May 18, 2020 (Updated November 19, 2020)
Page 1 of 20
Relief Granted by SFAR in Response to the COVID-19 Health Emergency
Frequently Asked Questions and Answers
Relief – In General
Relief from Certain Training, Recency, Testing and Checking Requirements
1. Second-in-Command Qualifications (§61.55) (SFAR III.A.1)
2. Flight Review (§61.56) (SFAR III.A.1)
3. Recent Flight Experience: Pilot in Command (§61.57) (SFAR III.A.1)
4. Pilot-in-Command Proficiency Check: Operation of an Aircraft That Requires More Than
One Pilot Flight Crewmember or is Turbojet-Powered (§61.58) (SFAR III.A.1)
5. Part 91, Subpart K Flight Crewmember Requirements (§§91.1065, 91.1067, 91.1069,
91.1071, 91.1073, 91.1089, 91.1091, 91.1093, 91.1095, 91.1099, 91.1107) (SFAR
III.A.2)
6. Mitsubishi MU-2B Series Special Training, Experience, and Operating Requirements
(Part 91, §§91.1703, 91.1705, 91.1715) (SFAR III.A.3)
7. Aeronautical Knowledge Recency (§107.65) (SFAR III.A.4)
8. Flight Crewmember Requirements (§§125.285, 125.287, 125.289, 125.291, 125.293)
(SFAR III.A.5)
9. Robinson R-22/R-44 Special Training and Experience Requirements (SFAR 73) (SFAR
III.A.6)
Relief from Certain Duration and Renewal Requirements
1. Medical Certificates: Requirement and Duration (§61.23) (SFAR III.B.1)
2. Prerequisites for Practical Tests (§61.39) (SFAR III.B.1)
3. Renewal Requirements for Flight Instructor Certification (§61.197) (SFAR III.B.1)
4. Relief for U.S. Military and Civilian Personnel Who are Assigned Outside the United
States in Support of U.S. Armed Forces Operations (SFAR 100‑2) (SFAR III.B.2)
5. Requirements for a Pilot School Certificate (§141.5) and Renewal of Certificates and
Ratings (§141.27) (SFAR III.B.5)
Relief – In General
Q: What is an SFAR?
A: SFAR stands for Special Federal Aviation Regulation (SFAR), and it is typically a temporary
rule to address a temporary situation. It is a rule and not an exemption, deviation, or
authorization.
Q: Why am I just hearing about this now? What about the public comment period?
A: The Administrative Procedure Act (APA) (5 U.S.C.) authorizes agencies to dispense with
notice and comment procedures for rules when the agency for “good cause” finds that those
procedures are “impracticable, unnecessary, or contrary to the public interest.” The FAA finds
good cause under 5 U.S.C. 553(b)(3)(B) to waive prior notice and the opportunity for public
comment.
May 18, 2020 (Updated November 19, 2020)
Page 2 of 20
Q: To whom does this SFAR apply?
A: This SFAR applies to:
(a) Certain persons who are unable to meet the following requirements during some
period of time between March 1, 2020 and January 31, 2021—
(1) Training, recency, testing, and checking requirements specified in this part, parts
91, 107, and 125 of this chapter, and SFAR No. 73 of this part; and
(2) Duration and renewal requirements specified in this part, parts 63, 65, and 141 of
this chapter, and SFAR No. 100–2 of this part; and
(b) Certain air carriers and operators who are unable to obtain special flight permits with
a continuing authorization under part 21 of this chapter for the purpose of flying the
aircraft to a point of storage.
Q: How do I know if I am eligible for this relief?
A: The provisions in this final rule provide temporary relief to persons who have been unable to
meet certain requirements during the national emergency concerning the novel coronavirus
disease (COVID-19). There are two sections to the relief. The first section, Training, Recency,
Testing and Checking Requirements, contains specific restrictive applicability requirements and
is not available to all persons. The second section, Duration and Renewal Requirements, has
certain qualifications specified in the details of the relief.
Relief for Training, Recency, Testing and Checking Requirements in the SFAR applies to -
(1) Operations conducted for compensation or hire under parts 91, 125, 133 and 137 of
this chapter by persons who are exercising the privileges of a commercial pilot
certificate issued under part 61 of this chapter;
(2) Operations conducted by persons who are exercising the privileges of a private pilot
certificate issued under part 61 of this chapter, provided the person meets one of the
following paragraphs—
(i) The person is conducting a charitable medical flight for a volunteer pilot
organization pursuant to an exemption issued under part 11 of this chapter,
and the flight involves only the carriage of persons considered essential for the
flight;
(ii) The person is conducting an agricultural aircraft operation under a private
agricultural aircraft operating certificate issued in accordance with § 137.19;
(iii) The person has at least 500 hours of total time as a pilot, that includes at least
400 hours as a pilot in command and at least 50 hours that were accrued
within the preceding 12 calendar months, and the person is conducting one of
the following operations consistent with the compensation or hire prohibitions
specified in § 61.113:
(A) A flight incidental to that person’s business or employment;
(B) A flight in support of family medical needs or to transport essential
goods for personal use;
(C) A flight necessary to fly an aircraft to a location in order to meet a
requirement of this chapter; or
(D) A flight to transport essential goods and medical supplies to support
public health needs;
May 18, 2020 (Updated November 19, 2020)
Page 3 of 20
Relief from Certain Training, Recency, Testing and Checking Requirements
1. Second-in-Command Qualifications (§61.55)
Q: What relief is available?
A: Relief is granted from the requirement that no person may serve as SIC of an aircraft
certificated for more than one required pilot flight crewmember or in operations requiring a SIC
unless that person has, within the previous 12 calendar months, become familiar with certain
information specific to the type aircraft and performed and logged pilot time in the type of
aircraft or in a flight simulator that represents the type of aircraft. The usual one grace month that
is allowed will be increased by one or two grace months depending upon your base month. For
SICs due through September 2020, a total of three grace months is available. For SICs due in
October through January 2021, a total of two grace months is available.
Q: What relief is not available?
A: The base month does not change as a result of the SFAR. When the requirement is met, the
base month will remain the same.
SFAR No. 118-2 does not extend further relief to pilots who have already taken the relief
provided by SFAR No. 118 or SFAR No. 118-1.
Q: How long does the relief last?
A: If the base month is anytime from March 2020 through September 2020, there are three grace
months after the base month. If the base month is anytime from October 2020 through January
2021, there are two grace months after the base month. A pilot whose base month is January
2021 will have until March 31, 2021 to complete the requirements of this section.
Q: Who is affected by the relief?
A: This relief is extended to pilots whose base month falls in March 2020 through January 2021
and who meet the SFAR applicability, eligibility, and qualifications.
Q: How do I comply with this relief?
A: Pilots must review the following information for the specific type of aircraft for which they
are seeking SIC privileges:
a. Operational procedures applicable to the powerplant, equipment, and systems;
b. Performance specifications and limitations;
c. Normal, abnormal, and emergency operating procedures;
d. Flight manual; and
e. Placards and markings.
Prior to serving as an SIC, pilots must have also logged at least three takeoffs and landings to
a full stop as the sole manipulator of the flight controls within the 180 days preceding the date of
the flight.
May 18, 2020 (Updated November 19, 2020)
Page 4 of 20
Q: What are any continuing or ongoing steps for the relief?
A: The pilot must have reviewed the information in §61.55(b)(1)(i)-(v) during the pilot’s grace
month(s) and always maintain a 180 day lookback for three takeoffs and landings.
2. Flight Review (§61.56)
Q: What relief is available?
A: The requirement for a flight review as per §61.56.
Q: What relief is not available?
A: The SFAR does not provide relief to pilots who do not meet the applicability requirements of
the SFAR stated at the beginning of the SFAR.
Q: How long does the relief last?
A: The SFAR provided up to a three calendar month grace period for pilots who were current to
act as pilot in command (PIC) of an aircraft in March 2020 and whose flight review was due in
March 2020 through September 2020. However, with increased aviation activity and growing
availability of instructors, the FAA has determined that pilots whose flight review is due from
October 2020 through January 2021 require at most two additional calendar months to complete
their flight reviews. Accordingly, the SFAR provides up to a two calendar month grace period
for pilots whose flight review is due from October 2020 through January 2021. The two-calendar
month extension applies only to pilots who were current to act as PIC of an aircraft in March
2020, and whose flight review is due October 2020 through January 2021. Eligible pilots must
complete the requirements prescribed in SFAR 118-2 prior to serving as a PIC. To act as PIC of
an aircraft after the relief period ends, the person that used this relief must satisfactorily complete
a flight review in accordance with § 61.56.
Q: Who is affected by the relief?
A: Relief for the flight review available under the SFAR only affects certain eligible pilots
conducting specific operations for which the FAA has determined relief is appropriate. See the
general section of this Q&A for operations that meet the applicability requirements of the SFAR
and qualify pilots for § 61.56 relief under the SFAR.
Q: How do I comply with this relief?
A: After determining that you meet the applicability requirements for relief from the flight
review provided by the SFAR, you will also need to comply with the requirements prescribed in
SFAR 118-2. See SFAR 118-2 for specific details.
3. Recent Flight Experience: Pilot in Command (§61.57)
Q: What relief is available?
A: Beginning October 1, 2020, SFAR 118-2 provides no further relief to the instrument recency
requirements of § 61.57(c).
Q: Why is further relief not available?
A: Opportunities to obtain the required instrument experience are available to pilots. Flying and
flight training activities have gradually resumed since the original § 61.57(c) relief was originally
May 18, 2020 (Updated November 19, 2020)
Page 5 of 20
made available in April 2020. The continued COVID-19 public health emergency no longer
significantly affects the ability to comply with the recency requirements.
4. Pilot-in-Command Proficiency Check: Operation of an Aircraft That Requires
More Than One Pilot Flight Crewmember or is Turbojet-Powered (§61.58)
Q: What relief is available?
A: Relief is available from the requirement of a PIC proficiency check for certain pilots who fly
an aircraft that requires more than one pilot flight crewmember or is turbojet-powered. For pilots
who meet SFAR applicability and qualifications, the SFAR extends the time available to
complete the proficiency check. The usual one grace month that is allowed will be increased by
one or two grace months depending upon your base month. For PICs due through September
2020, a total of three grace months is available. For PICs due in October through January 2021, a
total of two grace months is available.
Q: What relief is not available?
A: This section does not provide relief to persons conducting operations under 14 CFR subpart K
of part 91, parts 121, 125, 133, 135, or 137.
The base month does not change as a result of the SFAR. The base month remains the same.
SFAR No. 118-2 does not extend further relief to pilots who have already taken the relief
provided by SFAR No. 118 or SFAR No. 118-1.
Q: How long does the relief last?
A: If the base month is anytime from March 2020 through September 2020, there are three grace
months after the base month. If the base month is anytime from October 2020 through January
2021, there are two grace months after the base month. A pilot whose base month is January
2021 will have until March 31, 2021 to complete the requirements of this section.
Q: How do I comply with this relief?
A: Pilots must meet the flight experience requirements of § 61.57 that are applicable to the
operation to be conducted. Pilots must also have reviewed, within the previous 3 calendar
months preceding the month of the flight, the following for each specific aircraft type for which
PIC privileges are desired:
a. Operational procedures applicable to the powerplant, equipment, and systems.
b. Performance specifications and limitations.
c. Normal, abnormal, and emergency operating procedures.
d. Flight manual.
e. Placards and markings.
Q: What are any continuing or ongoing steps for the relief?
A: A pilot must maintain currency required by §61.57. A pilot must have completed the aircraft
review of
a. Operational procedures applicable to the powerplant, equipment, and systems,
May 18, 2020 (Updated November 19, 2020)
Page 6 of 20
b. Performance specifications and limitations,
c. Normal, abnormal, and emergency operating procedures,
d. Flight manual, and
e. Placards and markings within the previous three calendar months.
5. Part 91, Subpart K Flight Crewmember Requirements (§§91.1065, 91.1067, 91.1069,
91.1071, 91.1073, 91.1089, 91.1091, 91.1093, 91.1095, 91.1099, 91.1107)
Q: What relief is available?
A: Relief is granted for the timeframe requirements for 14 CFR part 91 subpart K testing and
checking, recurrent training, check pilot (simulator) and flight instructor (simulator) flight
segments or line-observation program, and check pilot and flight instructor observation check
requirements.
Q: What relief is not available?
A: The relief does not apply to the requirements for initial training, testing, checking, or
qualification.
Q: How long does the relief last?
A: Relief is available for events required to be completed between March 1, 2020 and September
30, 2020. An additional two grace months is provided, for a total of three grace months. For
events due from October 1, 2020 through January 31, 2021, one additional grace month is
provided for a total of two grace months.
Q: Who is affected by the relief?
A: Relief is available to pilots, flight attendants, check pilots, and flight instructors operating
under 14 CFR part 91 subpart K.
Q: How do I obtain this relief?
A: To obtain relief, the management specification holder must submit to their Principle
Operations Inspector (POI), an acceptable safety mitigation plan. The POI will review the plan
and either accept it or inform the management specification holder it is unacceptable.
Q: How do I comply with this relief?
A: The management specification holder must comply with the requirements of their safety
mitigation plan.
Q: Must a part 91 subpart K management specification holder revise its FAA-approved training
program to include the safety mitigation plan?
A: No. There is no requirement for a management specification holder to revise its FAA-
approved training program to include the safety mitigation plan.
May 18, 2020 (Updated November 19, 2020)
Page 7 of 20
6. Mitsubishi MU-2B Series Special Training, Experience, and Operating
Requirements (Part 91, §§91.1703, 91.1705, 91.1715)
Q: What relief is available?
A: Relief is available to the requirement that a person may not manipulate the controls, act as
PIC, or act as SIC, of a MU-2B series airplane for the purpose of flight unless that person
satisfactorily completes, if applicable, recurrent pilot training on the special emphasis items and
all items listed in the Training Course Final Phase Check in accordance with an FAA-approved
MU-2B training program that meets the standards of subpart N of part 91 within the preceding
12 months. The usual one grace month that is allowed will be increased by one or two grace
months depending upon your base month. For pilots due through September 2020, a total of
three grace months is available. For pilots due in October through January 2021, a total of two
grace months is available.
The SFAR also provides relief to the requirement that a person must satisfactorily complete a
flight review in accordance with § 61.56 and § 91.1715(c) in a Mitsubishis MU-
2B series airplane or an MU-2B simulator approved for landings with an approved course
conducted under part 142.
Q: What relief is not available?
A: This relief is not applicable to pilots who are required to complete initial/transition or
requalification training in an MU-2B series airplane.
The base month does not change as a result of the SFAR. When the requirement is met, the base
month will remain the same.
As required by § 91.1715(a), the pilot must maintain the takeoff and landing currency
requirements of § 61.57 in the MU-2B series airplane.
SFAR No. 118-2 does not extend further relief to pilots who have already taken the relief
provided by SFAR No. 118 or SFAR No. 118-1.
Q: How long does the relief last?
A: If the base month is anytime from March 2020 through September 2020, there are three grace
months after the base month. If the base month is anytime from October 2020 through January
2021, there are two grace months after the base month. A pilot whose base month is January
2021 will have until March 31, 2021 to complete the requirements of this section.
Q: Who is affected by the relief?
A: This relief is extended to pilots whose base month falls in March 2020 through January 2021
and who meet the applicability and qualifications specified in the SFAR.
Q: How do I comply with this relief?
A: To exercise the relief, a pilot must have logged a minimum of 10 hours of flight time in an
MU-2B series airplane within the previous 12 calendar months of the base month.
May 18, 2020 (Updated November 19, 2020)
Page 8 of 20
Three of those hours must be obtained within 3 calendar months preceding the base month
In addition, as required by §91.1715(a), the pilot must have at least 3 takeoffs and landings to a
full stop as sole manipulator of the controls in an MU-2B series airplane within the last 90 days
prior to the flight.
A pilot must complete 3 hours of self-study since January 1, 2020, and preceding the date of the
flight. This self-study must include the ground training required by §91.1705(h)(1) and the
special emphasis items listed in the approved MU-2B training program last completed. A pilot
must review the limitations, procedures, aircraft performance, and MU-2B Cockpit Checklist
procedures applicable to the flight training curriculum required by §91.1705(h)(2) for the MU-
2B model flown and the current general operating and flight rules of part 91
A pilot must complete online courses for 3 WINGS credits. These courses must have been
completed since January 1, 2020.
Q: Are there any other specific CFRs that I must comply with to take advantage of this relief?
A: A pilot exercising this relief must comply with all other part of Part 91, Subpart N—
Mitsubishi MU-2B Series Special Training, Experience, and Operating Requirements, including
the requirement that the takeoff and landing currency requirements of §61.57 of this chapter
must be maintained in the Mitsubishi MU-2B series airplane.
Q: What are any continuing or ongoing steps for the relief?
A: A pilot must have at least 3 takeoffs and landings to a full stop as sole manipulator of the
controls in an MU-2B series airplane within the last 90 days prior to the flight.
7. Aeronautical Knowledge Recency (107.65)
Q: What relief is available?
A: Provides relief to airmen who are due to establish recency of knowledge in the 24th calendar
month from the month they last completed training/testing. Recency of knowledge lapses
(“expires”) on the first day of the 25th calendar month from the month they last completed
training/testing. The relief will extend an airman’s aeronautical knowledge recency six calendar
months provided the requirements in the SFAR are completed.
Q: What relief is not available?
A: Airmen whose recency of knowledge (“currency”) lapsed on March 1, 2020 were not
restricted by the COVID-19 pandemic from visiting a knowledge testing center in February,
2020. Applicants for a remote pilot certificate must still comply with §107.63. This SFAR does
not offer any relief for those requirements.
CFIs are not authorized to endorse recency of knowledge required by §107.65.
An airman operating in accordance with this SFAR will be allowed to take the training course a
single time to establish recency of knowledge. Completing the training course an additional time,
will not “reset” the six calendar month extension.
May 18, 2020 (Updated November 19, 2020)
Page 9 of 20
Q: How long does the relief last?
A: Unless otherwise extended, airmen who are in their sixth calendar month must comply with
§107.65 as written in order to continue flying in the following calendar month. For example, if
an airman completes the online training per this SFAR on April 18th, 2020, in September, 2020
they will need to establish recency of knowledge by complying with §107.65 as written.
Termination of this SFAR will require compliance with §107.65 as written.
Q: Who is affected by the relief?
A: This SFAR applies to airmen who are:
1. Certificated under part 107; and
2. Whose recency of knowledge lapses between April 1, 2020 and September 30, 2020; and
3. Who must meet recency of knowledge requirements by passing an aeronautical
knowledge test per §107.65(a) or (b)
Q: How do I comply with this relief?
A: Airmen who are eligible and comply with the provisions of the SFAR will be able to take
either online training course (ALC-451 or ALC-515) at www.faasafety.gov in lieu of taking an
aeronautical knowledge test at a knowledge testing center required by §107.65(a) or (b).
Completing the online training course under the provisions of this SFAR will extend an airman’s
aeronautical knowledge recency six calendar months.
Q: I can’t find my previous aeronautical knowledge test/training course certificate. How may I
obtain a copy of my previous certificate required by this SFAR?
A: To obtain a copy of a previous aeronautical knowledge test certificate, contact the Airman
Certification Branch at (866) 878-2498. If an airman completed the online training course at
www.faasafety.gov, the airman may re-print the airman’s certificate from the airman’s account.
Q: To whom does the SFAR apply?
A: The SFAR applies to an airman:
1. Who is certificated as a remote pilot under part 107; and
2. Whose recency of knowledge lapses between April 1, 2020 and September 30, 2020; and
3. Who must meet recency of knowledge requirements by passing an aeronautical
knowledge test per §107.65(a) or (b).
Q: What does the SFAR do?
A: An airman who is eligible and complies with the provisions of the SFAR will be able to take
either online training course (ALC-451 or ALC-515) at www.faasafety.gov in lieu of taking an
aeronautical knowledge test at a knowledge testing center required by §107.65(a) or (b).
Completing the online training course under the provisions of the SFAR will extend an airman’s
aeronautical knowledge recency six calendar months.
May 18, 2020 (Updated November 19, 2020)
Page 10 of 20
Q: What happens after the additional six calendar months of aeronautical knowledge recency
the SFAR provides or the SFAR is terminated?
A: Unless otherwise extended, an airman who is in their sixth calendar month must comply with
§107.65 as written in order to continue exercising the privileges of their remote pilot certificate
in the following calendar month. For example, if an airman completes the online training per the
SFAR on May 4th, 2020, prior to November 1st, 2020 they will need to establish recency of
knowledge by complying with §107.65 as written. Termination of the SFAR will require
compliance with §107.65 as written.
Q: When am I due to establish recency of knowledge and when does my recency of knowledge
lapse?
A: An airman is due to establish recency of knowledge in the 24th calendar month from the
month they last completed training/testing. Recency of knowledge lapses (“expires”) on the first
day of the 25th calendar month from the month they last completed training/testing.
Q: My currency expired on March 1, 2020 (or earlier), am I eligible for this relief?
A: No. An airman whose recency of knowledge (“currency”) lapsed on March 1, 2020 were not
restricted by COVID-19 pandemic procedures from visiting a knowledge testing center in
February 2020.
Q: What is a “calendar month”?
A: A calendar month contains all dates within that month. For example, if an airman received
their initial remote pilot certification (or established recency of knowledge) on April 18th, 2018,
they would be current through April 30, 2020 (the 24th calendar month). In this example, on
May 1, 2020, the airman would not be permitted to exercise the privileges of their remote pilot
certificate until they met the requirements of §107.65.
Q: Does my remote pilot certificate expire?
No. Remote Pilot certificates do not expire. The ability to exercise the privileges of the
certificate must be established every 24 calendar months by complying with §107.65.
Q: What happens if I’m not eligible for the SFAR relief?
A: If your recency of knowledge expired in March 2020 (or before), you may still be able to
operate under part 107, provided you can comply with §107.12(a)(2). That regulation permits a
person to operate a small UAS under part 107 without holding a remote pilot certificate as long
as they are under direct supervision of a Remote Pilot who is current per §107.65.
Q: Does this provide relief for initial certification of remote pilots under part 107 as well?
A: No. Applicants for a remote pilot certificate must comply with §107.63. The SFAR does not
offer any relief for those requirements.
Q: If I qualify for initial certification under §107.63(a)(2) and I cannot visit a FAA Flight
Standards District Office (FSDO), who can process my application?
A: Any FAA Designated Pilot Examiner (DPE), Airman Certification Representative (ACR), or
Certified Flight Instructor (CFI) may process applications under §107.63(a)(2).
May 18, 2020 (Updated November 19, 2020)
Page 11 of 20
Note: CFIs are not authorized to issue a temporary certificate and the applicant will need to wait
until the Integrated Airman Certification and Rating Application (IACRA) notifies the applicant
that their temporary airman certificate is available for printing.
Q: Do I need to create an account on www.faasafety.gov in order to take either of the online
training courses identified in the SFAR?
A: Yes. In order for credit to be given for completing the online course, the user must create an
account. There is no cost for creating an account.
Q: If I don’t have access to the internet or a computer, will I be able to take the training course
another way?
A: No. The SFAR only provides relief by completing either training course (ALC-451 or ALC-
515) online at www.faasafety.gov.
Q: May a Certified Flight Instructor (CFI) endorse my recency of knowledge to meet the
requirements of §107.65?
A: No. CFIs are not authorized to endorse recency of knowledge required by §107.65.
Q: Is the FAA extending recency of knowledge without enforcement action, like they did for
medical certificates?
A: No. To use the relief provided by the SFAR, an airman must be eligible and complete one of
the training courses identified.
Q: If I still meet the currency requirements under §61.56 and I complete the online training
course per §107.65(c), do I still get a new 24 calendar month period?
A: Yes. An airman who qualifies for recency of knowledge per §107.65(c) without using the
provisions of the SFAR will still be able to complete the online training course and establish a
new 24 calendar month period.
Q: If I qualify for §61.56 relief under the SFAR, will I still be able to establish my recency of
knowledge per §107.65(c)?
A: Yes. If you are receiving SFAR relief for the currency requirements under §61.56, you may
use that relief and establish recency of knowledge under §107.65(c) which will be valid for 24
calendar months.
Q: Can I take the online training identified in the SFAR multiple times to get additional six
calendar month extensions?
A: No. An airman operating in accordance with the SFAR will be allowed to take the training
course a single time to establish recency of knowledge. Completing the training course an
additional time, will not “reset” the six calendar month extension.
Q: Do I need to carry additional documents with me when operating under the provisions of the
SFAR?
A: An airmen operating under the SFAR must remain in compliance with §107.7 and make
available to the Administrator “Any other document, record, or report required to be kept under
May 18, 2020 (Updated November 19, 2020)
Page 12 of 20
the regulations of this chapter.” This includes documentation that shows eligibility for the SFAR
and the training course completion certificate used under the provisions of the SFAR.
Q: What subject areas are not included in the online training courses that are required under
§107.73?
A: Airspace classification, flight restrictions, and their operating requirements as well as airport
operations are not included in the online training courses. The FAA recommends that remote
pilots eligible for relief under the SFAR review those subject areas after completing the online
training.
8. Flight Crewmember Requirements (§§125.285, 125.287, 125.289, 125.291, 125.293)
Q: What relief is available?
A: The timeframe requirements for 14 CFR part 125 recency, recurrent testing, and proficiency
checking.
Q: What relief is not available?
A: The relief applies to requirements for currently qualified crewmembers only. It does not apply
to requirements for the testing and qualification of new personnel.
Q: How long does the relief last?
A: Relief is granted for recency, recurrent testing, and proficiency checking events required to be
completed between March 1, 2020 and September 30, 2020. An additional 60 days is provided
for recency requirements. For recurrent testing and proficiency checking an additional two grace
months is provided, for a total of three grace months. For proficiency checking events required to
be completed between October 1, 2020 and January 31, 2021, an additional 30 days is provided
for recency requirements. For recurrent testing and proficiency checking during that time period,
one additional grace month is provided for a total of two grace months.
Q: Who is affected by the relief?
A: Relief is available to pilots and flight attendants operating under 14 CFR part 125.
Q: How do I obtain this relief?
A: To obtain relief, the certificate holder or A125 LODA holder must submit to their Principle
Operations Inspector (POI), an acceptable safety mitigation plan. The POI will review the plan
and either accept it or inform the certificate holder or A125 LODA holder it is unacceptable.
Q: How do I comply with this relief?
A: The certificate holder and A125 LODA holder must comply with the requirements of their
safety mitigation plan.
Q: Must a certificate holder or A125 LODA holder put its safety mitigation plan in its
procedures and policies manual?
A: No. There is no requirement for a certificate holder to place its safety mitigation plan in its
procedures and policies manual. The POI can accept the safety mitigation plan in a form and
manner acceptable to the POI.
May 18, 2020 (Updated November 19, 2020)
Page 13 of 20
Q. Does the SFAR part 125 relief apply to a Special Flight Authorization (SFA) (A510, A511,
A512) LODA holder?
A: No. An operator issued a LODA SFA is authorized to operate under 14 CFR part 91.
Applicable relief under parts 91 and 61 would apply.
Q: Does the SFAR part 125 relief apply to a Parachute, Museum, Airplane Manufacturer or
Leasing Operations, Leasing-Company-Specific LODA holder?
A: No. An operator issued a LODA for Parachute, Museum, Airplane Manufacturer or Leasing
Operations, or Leasing Company Specific operations is authorized to operate under 14 CFR part
91. Applicable relief under part 91 and 61 would apply.
9. Robinson R-22/R-44 Special Training and Experience Requirements (SFAR 73)
Q: What relief is available?
A: R-22 and/or R-44 pilots whose flight review under § 61.56 and SFAR 73 is due in March
through September 30, 2020 may extend an additional three calendar months. For pilots due in
October through January 31, 2021, a flight review under § 61.56 and SFAR 73 may be extened
an additional two calendar months. This relief is contingent on pilots meeting the following
criteria:
• Pilots have greater than 200 hours in helicopters with 50 hours in a Robinson.
• Pilots must have had 10 hours PIC time in an R-22 or R-44 as applicable in the
preceding 12 months, three hours of which have been within the preceding three
months of the due date reference § 61.56
• Pilots must meet the qualifications requirements of this section since January 1, 2020
prior to a flight being conducted on the following subjects:
o SFAR 73 awareness training in 2(a)(3)(i-v)
o 14 CFR Part 91 regulations
o Robinson R-22 or R-44 Maneuvers Guide
o Complete ALC-103
o Complete ALC-104
• Pilot has established eligibility in accordance with § 61.51
Q: What relief is not available?
A: Pilots who do not have 200 hours in a helicopter with 50 hours in a Robinson are not eligible
for relief provided under this SFAR.
A pilot whose flight review was due between March 2020 through September 30, 2020, has up to
3 additional calendar months to complete it. A pilot whose flight review is due between October
2020 and January 31, 2021 has up to 2 additional calendar months to complete it.
If someone is qualified in both the R-22 and R-44, they would be required to meet this SFAR in
both models. This would require 10 hours in previous 12 months with three hours in the previous
three months prior to being due for a flight review in both models.
May 18, 2020 (Updated November 19, 2020)
Page 14 of 20
Q: How long does the relief last?
A: Anyone due for a flight review under § 61.56 in March through September 2020 may extend
their due date by three calendar months. Anyone due for a flight review in October 2020 through
January 31, 2021 may extend their due date by two calendar months. A pilot whose flight review
is due in January 2021 must complete it by March 31, 2021 to continue exercising privileges.
Q: Who is affected by the relief?
A: Pilots of an R-22 or R-44 whose flight review under § 61.56 and SFAR 73 is due between
March 2020 and January 31, 2021.
Q: How do I comply with this relief?
A: The pilot must have had a minimum of three hours of self-study since January 1, 2020, and
prior to the first flight conducted within the allotted grace period in SFAR 118-2 on the areas of:
• SFAR 73 awareness training SFAR 2(a)(3) (i-v)
• Part 91 regulations
• Maneuvers guide of whatever model relief is sought, or BOTH if relief is sought in
both models
• ALC-103 and ALC-104 of wings program (each course only estimated .5 hours)
Pilot must show eligibility and document eligibility in accordance with § 61.51(a)(1) and
(2) in order to qualify for this SFAR.
Q: Are there any other specific CFRs that I must comply with to take advantage of this relief?
A: 14 CFR Part §§ 61.56 and 61.51, and SFAR 73
Q: What are any continuing or ongoing steps for the relief?
A: The airman must comply with § 61.56 in respective models by the end of the grace period in
SFAR 118-2.
Relief from Certain Duration and Renewal Requirements
1. Medical Certificates: Requirement and Duration (§61.23)
Q: What relief is available?
A: The FAA is extending the validity of medical certificates due to expire in each of the months
from March 2020 through January 2021. For persons whose medical was due to expire in March
through September 2020, this extension is for a period up to 3 calendar months. For persons
whose medical was due to expire in October 2020 through January 2021, this extension is for a
period up to 2 calendar months with the exception of persons residing or operating in the State of
Alaska, this extension is for a period of three calendar months. Please refer to the following
table:
May 18, 2020 (Updated November 19, 2020)
Page 15 of 20
BASE MONTH
§ 61.23 SFAR RELIEF
(ALL PILOTS)
§ 61.23 SFAR RELIEF
(ALASKA PILOTS)
March through May 2020
Expired
Expired
June 2020
Expires September 30, 2020
Expires September 30, 2020
July 2020
Expires October 31, 2020
Expires October 31, 2020
August 2020
Expires November 30, 2020
Expires November 30, 2020
September 2020
Expires December 31, 2020
Expires December 31, 2020
October 2020
Expires December 31, 2020
Expires January 31, 2021
November 2020
Expires January 31, 2021
Expires February 28, 2021
December 2020
Expires February 28, 2021
Expires March 31, 2021
January 2021
Expires March 31, 2021
Expires April 30, 2021
Q: What relief is not available?
A: The SFAR does not modify the requirements of § 61.53 regarding prohibition on operations
during medical deficiency.
Q: How do I comply with this relief?
A: There are no special provisions necessary to exercise the relief
Q: What class of medical certificates does this relief apply to?
A: Relief extends to all classes of medical certificates, regardless of the operation conducted.
Q: I live in the UK but hold an FAA commercial pilot certificate and a second class medical
certificate. Does the relief for expiring medical certificates apply to pilots living outside the US?
A: The Special Federal Aviation Regulation extends relief to U.S. certificated airmen operating
outside the U.S., provided that country does not specifically prohibit such operations.
Q: Am I limited in the number of times I can exercise medical relief?
A: Yes. The SFAR extends the validity period of a medical certificate. A pilot cannot extend the
validity of a single medical certificate multiple times.
For example, a medical certificate that expired in June 2020 could be extended until September
30, 2020. No further extension under the SFAR is permitted.
It is possible, however, for an airman to exercise the SFAR relief on more than one medical
certificate. If an airman is normally required to obtain a new medical certificate every 6 months,
it is possible for that airman to exercise SFAR relief more than once. For example, if an airman
originally had a medical certificate expire in March 2020, exercised SFAR relief of a three
month extension and was subsequently issued a new medical certificate in June 2020, that
airman may exercise the validity period extension provision of the SFAR on the June 2020
medical certificate that would otherwise expire in December 2020.
May 18, 2020 (Updated November 19, 2020)
Page 16 of 20
Q: I am a pilot operating an aircraft in the U.S. on a foreign pilot certificate. Can I exercise the
COVID-19 relief granted by my country's Civil Aviation Authority?
A: The FAA is honoring all other Civil Aviation Authorities' (CAA) relief for the global
COVID-19 outbreak. You must abide by the conditions and limitations of relief set forth by your
CAA. For reference, the International Civil Aviation Organization (ICAO) has created a
webpage that includes reports of all member CAA's associated relief. That webpage can be found
here: https://www.icao.int/safety/COVID-19OPS/Pages/ccrd.aspx.
2. Prerequisites for Practical Tests (§61.39)
Q: What relief is available?
A: The ability to present a successful expired knowledge test report when applying of a
certificate or rating.
Q: How long does the relief last?
A: Three months for knowledge test results expiring between 03/01/2020 through 09/30/2020.
Two months for those knowledge test results expiring between 10/31/2020 through 01/31/2021.
This relief will not be available for knowledge test results that expire after 01/31/2021.
EXPIRATION MONTH
§ 61.39 SFAR RELIEF
March through May 2020
Expired
June 2020
Expires September 30, 2020
July 2020
Expires October 31, 2020
August 2020
Expires November 30, 2020
September 2020
Expires December 31, 2020
October 2020
Expires December 31, 2020
November 2020
Expires January 31, 2021
December 2020
Expires February 28, 2021
January 2021
Expires March 31, 2021
Q: Who is affected by the relief?
A: Any applicant for an airman certificate or rating that presents a successfully completed FAA
knowledge test that expires between 03/01/2020 and 01/31/2021.
Q: How do I comply with this relief?
A: Present knowledge test results to evaluator and reference to COVID-19 SFAR relief for §
61.39(a)(1).
Q: Does the SFAR extend the date for a letter of discontinuance or notice of disapproval?
A: The FAA considered an extension to these so that an airman could receive credit for the
documented areas of operation the airman passed. Airman privileges and the testing
requirements are necessary and time sensitive to ensure that a newly certificated pilot is qualified
to safely operate aircraft in the National Airspace System (NAS). The FAA could not justify an
extension for these testing requirements given the FAA’s responsibility to verify all pilot skills
May 18, 2020 (Updated November 19, 2020)
Page 17 of 20
and proficiency in a timely fashion, before providing an individual a pilot certificate or rating
privilege.
3. Renewal Requirements for Flight Instructor Certification (§61.197)
Q: What relief is available?
A: The new SFAR provides an extension of renewal requirements for flight instructors that hold
a flight instructor certificate that expired between March 31, 2020 and May 31, 2020.
Q: What relief is not available?
A: Relief is not being granted for flight instructor certificates that expire after May 31, 2020.
Q: How long does the relief last?
A: The relief last three calendar months for flight instructor certificates that expired on March
31, 2020. The relief last two calendar months for certificates that expired April 30, 2020. The
relief last one calendar month for certificates that expired May 31, 2020.
Q: Who is affected by the relief?
A: The holder of a flight instructor certificate that expired between March 31, 2020 and May 31,
2020 is affected by the relief.
Q: How do I comply with this relief?
A: To comply with the relief, you must satisfactorily complete one of the following renewal
requirements specified in § 61.197(a)(2)(i) through (iv) before June 30, 2020 and submit a
completed and signed application with the FAA. Upon satisfactory completion, the FAA will
send a renewed flight instructor certificate to you by mail.
Q: Are there any other specific CFRs that I must comply with to take advantage of this relief?
A: - No, you do not need to comply with any other CFRs to take advantage of this relief.
4. Relief for U.S. Military and Civilian Personnel Who are Assigned Outside the United
States in Support of U.S. Armed Forces Operations (SFAR 100‑2)
Q: What relief is available?
A: Relief for U.S. Military and Civilian Personnel Who are Assigned Outside the United
States in Support of U.S. Armed Forces Operations Notwithstanding the 6 calendar month period
specified in paragraph 2 of SFAR No. 100-2 of this chapter, a person may exercise the relief
specified in paragraph 1 of SFAR No. 100-2 of this chapter for a duration of 9 calendar months
after returning to the United States, provided the person—
(1) Is eligible in accordance with paragraph 2 of SFAR No. 100-2 of this chapter;
(2) Complies with the documentation requirements specified in paragraph 3 of SFAR No.
100-2 of this chapter; and
(3) Returned to the United States from deployment between October 2019 and March 2020.
May 18, 2020 (Updated November 19, 2020)
Page 18 of 20
Q: What relief is not available?
A: No other relief is being granted for compliance with SFAR 100-2. Any return to the United
States after March 2020 does not fall under this SFAR provision. It remains 6 months.
Q: How long does the relief last?
A: The applicant has 9 calendar months from date of return between October 2019 and March
2020. Example: The last date to renew is December 31, 2020 if they returned in March 2020.
Q: Who is affected by the relief?
A: U.S. Military and Civilian Personnel Who are Assigned Outside the United States in Support
of U.S. Armed Forces Operations
Q: How do I comply with this relief?
A: Upon return to the United States, review the SFAR 100-2 and comply with the requirements
for renewal set forth in the regulation. Contact the FSDO or appropriate designee for an
appointment. Complete an FAA Form 8710-1. Provide the required documents as stated in
paragraph 3 of SFAR 100-2 to show orders returning to the United States that show compliance
within relief timeframe.
Q: Are there any other specific CFRs that I must comply with to take advantage of this relief?
A: Review Parts 61, 63, or 65 as applicable, and comply with the renewal requirements.
5. Requirements for a Pilot School Certificate (§141.5) and Renewal of Certificates and
Ratings (§141.27)
Q: Why has this relief not been updated?
A: During the initial months of the COVID-19 public health emergency, many schools may not
have been able to meet the renewal requirements due to a sudden halt in flying activity and the
issuance of stay-at-home orders. Since that time, part 141 pilot schools and provisional pilot
schools have been able to provide instruction during the recovery period of the COVID-19 public
health emergency, and are expected to meet the renewal requirements of part 141.
Q: What relief is being granted?
A: Title 14 CFR Part 141.5 and 141.27 requires a provisional pilot school to apply to become a
pilot school within 24 months of their initial certification or their air agency certificate will lapse.
Pilot schools also need to renew their air agency certificates every 24 months.
Due to the stay at home provisions of the COVID 19 response many provisional schools may be
unable to get the required activity (10 separate students graduating from applicable courses with
an 80% first time pass rate). The same issue affect pilot schools who may be unable to obtain the
required quality of training.
The relief granted is merely an extension of the 24-month timeframe, which will allow a school
that expires in April through June of 2020 to be given through December 31, 2020 to complete
application. There is no other relief available by this provision of the SFAR.
May 18, 2020 (Updated November 19, 2020)
Page 19 of 20
Q: What relief is not being granted?
A: There is no change to the quality and quantity of training required for renewal. A provisional
pilot school will still be required to present evidence that they have graduated 10 different people
from the school’s approved courses and those graduates did so with an 80% first time pass rate.
A pilot school will still be required to present evidence they have met the quality of training as
required by §141.5 (d).
Q: Is any additional relief being granted for the renewal of part 141 pilot schools or provisional
pilot school?
A: No. The relief is only for those schools that expired from April 2020 through June 2020.
Q: How long does the relief last?
A: This extension is only applicable to schools that may expire between April through June of
2020. The end date of this extension is December 31, 2020.
Q: Who is affected by the relief?
A: The relief is directly applicable to the certificate holder. However, without the relief some
provisional pilot schools and pilot schools may not be able to renew which would greatly affect
all personnel associated with the school.
Q: How do I obtain this relief (specific steps involved and/or personnel directed to)?
A: Each part 141 provisional pilot school must notify its responsible Flight Standards office that
it is applying for a pilot school certificate in accordance with this SFAR. Each part 141 pilot
school must notify its responsible Flight Standards office that it will renew its pilot school
certificate in accordance with this SFAR.
The part 141 provisional pilot school must submit an acceptable plan that explains the method to
meet the requirements of §141.5(d) and (e), which includes ensuring each instructor used for
ground or flight training is current and proficient and evaluating students to determine if they are
assigned to the proper stage of the training course and if additional training is necessary.
Each part 141 pilot school must submit an acceptable plan that explains the method to regain
currency that includes ensuring each instructor used for ground or flight training is current and
proficient and evaluating students to determine if they are assigned to the proper stage of the
training course and if additional training is necessary.
Q: How do I comply with this relief?
A: Each part 141 provisional pilot school and pilot school should review the status of the
school’s Air Agency Certificate and determine if the school will need the relief as contained in
the SFAR. The steps include identifying the certificate’s status and what will be lacking at the
time of the school’s renewal. Each part 141 provisional pilot school or pilot school should
determine what the school will need for each instructor assigned to a course to regain currency.
Q: Are there any other specific CFRs that I must comply with to take advantage of this relief?
A: Each part 141 provisional pilot school and pilot school should review the school’s Training
Course Outlines (TCOs) and syllabi to ensure they comply with the course requirements. Each
May 18, 2020 (Updated November 19, 2020)
Page 20 of 20
part 141 provisional pilot school or pilot school should review §141.79 to ensure the chief
instructor for each course is current. Each instructor in a part 141 provisional pilot school or pilot
schools should review §141.79 to ensure each instructor is current for the course they are
assigned to instruct. The chief instructor for each course should review each student’s training
folder to determine what steps the student will need to regain currency and what will be needed
to complete the course for which they are enrolled in.
Q: What are any continuing or ongoing steps for the relief?
A: Each part 141 provisional pilot school or pilot school must review the status of the school’s
certificate and determine when the Air Agency Certificate will expire. This will require a part
141 pilot school to look at the date of the school’s previous renewal in order to determine when
the school’s current certificate will expire. The part 141 provisional pilot school should review
the date of the school’s certification and determine when the provisional pilot status expires. Part
141 provisional pilot schools are reminded that as soon as they meet §141.5, specifically, §141.5
(d) and (e), the school may apply for a pilot school certificate.
***End of Frequently Asked Questions***
