FAA Issues SFAR
The FAA has issued a Special Federal Aviation Regulation (SFAR) providing regulatory relief to persons that have been unable to comply with specific FAA requirements due to COVID-19 impacts. Because the SFAR consists of three sections, each with different applicability, a careful reading and some interpretation is required to determine what relief is applicable to CAP flight operations. The discussion below addresses CAP/DO’s interpretation of the application of each section and CAP’s planned approach to implement the SFAR.
Section A (Training, Recency, Testing and Checking Requirements). This section provides relief to certain eligible pilots when conducting specific operations. For the purpose of CAP operations, flight instructors and persons holding a remote pilot certificate are provided relief while operating under Part 91 and Part 107, respectively. Relief is also provided to pilots conducting any operation that requires the pilot to hold at least a commercial pilot certificate or for private pilots conducting flights to transport essential goods and/or medical supplies. Since relief for commercial or private pilots is based on mission requirements, determination of eligibility must be made during the mission approval process and will only be considered when there is a shortage of qualified pilots to support the mission.
Relief provided under Section A includes extension of Flight Review expirations, extension of the timeframe permitted to meet instrument recency requirements, and extension of remote pilot knowledge recency requirements. CAP’s guidelines for each item of relief are discussed below:
- Flight Review. CAP Instructor Pilots holding an FAA Flight Instructor Certificate who have a Flight Review expiring in the period March 2020 to June 2020 are eligible to have their Flight Review expiration date extended to 30 June 2020. Prior to granting an extension within Ops Quals, CAP must validate that the pilot has complied with FAA required risk mitigations. Accordingly, the following process must be followed:
- Go to eServices > Ops Quals > Pilot – View/Upload Documents and upload to “FAA Flight Review” documentation of 10 hours PIC in the past 12 calendar months in an aircraft for which you are rated.
- Go to eServices > Ops Quals > Pilot – View/Upload Documents and upload to “FAA Flight Review” documentation of 3 WINGS credits accomplished Jan 2020 or later.
- Go to eServices > Ops Quals > Pilot FAA Requirements – Flight Review and enter 30 June 2018 in the Flight Review date, then click Submit.
- Instrument Recency. As a risk mitigation measure, CAP pilots shall not use the 3-month extended instrument recency period provided by the SFAR for CFIs when flying CAP aircraft.
- Remote Pilot Knowledge Recency. CAP Remote Pilots who need to re-establish recency of knowledge between April 2020 and June 2020, may use an online training course (www.faasafety.gov) to extend their expiration by 6 months. This is a manual process which is not tracked in Ops Quals.
Section B (Duration and Renewal Requirements) applies to all operations. Relief provided under Section B includes extension of medical and flight instructor certificates, as well as practical test validity periods. CAP’s guidelines for each item of relief are discussed below:
- Medical Certificate. Medical certificates expiring March 2020 – June 2020 will automatically be extended to 30 June 2020. Such extension shall not be interpreted as a change to the requirement of 14 CFR 61.53 regarding prohibition on operations during medical deficiency.
- CFI/CFII Certificates. FAA Flight Instructor Certificates expiring March 2020 – June 2020 will automatically be extended to 30 June 2020. Flight instructors shall refer to the guidance provided in SFAR 118 to determine how to meet the revised requirements for renewal.
- Prerequisites for Practical Tests. Knowledge tests expiring between March 2020 and June 2020 can be presented for a practical test for an additional 3 months past their expiration date.
Section C (Special Flight Permits) does not apply to CAP.
Action in Progress. Where appropriate, medical and FAA flight instructor expiration dates have been extended within Ops Quals. Qualifications are currently being updated to reflect the extensions. This process should be complete today. Ops Quals remains CAP’s system of record regarding aircrew qualifications and flight release. Accordingly, unless a mission has been granted specific relief related to commercial pilot privileges, pilots shall not be released unless Ops Quals or a current FRO Support Report show the pilot to be qualified. If you believe a member is eligible for relief, but it has not been granted in Ops Quals, submit a Help Desk ticket in eServices with the subject “SFAR – [Qualification Name].” Mission critical release issues should be directed to the NOC.