How To Spell FAR/AIM
Allow myself to introduce…myself…My name is Chris, and I’m an alco…oops, wrong intro! I’m not a TPN staff writer, just a longtime fan; I am a retired military pilot, a major airline pilot, a chief pilot at a Part 141 flight school, and an FAA designated pilot examiner. I have a few hobbies too: I run an aircraft MX shop, I am a General Contractor, and am starting a MX school for military aircraft maintainers. Who knew that 24 years of 12-14-hour days would become addictive? I am the product of a public high school in a third-world country in a foreign language, so my grammar and spelling are terrible. The opinions that follow are mine alone. In the capacity of free-lance writer, I do not represent anyone other than myself. I’ll try to be PC, but if I hurt your feelings, I’m sorry you have a weak constitution. Lastly: rules change frequently, so any article that I write has a limited shelf-life. Always consult with professional service providers or the FAA before spending any money! If TPN accepts any more of my articles after this one…this is the first of several (still TBD how many) articles that apply to all (US-citizen) pilots. If you are a foreign exchange pilot currently in the US, there are other rules for you. I don’t plan to write about those rules, so send me an email if you have questions. I’ll focus on things we (US military pilots) probably should have been taught at pilot training: it is never too late to learn. I am living proof that anyone can learn to spell FAR/AIM (in English)!
I’d like to start with a brief description of the FAA, FARs, and other FAA governing documents. Then, I’ll talk about FARs that cover training (with a focus on military competency and ATP ratings), and wrap it up with a summary of what I am trying to convey.
Let me be nerdy for a minute…The US government is governed by Coded Federal Regulations (CFR) that are broken down by title, chapter, sub-chapter, and parts. The FAA falls under Title 14 of the CFRs (Aeronautics and Space), Chapter 1 (Federal Aviation Administration and Department of Transportation), sub-chapters A-N, parts 1-199. When referencing an FAA rule (for example training) typically folks just say, “part 61,” or write “§§61.” What that really means is, 14CFR Chapter 1, subchapter D (Airmen), part 61. For example, PART 61 -CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS (§§ 61.1 – 61.429. Cornell Law has a great website to help interpret what the legal language actually means. Internally, the FAA uses the Flight Standards Information System (FSIMS) to tell its employees how to do their job. FSIM 8900.1 covers most of the topics I will discuss. FSIMS.FAA.gov has more information than you’ll ever care to read. But, if you wanted to know the process to get a military competency commercial and instrument certificate, you could search FAA FSIMS Military competency. Eventually in your search, you would find the Airmen Certification Standards (ACS) for Military Competency (FAA-S-ACS-12). My point with bringing up all of these FAA rules is only to show you that it is complicated, and multiple layers deep! Assuming that (as a military pilot) you understand the FAA’s rules are crazy. Yet, as a military competency examiner, I routinely hear, “common sense would dictate that…”. Wrong! The good news is that FAA Aviation Safety Inspectors (ASIs), and (most) Designated Pilot Examiners that are Military Competency Examiners (DPE-MCE) are available for telephone consultations and questions…for free! You can search the FAA website for an FAA Flight Standards District Office (FSDO) ASI at https://www.faa.gov/about/office_org/field_offices/fsdo/, or a DPE-MCE near you https://www.faa.gov/other_visit/aviation_industry/designees_delegations/individual_designees/dpe/. Please remember that most DPEs have other jobs, so don’t wait until the last second to ask questions. Also, ASIs are FAA employees and have around 180 additional duties. There is an ASI in the “office” Mon-Fri, but they are very busy and will probably refer you to a DPE-MCE. DPE-MCEs charge a small fee to process your paperwork.
Lastly on this topic, one of the FAA’s functions is to certificate pilots. They are the experts on FAR/AIM…they are here to help! They are not the bad guys we were taught about during pilot training.
So, you’ve reached a point in your career where you’ve decided to get all of the FAA ratings you can based on military competency…what now? Sheppard Air (http://www.sheppardair.com/mcs.htm) has a good guide to follow. The most often misunderstood concepts deal with ratings themselves and what they mean. That leads to the most common question I hear: what do I actually qualify for under mil-comp? The simple answer is: it depends on what you have flown in the military (to include pilot training). If you never flew a single-engine airplane, you
cannot have a single-engine rating at any level. If you were never a multi-engine instructor, you cannot hold an MEI. If you have been a multi engine IP, you can have an MEI, and not be able to teach in a single-engine airplane. So, I’d like to take a minute to peel back the layers on FAA ratings because they are misunderstood by most military-only pilots.
Each pilot certificate comes with inherent limitations and privileges, but may contain additional limitations and privileges. For example, you could earn a sport pilot certificate that says, Limitations: not authorized to carry passenger; not authorized to fly an airplane with rudders; not authorized to fly into towered airports, etc…You can also have additional endorsement for a pilot certificate in your logbook. For example: High Performance, Complex,Tail-wheel, and Pressurized Airplane operations are all endorsements that go in your logbook. Once you have a pilot rating in a class and category, you can add other classes and categories relatively easily. For example, if you have a mil-comp MEI with instrument airplane, you can add-on an airplane single-engine land IP certificate (referred to as aCFI) reasonably easily as long as you have a commercial ASEL. For those of you old folks that flew the Tweet, and never flew a single engine airplane in the military, the path isn’t so easy! More to follow in another article (I’ll call:The Add-on Ratings). The following certificates are issued under Part 61 through the FAA’s Integrated Airmen Certification and/or Rating Certification (IACRA) system (also see Aircraft Ratings and Pilot Certifications):
- Student Pilot: (Non-military pilots start here, with very few exceptions)
- Sport Pilot
- Recreational Pilot Private pilot (in the grand scheme of ratings, think of this as a high school diploma)
- Commercial Pilot (This is like a 2-year degree, and if this is your first FAA rating as a military pilot, it is the level at which you will get a competency rating).
- Airline Transport Pilot the (PhD of flying)
Notice that “Instrument” isn’t a certificate. It is an additional rating. Instrument Airplane (or Rotorcraft,etc…) is implied with ATP since you can’t have one without the other. You can hold an instrument airplane rating on the private or commercial certificate also. Pilot certificates are also broken down by aerospace vehicle (category, class by type (if required)), and by additional ratings. Examples of “category” include Airplane, Rotorcraft, Glider, Powered Lift, and Lighter than Air. Class includes Airplane, Single Engine Land; Airplane, Multi Engine Sea, Rotorcraft Helicopter, etc… Examples of ratings you can have include:
Private Pilot, Airplane, Multi-Engine Land; Instrument Airplane;
Airline Transport Pilot, Airplane Multi Engine Land BE-300, MU-400 (T-1A type rating);
Commercial Pilot, Airplane Multi and Single-Engine Land, Rotorcraft Helicopter; Private Pilot Privileges Glider, Instrument Airplane and Helicopter.
Confused yet? The answer to the original question, “what am I eligible for” lies in these questions: what did you fly at pilot training? What have you been rated in while in the military since pilot training? You are eligible for Commercial Pilot privileges, and Instrument Privileges in whatever you flew (with some exceptions) as long as you have proof of a checkride. FAR 61.73 address military competency.
Earning the Airline Transport Pilot rating is a different ball of wax…specifically, the Multi Engine ATP. I won’t go into the full background of why the requirements to earn this rating changes @ 5 years ago, but there is currently no waiver for military competency for the Certification Training Program (CTP). The
CTP is the pre-req for the written test for the Multi Engine ATP. The CTP in no way prepares you for the written test (see Sheppard Air above). The written test opts you for the practical test. There is a waiver for military pilots when it comes to the practical, but it only waives the 1,500-hour requirement to 750 hours, and authorizes you to earn an ATP-Restricted. The ATP-R is also authorized for Part 141 Flight School graduates with either a 2- or 4-year degree (but the hour requirement varies.
Speaking of Part 141 (and 61 from above) …these are the 2 FAR’s that cover GA flying training. You can also train under Part 121, 125, 135, and 142 (and I will cover those in yet another article titled: Training). For now, I hope it suffices to say that anybody with an instructor rating and an airplane can train you under Part 61 WITHOUT ANY SUPERVISION FROM THE FAA!…until something goes wrong, and the FAA steps in. There are lots of Part 61 flight schools. Part 141 flight schools, on the other hand, are certificated by the FAA to teach flying at the university level. Part 141 flight schools voluntarily allow the FAA to heavily supervise and monitor their activity.There is a lot involved with Part 141 schools that I will not talk about except to say it is a huge expense to earn and maintain the certificate (if anybody really wants to know, email me). Most airlines add points to your application if you check the box that says, “I attended a Part 141 Flight School.” Don’t check the box if you didn’t…they’ll check. A flight school must be approved by the FAA under Part 141 (or 142 for simulators) to offer training that is paid for using the GI Bill, or COOL, or to offer work under Skill Bridge (I’ll cover that in another paper that I’ll call: Non-Traditional Funding for Pilot Certificates).
Last topic, I promise: Part 91 is the set of rules that governs “how” we fly in GA (i.e. weather requirements, cloud clearances, required equipment, etc…). For example, under Part 91 rules, there is no weather minimum required to take off. That’s right. And, if you’re VFR in Class G airspace, you don’t even need a radio or transponder…or attitude indicator. So, the least qualified pilots have the least restriction and no oversight.
But Chris, why do I care about this stuff? I am going to retire/separate, and go on to be an airline pilot…Competency as a professional pilot has many forms. One constant: it is your job to continue studying, even after you get your “forever” job. My first instrument approach at my airline was an old-school VOR-A…into Mexico City (very mountainous) …at night…around thunderstorms…and, there was a rock in my shoe. OK, the last line wasn’t true, but you get my point. I have done charters at my airline with a major sports team in the back of the jet at night, under VFR (the team went into overtime during playoffs, and the tower closed). Knowing how to operate in the national airspace system is required, but no one is going to spoon feed it to you.
To wrap this up: There are lots of rules and regs that you never cared about before…you may still not care about them, but at least now you know about them. When in doubt: ask!