R-ATP Exemption Follow-Up

Back in 2014, I wrote about six different universities and a community college that were all petitioning the FAA to become exempt from the requirement to hold a ground school certification so that they could participate in the R-ATP program.

That post had become somewhat stale, so here is a look back at what happened in the past few years.

Petitions Denied

Chandler-Gilbert Community College was denied its exemption in November 2017 and as of May 2018 was not authorized to certify R-ATP applicants.

Metropolitan State University of Denver was denied its exemption in July 2014 and as of May 2018 was not authorized to certify R-ATP applicants.

Denied and Then Authorized

Baylor University was denied its exemption in December 2014 and later gained R-ATP authorization in February 2016.

Eastern Michigan University was denied its exemption in August 2015 and later gained R-ATP authorization in July 2016.

Jacksonville University formally withdrew its petition for exemption in September 2016 and gained R-ATP authorization later that same month.

Petitions Granted

Auburn University was granted its exemption in November 2015, allowing Part 61 students who graduated between August 2010 and December 2016 to apply for R-ATP.

Purdue University was granted its exemption in July 2014, allowing Part 61 students who graduated between January 2009 and December 2016 to apply for R-ATP.

R-ATP Cross Country Time

ATP Qualifications Job AidI previously wrote about a regulatory boo boo that made it impossible to determine how much cross country flying experience was required to obtain a restricted ATP certificate.  The regulation that allowed students to apply for the rating with 30 college credit hours was never included in the nearby paragraph authorizing reduced cross-country time requirements.

To bring some clarity to this issue, I can now point you to this official checklist: FAA ATP Qualifications

Although this checklist is not regulatory, it is published by the FAA and so shows the original intent of the R-ATP regulation to allow anyone with 200 hours of cross-country time to apply for reduced minimums.

Since FAR § 61.160(e) contradicts the above checklist, I still anticipate a future amendment to fix this regulation.

Safety Pilots are Not Allowed Cross Country Experience

Think twice the next time you log a “time share” flight or act as a safety pilot on a cross country flight.  According to legal interpretations from the FAA dated in 2009, only the pilot flying is allowed to log cross country time under § 61.  As explained in the Gebhart Interpretation:

Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time.  Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight.

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Restricted ATP Minimums

Easy-to-read details about the new ATP rules?  You found them!  I understand the need for simple explanations. There are six ways to get an ATP license now, each with different requirements.

This is my summary and comparison of the R-ATP minimums from 14 C.F.R. § 61.159 and § 61.160.

160 (a) 160 (b) 160 (c) 160 (d) 160 (f) 159
Age 21 years 21 years 21 years 21 years 21 years 23 years
Total Time as a Pilot 750 hours 1,000 hours 1,250 hours 1,250 hours 1,500 hours 1,500 hours
Cross-Country Time 200 hours 200 hours 200 hours see notes 200 hours 500 hours
Instrument Training Any § 141 § 141 § 141 Any Any
Commercial Training Any § 141 § 141 § 141 Any Any
Education Military Bachelor Associate Bachelor
Concentration Aviation Aviation Aviation
Certification see notes see notes see notes
Recognized Coursework 60 credits 30 credits 30 credits

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R-ATP Exemption for Part 61 Training

Logos of EMU, Jacksonville, MSU Denver, and Purdue.My searches on federal websites found four petitions by universities seeking R-ATP authorization without a required part 141 ground school certificate.

The petitioners are, in alphabetical order: Eastern Michigan University, Jacksonville University, Metropolitan State University of Denver, and Purdue University.

Letters and documents filed by these universities seem to be routine.  I will point out also that the Jacksonville petition included a copy of the university’s rejection letter from the FAA dated December 2013.

While the FAA is not currently accepting comments on these petitions, I would like to offer my encouragement.  The FAA should authorize these universities as rapidly as possible, recognizing they are accredited institutions that offer 4-year degrees with aviation concentrations.  This is the purpose and intent of the R-ATP program, after all.

Details and reference numbers are listed below, in chronological order.

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CFI Checkrides Do Count as Flight Reviews

Federal Register Cover PageYes, it’s true!  After a CFI or CFII checkride, you do not need another flight review for 24 calendar months.

For example, I passed the commercial AMEL practical test on 26 October 2012.  When I was hired in October 2013, I reported my flight review date for my commercial test, meaning I would need a flight review in 2014.  But, then my flight review date changed.  Why?

As of 15 November 2013, flight instructor practical tests are recognized as flight reviews.  This rule was published as a revision to FAR 61.56 in the Federal Register under RIN 2120-AK23 on 16 September 2013, pages 56822 through 56829.

Thanks to this new regulation, my flight review date changed to 19 August 2013.  I will need a flight review in 2015.

If you find conflicting information on this topic, it is likely obsolete.  This new regulation does not appear in the ASA printing of the 2014 FAR/AIM.

Enjoy the new grace period, and have a Happy New Year!

First Officer Qualification Rule in Detail

Cover page of the Federal Register for July 15.The new first officer qualifications are a hot topic.  On July 10, the FAA released its Final Rule, which should appear in the Federal Register next week.  Everyone has something to say about this.  But opinions aside, all I can I find on the web is the text of the new rule and several paraphrased copies of the FAA press release.

Let’s take a closer look at what’s inside the 221 pages of the Pilot Certification and Qualification Requirements for Air Carrier Operations.

To get the most important information up front here, I compiled a detailed summary of changes as they would apply to a graduate of a qualifying 4-year degree program.

I also outlined the structure of the Final Rule and noted the page numbers of some important sections.  The small page numbers correspond to the unofficial FAA version, followed in parentheses by the official page number in the Federal Register.  For example: Page 1 (42324).  This will help you to reference either version of the Final Rule.

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