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Q: pilot requirements ( Answered,   1 Comment )
Subject: pilot requirements
Category: Miscellaneous
Asked by: jimtac-ga
List Price: $5.00
Posted: 05 Feb 2006 07:53 PST
Expires: 07 Mar 2006 07:53 PST
Question ID: 441697
as a pilot holding a single-engine land rating, can i fly a
multiengine aircraft which requires only one pilot and carrying no
Subject: Re: pilot requirements
Answered By: byrd-ga on 05 Feb 2006 12:23 PST
Hi jimtac-ga,

I thought this would be a clearcut case of "no," and a simple matter
of locating the right FAR to document that. Much to my surprise I
learned otherwise and in fact, the short answer to your question is a
qualified "yes." However, the qualifications are significant, so
please pay attention to the details.


First, going strictly by the FARs, it would appear the answer is no,
you can't act as PIC in an aircraft for which you don't have the
appropriate class rating. The class ratings are spelled out in

 61.5 Certificates and ratings issued under this part.
(b) The following ratings are placed on a pilot certificate (other
than student pilot) when an applicant satisfactorily accomplishes the
training and certification requirements for the rating sought:

 (2) Airplane class ratings- 

  (i) Single-engine land. 
  (ii) Multiengine land. 
  (iii) Single-engine sea. 
  (iv) Multiengine sea. 

Combining that with 

 61.3   Requirement for certificates, ratings, and authorizations.

(a) Pilot certificate. A person may not act as pilot in command or in
any other capacity as a required pilot flight crewmember of a civil
aircraft of U.S. registry, unless that person-

(1) Has a valid pilot certificate or special purpose pilot
authorization issued under this part in that person's physical
possession or readily accessible in the aircraft when exercising the
privileges of that pilot certificate or authorization.


 61.31   Type rating requirements, additional training, and
authorization requirements.

 (d) Aircraft category, class, and type ratings: Limitations on
operating an aircraft as the pilot in command. To serve as the pilot
in command of an aircraft, a person must?

(1) Hold the appropriate category, class, and type rating (if a class
rating and type rating are required) for the aircraft to be flown;

it would seem that, unless you have in your possession a certificate
with the multi-engine class rating on it, you can not exercise the
privileges of a multiengine rating, i.e. act as PIC in a ME aircraft.


However, this question is further addressed and clarified in an
Advisory Circular, which as you likely know, carries regulatory weight
when, as in this case, it is initiated and issued by the Flight
Standards Service
Certifications Branch, AFS-840 and intended to act as a further guide
and supplement to the FAR.

In this case, the pertinent Advisory Circular is AC No. 61-98A. 

It says, 

Subchapter 13. Solo Operations in an Aircraft for which the Pilot Does
Not Hold a Category and Class Rating

A person may not act as PIC of an aircraft that is carrying another
person or is operated for compensation or hire, unless that person
holds a category and class rating for that aircraft; however, subject
to the previous restrictions, a person may act as PIC of an aircraft
in solo flight without holding a category and class rating appropriate
to that aircraft if he or she has received the flight instruction and
endorsement required by FAR Section 61.31(d), or has soloed and logged
PIC time in that category and class of aircraft before November 1,

a.The instruction required by FAR Section 61.31(d)(2) must be in the
pilot operations required by FAR Part 61, appropriate to that category
and class of aircraft for first solo, and must be given to the pilot
by an appropriately rated CFI who, upon finding the pilot competent to
solo that category and class of aircraft, so endorses the pilot's
logbook. The format for the required endorsement is contained in the
current issue of AC 61-65.

b.CFI's should be aware that the provisions of FAR Section

61.31(d) were intended to facilitate a pilot's need to acquire solo
flight time in the pursuit of a category and class rating in that
aircraft. This FAR section was not intended to encourage unlimited or
unrestricted solo operations for an indefinite time period.
Accordingly, the CFI should determine the intentions of any pilot
seeking such an endorsement and should consider such requests only in
cases where pilots are seeking to acquire additional category and/or
class ratings. In any case, CFI's should consult FAR Section 61.87 to
determine the criteria for first solo, and may also wish to consult
the appropriate PTS before advising pilots on what will be required to
obtain a solo category and class endorsement. After providing the
required instruction, a CFI may want to consider the need for an
endorsement which restricts the pilot's operations to whatever extent
the CFI considers necessary in the interest of safety.For example, the
endorsement might limit the pilot to local operations only, or to
flight in day-VFR conditions only. Finally, the CFI may want to
include an expiration date on the endorsement which coincides with the
date by which the applicant is expected to have completed the
practical test. Before undertaking the instruction leading to such an
endorsement, the CFI should explain to the pilot the instructor's
prerogative to issue an endorsement containing restrictions.


This circular does not appear to have a newer version anywhere, and is
cited in many places by various people and entities, including CFIs
and flight schools, so I believe it is the most current regulation
applying to this situation. For some reason, the FAA library link is
not working. However, the full text of this AC is available from a
number of sources. I'll include the FAA link for your info, and a
couple of others in several formats as well: (non-working as of this date)

In addition, here's a link to FAR Part 61. The specific FARs cited in
this answer and in the referenced AC are easily accessible by
hyperlink from there:


 61.3   Requirement for certificates, ratings, and authorizations.
 61.5   Certificates and ratings issued under this part.
 61.31  Type rating requirements, additional training, and
authorization requirements.
 61.87  Solo requirements for student pilots.
 61.109 Aeronautical experience.

AC 61-65 (endorsements): (non-working as of this date) 


  35. To act as PIC of an aircraft in solo operations when the pilot
who does not hold an appropriate category/class rating:  61.31(d)(3)

I certify that (First name, MI, Last name) has received the training
as required by  61.31(d)(3) to serve as a PIC in a (category and
class of aircraft). I have determined that he/she is prepared to serve
as PIC in that (make and model of aircraft).  S/S [date] J.J. Jones
987654321CFI Exp. 12-31-00


Finally, should you want to get an official opinion on this matter
just to be sure, I'd recommend arming yourself with this information,
and then calling or visiting your nearest Flight Standards District
Office (FSDO) to ask about it. Here's a link to the FSDO locator:


I hope this information fully answers your question. In preparing this
answer, I assumed you were asking as a U.S. certificated pilot and so
provided information based on U.S. FAA regulations. If you needed
information for a different country, if you are still uncertain of any
details and/or if you have trouble with any links, please ask in a
Request for Clarification before rating and closing your question, so
I can be sure you have the information you need.

Good luck to you, and thanks for a very interesting hunt! We've both
learned something here!  :-)

Best wishes, and blue skies,

Search strategy:

As a pilot myself (Commercial, Instrument, ASEL) I already had links
in my bookmarks to the FARs and was fairly sure this topic would
likely be addressed in Part 61, so I went there first and read the
appropriate regulations. But since there was some ambiguity there, I
then searched on the following terms:

[FAR class rating]
[FAR class rating required]
[FAR "when is" class rating required]
[FAR "class rating appropriate"]

and located information referencing AC 68-91a. After being unable to
access the full text of the AC on the FAA website, I then searched
further, using

[FAA AC 68-91a]

to locate several other copies of the text of this AC. And finally, I searched on 

[AC 61-65d Certification]

to locate the text of that AC 61-65 pertaining to the required
endorsements mentioned in 68-91a.
Subject: Re: pilot requirements
From: weisstho-ga on 05 Feb 2006 18:39 PST
Nice Answer, Byrd!!

Of course the REAL answer is that insurance coverage would no doubt be
voided by such action. You prang it and you own it.

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