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
3-3 100 NM distance at night, as currently required by § 61.109(e)(2)(i), § 194.237(a) allows an applicant to complete two cross-country flights at night, each of which involves a flight of over 50 NM total distance.
3.4.2 Additionally, in place of the solo cross-country flight that is currently required by § 61.109(e)(5)(ii) (i.e., 150 NM total distance with one segment of the flight consisting of a straight-line distance of more than 50 NM), § 194.237(b) allows an applicant to complete the following alternate requirements:
1. One solo cross-country flight of 100 NM total distance, with landings at three points, and one segment of the flight being a straight-line distance of more than 25 NM between the takeoff and landing locations; and
2. An additional solo cross-country flight in a powered-lift 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 additional solo cross-country flight requires landings at a minimum of three points, with one segment consisting of a straight-line distance of at least 25 NM from the original point of departure. This additional cross-country flight must include different points of landing than the initial cross-country flight.
4-1 CHAPTER 4. ALTERNATE REQUIREMENTS FOR PRACTICAL TESTS AND
TRAINING IN A POWERED-LIFT
4.1 Required Equipment for Practical Tests in a Powered-Lift.
4.1.1 Title 14 CFR part 61, § 61.45(b) stipulates the equipment, other than controls, required of an aircraft used on the practical test and allows the use of an aircraft with operating characteristics that preclude the applicant from performing all the tasks for a practical test. In this case, an appropriate limitation is placed on the applicant’s certificate or rating. However, 14 CFR part 194, § 194.207(a) permits an applicant for a certificate or rating to use a powered-lift that is precluded from performing all of the tasks required for the practical tests. Applicants will not be required to have the certificate or rating issued with an appropriate limitation, as is currently required by § 61.45(b)(2). The purpose of the limitation under § 61.45(b)(2) is to ensure the pilot operates only the make and model (M/M) within the category and class of aircraft brought to the test, thereby preventing the pilot from acting as pilot in command (PIC) of an aircraft capable of performing tasks for which the pilot has not been tested. However, in the case of pilots seeking a certificate with associated powered-lift ratings, § 61.31(a)(3) requires all pilots to receive a PIC type rating for each aircraft type. Therefore, such a limitation is not necessary because § 61.31(a)(3) requires applicants to take a practical test in each powered-lift they seek to operate to act as PIC. In other words, because all powered-lift will require a type rating, a pilot is already limited to acting as PIC of only those powered-lift for which they hold a type rating (i.e., for which they have passed a practical test).
4.1.2 For example, if type A powered-lift could not perform a stall, then a pilot seeking a type rating in type A would not be tested on stalls and would not receive a limitation on the type rating for type A. If the pilot wished to act as PIC of type B powered-lift, which is capable of performing a stall, the absence of a limitation for the type rating for type A would not present a safety concern because the pilot would need to take a practical test for a type rating in type B powered-lift, pursuant to § 61.31(a), which would include the previously omitted evaluation on stalls. In other words, the type rating itself contains the limitation contemplated in § 61.45(b)(2) for an aircraft not able to perform all tasks in the Airman Certification Standards (ACS).
4.1.3 Section 61.43(a)(1) requires that the completion of a practical test for a certificate or rating includes the performance of the tasks specified in the areas of operation for the airman certificate or rating sought. For powered-lift, these tasks are set forth in the ACS for the appropriate certificate or rating that the applicant is seeking. Section 194.207(b) provides evaluators conducting practical tests for powered-lift the ability to waive any task for which the FAA has provided waiver authority. In order to determine what tasks may be waived, the type certification and evaluation process will be utilized to identify the operational limitations of the powered-lift, which may preclude the conduct of certain tasks listed in the ACS. The Flight Standardization Board Report (FSBR) subsequently will ascertain what tasks in the ACS are not applicable to the specific type of powered-lift. This waiver authority is not at the evaluator’s discretion; rather, the waived tasks are set forth on a designee’s Certificate Letter of Authority (CLOA) specific to each powered-lift type in which they are authorized to conduct practical tests. Specifically, the
4-2 CLOA will identify the type of powered-lift that the evaluator is authorized to conduct a practical test in, and the specific tasks that the evaluator is authorized to waive for the practical test will be set forth in the limitations section of the CLOA.
4.2 Required Flight Training Tasks. In addition to the required tasks specified in the areas of operation for the airman certificate and rating sought, § 61.39(a) requires an applicant for a certificate or rating to receive and log flight training on the applicable areas of operation. Section 194.207 authorizes an evaluator to waive a specific task during a practical test because the powered-lift used is precluded of performing a specific task.
Therefore, an applicant for a Private Pilot Certificate or Commercial Pilot Certificate with a powered-lift category rating concurrently with a powered-lift type rating is relieved from the requirement to receive flight training on any task specified in an area of operation that is waived on the practical test.
4.2.1 I n the case where the FAA identifies that a task is precluded from being accomplished because of factors during aircraft certification, the FAA will update its website at https://www.faa.gov in order to notify instructors, designees, and the general public on any specific task that is precluded from being trained or tested.
5-1 CHAPTER 5. ALTERNATE ELIGIBILITY REQUIREMENTS FOR A PERSON
SEEKING AN INITIAL POWERED-LIFT TYPE RATING
5.1 Practical Tests for Powered-Lift Category Rating and Type Rating. If an applicant applies to obtain an initial powered-lift type rating concurrently with a powered-lift category rating and instrument-powered-lift rating, that applicant is required to take three practical tests concurrently under 14 CFR part 61, § 61.63(d)(1). However, SFAR 120 provides temporary relief for the initial powered-lift practical tests.
Title 14 CFR part 194, § 194.211(b) provides eligible applicants with an option to obtain a powered-lift type rating without concurrently completing the required instrument rating;
in other words, the applicant may take the instrument-powered-lift rating practical test independent from the practical tests for the powered-lift category and type ratings.
5.2 E ligible Applicants. To be eligible to utilize the relief provided in § 194.211(b) and obtain an initial powered-lift type rating without concurrently holding or concurrently obtaining an instrument-powered-lift rating, a person must be seeking a type rating in a powered-lift capable of performing instrument maneuvers and procedures, pursuant to § 194.211(a). If the powered-lift in which the type rating is sought is incapable of performing instrument maneuvers and procedures, then the applicant must comply with § 61.63(e).
Note: Although certain powered-lift may not be instrument flight rules (IFR)-certified initially, they will likely be capable of performing instrument maneuvers and procedures because they will have the equipment necessary to perform instrument maneuvers. In this case, the applicant would be required to comply with either § 61.63(d) or § 194.211.
5.3 Practical Tests Required for Persons Seeking an Initial Powered-Lift Type Rating.
5.3.1 Under § 194.211(b)(1), applicants for an initial powered-lift type rating to be completed concurrently with a powered-lift category rating would not need to concurrently hold or obtain the instrument-powered-lift rating at the same time they obtain their powered-lift type and category ratings. Instead, the applicant applying for an initial powered-lift type rating pursuant to § 194.211(b) could choose to take the instrument-powered-lift rating practical test independent from the powered-lift type rating practical test and powered-lift category rating practical test. Opting to take the instrument-powered-lift rating practical test separately results in a “visual flight rules (VFR) only” limitation being placed on the type rating. Paragraph 5.6 describes how to remove the limitation. Commercial applicants will also receive the limitation specified in § 61.133(b)(1), “The carriage of passengers for hire in powered-lifts on cross-country flights in excess of 50 nautical miles or at night is prohibited.”
5.3.2 T he “VFR only” limitation in § 194.211(b) is a one- time-only option for initial powered-lift type rating applicants that do not wish to be subjected to the burden of taking three practical tests at one time. Except as provided in § 194.211(c), any additional powered-lift type ratings require the entire practical test in accordance with
5-2 FAA-S-ACS-17, Airline Transport Pilot and Type Rating for Powered-Lift C ategory Airman Certification Standards (ACS).
5.3.3 Additionally, because § 194.211(b)(2) does not require the type rating test to be taken in a ctual or simulated instrument conditions, the practical test for the type rating would not require the applicant to perform those areas of operation in the ACS that include instrument maneuvers and procedures in actual or simulated instrument conditions.
5.4 Pilot Privileges With a “VFR Only” Limitation. In accordance with § 61.3(e), a pilot with a “VFR only” limitation (i.e., the pilot did not concurrently complete the instrument-powered-lift rating practical test and, therefore, does not possess the instrument rating) on their powered-lift type rating is prohibited from operating the powered-lift under IFR even if the powered-lift can perform instrument procedures and maneuvers. The pilot is only permitted to operate the powered-lift under the conditions for which the pilot demonstrated mastery of the powered-lift on the practical test.
5.5 Removal of “VFR Only” Limitation—Private Pilot. Under § 194.211(b)(6), a pilot holding a Private Pilot Certificate with a powered-lift type rating and category rating with a powered-lift “VFR only” limitation is not required to remove the “VFR only” limitation if the limitation applies to a powered-lift type that is not a large aircraft or turbojet-powered. If a private pilot chooses to remove the “VFR only” limitation, they must comply with the “VFR only” limitation removal requirements set forth by § 194.211(b)(4), as discussed in paragraph 5.6.
5.6 Removal of “VFR Only” Limitation—Other Than Private Pilot. Except for private pilots that operate powered-lift types that are not large aircraft or turbojet-powered, a person who obtains a powered-lift type rating with a “VFR only” limitation must remove the “VFR only” limitation within 2 calendar months from the month in which the person completed the powered-lift type rating practical test, in accordance with § 194.211(b)(4).
Note: The purpose of the “VFR only” limitation is to permit limited flexibility in the scheduling of the instrument-powered-lift rating practical test at a time separate from the category and type rating practical tests. An applicant is eligible to take the instrument-powered-lift rating practical test at the same time as the powered-lift type rating and powered-lift category rating practical tests.
Therefore, the applicant will have obtained the required 3 hours of flight training in preparation for the instrument rating practical test within the 2 calendar months preceding the month of the practical tests, as required by § 61.65(f)(2)(i). The applicant should have sufficient time within the 2-calendar-month window for the endorsement to complete all of the practical tests and should not need to accomplish any additional training to be eligible to take the instrument-powered-lift practical test during this time period.
5.7 Practical Test Requirements to Remove the “VFR Only” Limitation.
5.7.1 In accordance with § 194.211(b)(4), a person with a powered-lift type rating with a “VFR only” limitation may remove the limitation by completing both of the following:
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1. Passing an instrument rating practical test in a powered-lift, where the test must be passed in actual or simulated instrument conditions; and
2. Passing a practical test in the powered-lift type for which the “VFR only” limitation applies on the areas of operation listed in § 61.157(e)(3) that includes performing instrument maneuvers and procedures in actual or simulated instrument conditions.
5.7.2 T he required tasks for the instrument-powered- lift rating are found in FAA-S-ACS-3, Instrument Rating—Powered-Lift Airman Certification Standards. The Airline Transport Pilot (ATP) and Type Rating for Powered-Lift Category ACS specifies which areas of operation and tasks an applicant must satisfactorily perform during the type rating practical test to remove the “VFR only” limitation for a powered-lift type.
5.7.3 Wh en an applicant takes concurrent practical tests to remove the “VFR only” limitation from their certificate, they will have to accomplish all required tasks, per § 194.211(b)(4).
However, when a task required for the instrument rating practical test overlaps with a task required for the type rating practical test, § 194.211(d) allows an applicant to perform the task a single time, provided the person performs the task to the highest standard required for the task.
Example: An applicant with a “VFR only” limitation on their powered-lift type rating applies to take the instrument-powered-lift practical test to remove the limitation. That person would be required to perform a circling approach procedure on both the instrument rating practical test and the type rating practical test. The Instrument Rating—Powered-Lift ACS requires the applicant to perform the procedures while maintaining an airspeed of ±10 knots and a desired heading/track of ±10 degrees. The ATP and Type Rating for Powered-Lift Category ACS also requires the applicant to perform the circling approach procedure, but to more exacting standards (e.g., maintain an airspeed of ±5 knots and a desired heading/track of ±5 degrees). If a pilot demonstrates their ability to perform the circling approach procedure to the more exacting standards specified in the ATP and Type Rating for Powered-Lift Category ACS, the pilot would not be required to perform the same task a second time to the less stringent standards specified in the Instrument Rating—Powered-Lift ACS.
5.7.4 In addition, once a commercial applicant successfully completes the instrument practical test, the limitation specified in § 61.133(b)(1) will also be removed because, consistent with that section, the pilot will have accomplished the requirements listed in § 61.65 for an instrument rating in the same category of aircraft listed on the person’s Commercial Pilot Certificate.
5.8 Effect of Failure to Remove “VFR Only” Limitation.
5.8.1 If the pilot does not remove the “VFR only” limitation as required by § 194.211(b)(3), then the powered-lift type rating for which the “VFR only” limitation applies will become invalid for use until the person removes the limitation in accordance with § 194.206(b)(4). Per § 194.211(b)(3), a pilot who does not complete the instrument practical test and remaining ACS tasks of the type rating practical test within
5-4 2 calendar months from issuance of the initial powered-lift type rating will no longer be qualified to fly a powered-lift. In order to restore their powered-lift privileges, the pilot must have 3 hours of training within the previous 2 calendar months and complete the requisite practical tests.
5.8.2 If a pilot does not complete the instrument practical test in the powered-lift within 2 calendar months and that pilot is qualified in another category aircraft, they may continue to exercise their other privileges while their powered-lift privileges are invalid.
For example, if a pilot holds an airplane category rating and is adding a powered-lift category rating and initial type rating but does not complete the practical test to remove the “VFR only” limitation within 2 calendar months, they can continue to exercise their airplane privileges.
5.9 Obtaining Additional Powered-Lift Type Ratings With “VFR Only” Limitation.
A person holding a Private Pilot Certificate may apply for an additional powered-lift type rating with a “VFR only” limitation. Pursuant to § 194.211(c), an applicant who holds a Private Pilot Certificate and is seeking an additional powered-lift type rating for a powered-lift that is not a large aircraft or turbojet-powered need not comply with the requirements of § 61.63(d)(1). Rather, the applicant may apply without holding or concurrently obtaining an instrument-powered-lift rating, but the type rating will be limited to “VFR only.” As with obtaining an initial powered-lift type rating with a “VFR only” limitation, the applicant does not have to take the type rating practical test in actual or simulated instrument conditions and may remove the limitation for that powered-lift in the same manner specified to remove a “VFR only” limitation on an initial powered-lift type rating, as set forth in § 194.211(b)(4) (and discussed in paragraph 5.7).
6-1 CHAPTER 6. ALTERNATE AERONAUTICAL EXPERIENCE AND LOGGING REQUIREMENTS—GENERAL PROVISIONS
6.1 Alternate Means to Obtain Ratings.
6.1.1 Pilots seeking to receive a Commercial Pilot Certificate with a powered-lift category rating in accordance with 14 CFR part 61, § 61.129(e) and an instrument- powered-lift rating in accordance with § 61.65(f) may encounter certain challenges in gaining the aeronautical experience necessary to receive these ratings. Therefore, the FAA has established alternate means for certain persons seeking to obtain ratings in a powered-lift.
A person may choose to comply with the alternate aeronautical experience and logging requirements or the standard part 61 requirements. However, if no alternate aeronautical experience or logging requirement is provided in 14 CFR part 194, then the person must meet the applicable part 61 requirements, pursuant to part 194, § 194.215(b).
6.1.2 P art 194 provides a pathway for new aircraft entering the civilian market and the initial pilots who fly these aircraft. The alternate pathway is broken down into three groups with specific alternate aeronautical experience requirements set forth to qualify the person to take the practical test. The three groups include:
1. Instructor pilots and test pilots at a manufacturer. Test pilots and instructor pilots employed by a specific manufacturer for aircraft undergoing certification are authorized to log aeronautical experience in these aircraft through a Letter of Authorization (LOA). Additionally, FAA test pilots or aviation safety inspectors (ASI) will also be able to log aeronautical experience in these aircraft when conducting duties for the purpose of establishing new type designs in the case of an FAA test pilot, or for the purpose of establishing a pilot type rating in the case of an ASI.
2. Initial cadre of instructors at a certificate holder (CH) (check pilots, chief instructors, assistant chief instructors, or Training Center Evaluators (TCE)). These individuals will need to satisfactorily complete the manufacturer’s training curriculum in a type-certificated aircraft at the manufacturer to qualify for the practical test to add a powered-lift category rating.
3. Pilots receiving training under an approved training program. CHs will need to apply for and receive approval of a training curriculum so that the initial cadre of instructors who train with the manufacturer can return to the CH and train pilots on the use of the powered-lift.
Note: The FAA uses the term “initial cadre” throughout this AC. In some instances, initial cadre refers to a sufficient number of instructors and evaluators to train and qualify pilots for powered-lift ratings under an approved training program under 14 CFR part 135, 141, or 142. In other instances, the term refers to a sufficient number of pilots who are rated in powered-lift.
6.1.3 I n accordance with § 194.215(a), the alternate aeronautical experience requirements (except for cross-country) for a Commercial Pilot Certificate and instrument-powered-lift