHOUT

FULLY FUNCTIONING DUAL CONTROLS USED IN FLIGHT TRAINING

9.1 Alternate Requirements for Flight Training Using an Aircraft Without Fully Functioning Dual Controls.

9.1.1 A person may apply for a powered-lift category rating, an instrument-powered-lift rating, and a powered-lift type rating concurrently for a powered-lift with single controls and a single pilot station under an approved 14 CFR part 135, 141, or 142 training program by meeting the requirements listed in 14 CFR part 194, § 194.253(b) and part 194 appendix A.

9.1.2 Applicability of this provision applies to an approved part 135, 141, or 142 training program for a powered-lift aircraft originally type certificated or seeking type certification with one set of controls and a single pilot station.

9.2 Required Training. An applicant must complete training in the order presented below.

9.2.1 Ground Training.

9.2.1.1 An applicant must receive and log the required ground training set forth by 14 CFR part 61, §§ 61.63(b) and 61.65(b) prior to receiving any flight training.

9.2.1.2 Upon completion of the ground training, an applicant must successfully complete a written or oral check administered by the training provider.

9.2.2 Full Flight Simulator (FFS) Training. In lieu of flight training in an aircraft, section 4 of part 194 appendix A permits the flight training requirements referenced in §§ 194.217 through 194.235 (except for the alternate cross-country experience requirements listed in § 194.233), as well as any other applicable flight training requirements under parts 61 and 194 to be accomplished in an FFS.

9.2.2.1 A training program would have to be submitted by the operator and approved by the FAA and must incorporate all the flight training necessary for an eligible applicant to receive a powered-lift category rating, an instrument-powered-lift rating, and type ratings under parts 61 and 194. At a minimum, the training program must include at least 20 hours of flight training in an FFS for the commercial pilot powered-lift category rating and 15 hours of flight training in an FFS for the instrument-powered-lift rating.

9.2.2.2 Upon completion of the ground training requirements above, an applicant may complete all applicable flight training requirements prescribed in part 61 or the corresponding framework prescribed in §§ 194.217 through 194.235 (except for the alternate cross-country requirements outlined in § 194.233), as applicable, in a qualified Level C or higher FFS representative of the powered-lift type with single controls and a single pilot station.

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9.2.2.3 Upon completion of the simulator training, an applicant must satisfactorily accomplish a check in a qualified Level C or higher FFS in accordance with the approved training program.

9.2.2.3.1 This check initiates a 90-day window in which the applicant must complete a familiarity flight and demonstration flight outlined in the following paragraphs (e.g., if a check in the FFS was completed on January 2, 2024, the applicant must complete a familiarity flight and demonstration flight as outlined below before April 1, 2024).

9.2.3 Aircraft Familiarity Flight.

9.2.3.1 The purpose of this segment is to expose the applicant to the operation of the aircraft in actual flight in the National Airspace System (NAS) while the person administering the familiarity flight demonstrates the maneuvers and procedures necessary for the ratings sought.

9.2.3.2 Within 90 days upon the satisfactory completion of the check above, an applicant must observe an aircraft familiarity flight in the powered-lift with an authorized instructor.

9.2.3.3 The aircraft familiarity flight must be accomplished in the aircraft with an instructor piloting the aircraft and the applicant having an unobstructed visual sight of the controls, an unobstructed visual sight of the instrumentation, and the ability to engage in active communication with the instructor during the entire flight.

9.2.3.4 The person authorized to conduct the flight must demonstrate all of the maneuvers and procedures required for the issuance of a Commercial Pilot Certificate with a powered-lift category rating, for the issuance of an instrument-powered-lift rating, and for the issuance of a powered-lift type rating.

9.2.3.5 Upon successful completion of the familiarity flight, the authorized instructor may endorse the applicant to act as pilot in command (PIC) of the specific powered-lift for the sole purpose of accomplishing the required demonstration flight with an authorized instructor on board. This demonstration flight is described below.

9.2.3.5.1 The expiration date of the endorsement specified above must not be longer than 90 days from the date of the successful completion of the check in the FFS.

9.2.4 Demonstration Flight.

9.2.4.1 The purpose of a demonstration flight is to enable an authorized instructor to ascertain that an applicant possesses satisfactory proficiency in the operation of the aircraft to then act as PIC safely in solo flight.

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9.2.4.2 The demonstration flight requires the applicant to pilot the aircraft and demonstrate all the maneuvers and procedures required for the issuance of a Commercial Pilot Certificate with a powered-lift category rating, for the issuance of an instrument-powered-lift rating, and for the issuance of a powered-lift type rating while an authorized instructor observes the applicant.

9.2.4.3 The authorized instructor must have an unobstructed visual sight of the controls and instrumentation and maintain active communication with the applicant for the entire flight.

9.2.4.4 Upon successful completion of the demonstration flight and the applicant having demonstrated satisfactory proficiency in the aircraft, the check pilot, Training Center Evaluator (TCE), authorized instructor, instructor pilot, aviation safety inspector (ASI), or another person authorized by the FAA to administer this check may endorse the applicant to act as PIC of the specified powered-lift to conduct solo flight(s), subject to any conditions and limitations the instructor believes to be warranted.

9.2.4.4.1 The endorsement is valid for no more than 90 days from the date of successful completion of the demonstration flight.

9.2.5 Failure to Complete Demonstration Flight During Specified Endorsement Period. If an applicant does not successfully complete the demonstration flight within 90 days from the day of the FFS check, they may receive another endorsement if they complete the following requirements:

1. The applicant must return to the FFS and successfully complete a demonstration of proficiency, which must consist of the maneuvers listed in section 10 of part 194 appendix A, unless otherwise waived in accordance with § 194.207(c); and

2. The applicant must complete another aircraft demonstration flight in accordance with paragraph 9.2.4 above.

9.2.6 Solo Flights.

9.2.6.1 As a result of the applicant completing all of the required flight training in an FFS and not in the actual flight environment, the FAA increased the amount of solo flight time to 20 hours. This accounts for the amount of PIC flight time required by § 194.216(a). For example, the applicant will receive credit for 15 hours of FFS toward the PIC requirements outlined in § 194.216(a). The applicant would have 20 hours of PIC flight experience remaining. Because the remaining PIC experience will be gained as solo experience, the applicant will have met the required 35 hours of PIC flight experience listed in § 194.216(a).

9.2.6.2 An applicant has 90 days to complete the following solo flight training requirements:

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1. Ten hours of solo flight time in accordance with § 61.129(e)(4), or the applicant may utilize the corresponding alternate provision for the cross-country time as set forth in §§ 194.217 through 194.231, as applicable;

2. Ten hours of solo flight time that must include maneuvers and procedures required for the issuance of a Commercial Pilot Certificate with a powered-lift category rating, for the issuance of an instrument-powered-lift rating, and for the issuance of a powered-lift type rating; and

3. If the aircraft is unable to comply with the standard cross-country requirements in part 61, then the applicant must also comply with the alternate cross-country aeronautical experience requirements prescribed in § 194.233.

9.2.7 Lapse of Endorsement for Solo Flight.

9.2.7.1 If an applicant is unable to complete the solo requirements within the 90-day endorsement window, then the applicant will need to meet specific requirements to receive another 90-day endorsement. There are two avenues an applicant can take to receive another endorsement. Below are the options to receive another solo endorsement.

9.2.7.1.1 Re-endorsement within 90-day endorsement window. If the applicant identifies that they will not complete the requirements within the timeframe, they will be required to complete another abbreviated demonstration flight with an authorized instructor. The requirements for the demonstration flight are found in section 10 of part 194 appendix A. Once the applicant successfully completes the demonstration flight, they may receive another 90-day endorsement.

9.2.7.1.2 Re-endorsement outside of the 90-day endorsement window. If an applicant does not complete the solo requirements and the 90-day endorsement has lapsed, the applicant will need to demonstrate proficiency in an FFS, which will result in an applicant being endorsed to accomplish another demonstration flight. The applicant must complete the demonstration flight in the powered-lift, and upon successfully completing the demonstration flight, the applicant may receive another 90-day endorsement to complete the solo requirements.

9.3 Practical Test. Upon completion of the requirements listed above and meeting the applicable regulatory requirements of part 61 or 194, as applicable, the applicant may apply for a Commercial Pilot Certificate with a powered-lift category rating, an instrument-powered-lift rating, and a type rating in the specific powered-lift for which training under part 194 appendix A has occurred.

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9.3.1 Training Prerequisite. In accordance with § 61.129(e)(3)(iv), an applicant must complete 3 hours of training on the areas of operation listed in § 61.127(b)(5) or the corresponding section in part 194 in an FFS in preparation for the practical test within the preceding 2 calendar months from the month of the practical test. Section 7(a) of part 194 appendix A allows this requirement to be met using a Level C or higher FFS.

9.3.1.1 Part 194 allows for a person to complete the full training program in such a timeline that would allow the crediting of the FFS training in section 4 of part 194 appendix A to meet the requirements of § 61.129(e)(3)(iv) and section 7(a) of part 194 appendix A. In other words, if the training program is completed within the preceding 2 calendar months, the flight training conducted during that period would be counted for purposes of both the 20 hours of flight training and the 3 hours of practical test preparation. The applicant would perform a lookback as is normally accomplished when receiving other ratings today.

9.3.2 Practical Tests Conducted in an Aircraft. Section 61.45(e) permits the use of an aircraft with a single set of controls for a practical test if the following provisions are met.

9.3.2.1 The evaluator must agree to conduct the test in the aircraft, and they must be located in a position to observe the proficiency of the applicant. The examiner is responsible for ensuring the practical test is in compliance with § 61.43, by encompassing all required tasks and maneuvers listed in the applicable Airman Certification Standards (ACS).

9.3.2.2 Section 61.45(e)(2) does not allow for demonstration of instrument skills during a practical test with aircraft that have one set of flight controls. As a result, the instrument tasks are required to be completed in an FFS. If the practical test cannot be completed in its entirety in the aircraft, and some tasks are required to be accomplished in the FFS, then the satisfactory outcome of the practical test will result with the issuance of the Temporary Airman Certificate with the following limitations. The exception to this limitation is if the applicant meets the requirements of § 61.64(e).

9.3.2.2.1 The pilot will receive a limitation stating the certificate is subject to certain PIC limitations and will be restricted from the carriage of persons or property other than necessary for the conduct of the flight. Additionally, the carriage of property for compensation or hire is not permitted, but the carriage of property under 14 CFR part 91 would be permitted, such as company materials. The limitations may be removed when the pilot meets the requirements listed below in paragraph 9.4.

9.4 Supervised Operating Experience (SOE) for a Powered-Lift With Single Controls and a Single Pilot Station. If a pilot receives a limitation as indicated above, they must meet the requirements set forth in section 8 of part 194 appendix A to have the limitation(s) removed. The following describes the requirements to get the limitation(s) removed.

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9.4.1 Applicants Adding an Initial Powered-Lift Rating With Single Flight Controls and a Single Pilot Station. The applicant must perform 10 hours of flight time in an aircraft of category and type for which the limitation applies under the observation of a pilot who holds a category and type rating without limitations for the aircraft, maintaining full communication with the observing pilot.

9.4.1.1 The flight time must also include a cross-country flight in a powered-lift under instrument flight rules (IFR) on a flight plan filed with an air traffic control (ATC) facility that involves a flight of at least 100 nautical miles (NM) along airways or by directed routing from an ATC facility, an instrument approach at each airport, and three different kinds of approaches with the use of navigation systems.

9.4.1.2 Since there is only a single set of controls and a single pilot station, the applicant must accomplish the cross-country flight detailed in paragraph 9.4.1.1 without the use of a view-limiting device.

9.4.1.3 The applicant must log each flight and the observing pilot attest in writing to each flight.

9.4.1.4 The applicant must present evidence of the SOE to any examiner or Flight Standards office to have the limitation removed.

9.4.2 Applicants Who Already Hold Powered-Lift Ratings and Are Only Adding an Additional Powered-Lift Type Rating in a Powered-Lift With Single Flight Controls and a Single Pilot Station. Applicants must comply with § 194.255 for an applicant adding an additional powered-lift type rating. Despite the requirements of § 61.64(f), a person who holds a powered-lift category rating, an instrument-powered-lift rating, and a powered-lift type rating and seeks an additional type rating for a powered-lift with single flight controls and a single pilot station in accordance with §§ 61.63(d) and 61.64(a), and does not meet requirements of § 61.64(e), will receive a limitation on the certificate restricting the person operating the powered-lift type from carrying any person or property on the aircraft, other than necessary for the purpose of removing the limitation from their certificate listed in § 194.255(b). The applicant must complete the following requirements.

9.4.2.1 The applicant must perform 25 hours of flight time in the type of powered-lift for which the limitation applies under the observation of a fully rated pilot without limitations for the aircraft, maintaining full communication with the observing pilot.

9.4.2.1.1 The observing pilot must have an unobstructed visual sight of the controls and instrumentation.

9.4.2.2 The applicant must log each flight and the observing pilot attest in writing to each flight.

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9.4.2.3 The applicant must present evidence of the SOE to any examiner or Flight Standards office to have the limitation removed.