FAA SFAR Offers Extensive Regulatory Relief


The FAA has published a Special Federal Aviation Regulation (SFAR) designed to provide regulatory relief for individuals unable to meet some training, experience, testing and checking requirements due to the coronavirus (COVID-19) pandemic. The SFAR includes provisions for expiring flight instructor and medical certificates, recent flight experience requirements, flight reviews, knowledge tests and inspection authorizations. The special regulation will go into effect immediately following its publication in the Federal Register.

“Since March 2020 and with each month thereafter, a new group of pilots becomes unavailable to perform critical operations because they cannot comply with certain training, recent experience, testing, or checking requirements,” the FAA said. “This SFAR will provide temporary relief to certain individuals whose qualifications would otherwise lapse, to ensure there are a sufficient number of qualified personnel available to conduct essential aviation activities during this period.”

The SFAR (PDF) extends the validity of medical certificates that expire from March 31, 2020, through May 31, 2020, until June 30, 2020. The agency emphasized that the prohibition on operations during medical deficiency remain unchanged. Similarly, the validity of flight instructor certificates expiring between March 31, 2020, and May 31, 2020, will be extended until June 30. Flight instructor certificates renewed during the grace period will retain their original expiration month. FAA knowledge tests expiring between March and June have also been granted an additional three calendar months.

Under the SFAR, pilots with biennial flight reviews due March through June 2020 can extend the 24-calendar-month requirement by three calendar months provided they have “logged at least 10 hours of PIC time within the twelve calendar months preceding the month the flight review was due” and completed FAA Safety Team online courses totaling at least three WINGS credits. A grace period for instrument currency has been established until June 30 as long as the pilot has “logged at least three instrument approaches in actual weather conditions, or under simulated conditions using a view-limiting device” within the six calendar months preceding a flight. The SFAR also provides a three-month extension for mechanics with inspection authorization to complete renewal requirements originally due by March 31, 2020.

Kate O'Connor
Kate O’Connor works as AVweb's Editor-in-Chief. She is a private pilot, certificated aircraft dispatcher, and graduate of Embry-Riddle Aeronautical University.

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  1. One item of the SFAR needs to be considered, and that is Section 2 that limits the availability of training, recency, testing and checking requirements (read, the Flight Review and Instrument Procedures Currency extensions) to only certain operations. They are: (a) those operations requiring at least a commercial certificate (e.g., Parts 135 and 121 operations); (b) charitable medical flights (e.g., PALS and Angel Flight); (c) agricultural operations; or (d) for pilots with at least 500 hours total time, 400 hours as PIC and at least 50 hours within the 12 months preceding the flight, (i) flights incident to business or employment, (ii) a glight in support of family medical needs or to transport essential goods for personal use, (iii) a flight necessary to fly an aircraft to a location in order to meet a requirement of the FARs, or (iv) a flight to transport essential goods and medical supplies to support public health needs. It is not a cart blanche to extend Flight Reviews or IPCs for the stated periods.

  2. There is a difference in wording regarding the applicable dates for expiring CFI certificates and expiring knowledge tests. For CFI’s the applicable dates are for those “… expiring between March 31, 2020 and May 31, 2020, the FAA is extending the validity of these flight instructor certificates until June 30, 2020.” However, regarding knowldge tests the wording is ” … knowledge tests expiring between March 2020 and June 2020. … the FAA is extending the validity of knowledge tests by a duration of three calendar months.”

    The SFAR makes clear that if a CFI waits until after June 30, 2020 to renew, that the CFI will have to go through a reinstatement. (“After June 30, 2020, a flight instructor who holds an expired flight instructor certificate must reinstate that certificate in accordance with §61.199.”)

    However, there is no clarification regarding knowledge tests. Does it mean that a knowledge test expiring at the end of June 2020 (taken June 06, 2018) is extended for three calendar months to September 30, 2020?

    The confusion is this: does “between March 2020 and June 2020” mean “between March 1, 2020 and June 30, 2020 inclusive”? The subheadline on Dan Namowitz article in aopa.org says ” The FAA issued a special federal aviation regulation (SFAR) that provides blanket extensions of medical certificates and airman knowledge tests that would have expired between March 1 and May 31 to all pilots regardless of the type of their flying.”

    However, an online chat with AOPA Customer Service this morning indicated that the SFAR does in fact apply to knowledge tests expiring in June 2020.

    Since they all expire at the end of a month, the FAA could have written specifically “knowledge tests expiring on March 31, April 30, May 31, and June 20 are extended for an additional 3 calendar months” and there would not be any ambiguity.

  3. My BFR expires 5/31/20. So the way I read this article I can extend out 3 months, or till 8/31/20. Is that the way others are reading this?