Baker urges FAA to lift 'impossible' compliance barriers
With life on hold during the coronavirus pandemic, the clock continues to tick toward the dates when pilots’ practical test and knowledge test eligibility ends, currency or instrument proficiency runs out, and flight instructor certificates expire.
In a March 17 letter to FAA Administrator Steve Dickson, AOPA President Mark Baker described the impact on general aviation pilots and urged a flexible approach that allows extensions and relief from regulatory time restrictions for the duration of the crisis.
Many pilots confront seemingly intractable dilemmas in the face of closures, curtailment of travel, and the recommendations of health officials to practice social distancing. “For example, federal requirements require pilots to renew their medical certificate in person, to complete their pilot certification examinations within a certain amount of time, and to complete knowledge tests at off-site testing facilities,” he wrote. “The current restrictions to the U.S. population create an impossible barrier for these individuals to meet the necessary airman and aircraft requirements.”
AOPA is receiving numerous member inquiries about how to deal with currency requirements during the pandemic. Our government affairs team is working with the FAA to create solutions, said Christopher Cooper, AOPA director of regulatory affairs.
- One challenging situation confronts instructors whose certificates expire every 24 months and must be renewed by one of several methods within the 90 days before the expiration date (doing so afterward requires starting over with a practical test). Many CFIs renew via online flight instructor refresher courses—but others attend in-person FIRCs, many of which have now been canceled because of the coronavirus. “Without an extension or relief, some individuals’ instructor certificates will expire in the next month or two,” Cooper said.
- Some existing problems will be exacerbated during the coronavirus crisis: Dealing with limited availability of designated pilot examiners to conduct practical tests has been a work in progress for two years and now faces new obstacles. The FAA is considering waiving some DPE management policies, but some DPEs have canceled appointments with practical test applicants because of the outbreak. “As a result, applicants may run into the issue of not being able to complete their practical within the required time limits,” Cooper said.
- A related concern for applicants is that airman knowledge tests are valid as a practical test prerequisite for two years from the date they are taken. But if a knowledge test were to expire with testing facilities still closed, applicants would have no way to retake their knowledge tests, leaving them ineligible for the practical test indefinitely without some kind of FAA relief.
- Reduced access to aircraft and CFIs could affect pilots’ livelihoods and the ability to exercise their privileges by triggering a wave of expirations of instrument proficiency checks, flight reviews, and recency-of-experience intervals unless the FAA can make exceptions, Cooper added.
- Medical certificate expiration dates are also looming. AOPA’s medical certification team is monitoring the situation and working with the FAA on contingencies, he said.
- Aircraft maintenance and continuing airworthiness requirements must also be addressed.
The European Union Aviation Safety Agency is addressing the needs of the aviation community in EASA-member countries under the exemption notification provisions of its rules, which permit grant extensions of validity periods of “ratings, certificates, and attestations” for up to eight months.
