Regulations – Robert Chapin

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

I 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.

Update: After 8 years, the FAA corrected paragraphs (d) and (e) as follows.

The FAA is also making a clarifying amendment to § 61.160(e) by adding a cross-reference that was inadvertently omitted in the Pilot Certification and Qualification Requirements for Air Carrier Operations final rule.As evident from the preamble to that final rule, § 61.160(e) was intended to “reduce the cross-country flight time required for all applicants for an R-ATP [airline transport pilot certificate with restricted privileges] certificate to 200 hours.”However, the express language of the rule provided relief only to those categories of applicants listed in paragraphs (a), (b), and (c). Because the relief in § 61.160(e) was intended for all eligible applicants,including persons eligible under § 61.160(d), the FAA is amending § 61.160 by adding a cross-reference to paragraph (d).

86 FR 62084

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

Yes, 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

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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