61.87 solo

MikeD

Administrator
Staff member
A person just about to solo in ASEL. She is a current ATP Rotorcraft-helo, but with no Airplane Category on any certificate. Regarding 14 CFR 61.87(p), the solo endorsement shouldn’t have a 90 day expiration, because technically she is not a student pilot. It would have no expiration, correct? I seem to remember back in the early 90s when getting my CFI initially the idea that “one is only a student pilot once in their career”.
 
But for a different category? Do they still have student pilot certificates? I think they had a number of categories on them.


I believe you only have a student pilot certificate once in your life. Hence they don’t have a student pilot certificate anymore, and never will. They are considered an ATP, with a solo endorsement for another category. I believe the logbook endorsement has no expiration date due to this, but I’m trying to confirm it.
 
Well, besides whatever the technically FAA correct answer is, is there any problem to CYA and evaluate this person for ASEL solo priveleges, and just give a new endorsement to be covered?
 
I always put a 90 limit on mine. You can add what ever you want to the endorsement that is more restrictive than the FAA min.
 
I always put a 90 limit on mine. You can add what ever you want to the endorsement that is more restrictive than the FAA min.

@MikeD - I kinda feel like our quoted colleague above. However, this is interesting, and I always enjoy a merry chase through the regs.

I've spent a bit of time scouring the FARs and can't really find a definition where you're "not a student" even if you're not category rated with an ATP. But I did notice something in AC61-65H that helps, I think:

To act as pilot in command of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: § 61.31(d)(2). I certify that [First name, MI, Last name] has received the training as required by § 61.31(d)(2) to serve as a pilot in command in a [specific category and class] of aircraft. I have determined that [he or she] is prepared to solo that [make and model] aircraft. Limitations: [optional].

Since the FAA (specifically, my local FSDO) regularly encourages us to use their publications and this is their publication and this language (which is appropriate to your question) does not specify a time limitation when other STUDENT endorsements DO specify it, I think you have latitude on a time endorsement.

From a practical perspective - and this is my opinion only - if I'm the instructor here, I want to put a time limit on the endorsement, if only to maintain accountability until the endorsement is not needed. If something were to happen, Buddha forbid, the FAA wants to talk to the endorsing instructor, in my experience. My experience, is however, limited.

More experienced CFIs and/or FAA wizards are welcome and encouraged to correct me if I'm wrong.
 
I believe you’re right being 61.31 where that was seen and that you have found, endorsement-wise. Good ole AC 61-65!

Yes, this is where that specific endorsement comes into play. Because the pilot in question is not a student pilot, no specific time limit comes into play nor is required. Once a pilot gets any certificate beyond student, they are considered at that certificate level for life, barring suspension/revocation. And hence, they are never a formal student pilot ever again, even though they may be learning in a new category. In the case here, the ATP is seeking the add-on of an ASEL Category/class at a Commercial level, so the solo endorsement is towards that end.
 
I believe you’re right being 61.31 where that was seen and that you have found, endorsement-wise. Good ole AC 61-65!

Yes, this is where that specific endorsement comes into play. Because the pilot in question is not a student pilot, no specific time limit comes into play nor is required. Once a pilot gets any certificate beyond student, they are considered at that certificate level for life, barring suspension/revocation. And hence, they are never a formal student pilot ever again, even though they may be learning in a new category. In the case here, the ATP is seeking the add-on of an ASEL Category/class at a Commercial level, so the solo endorsement is towards that end.

Mike, see my transition article on the main page. It explains most everything.
 
Mike, see my transition article on the main page. It explains most everything.
This one?

 
That’s the one. And due to that, the solo endorsement given has no expiration requirement. No 90 days, due to not being a student pilot. It’s an interesting nuance.

This pilot is going to get a Commercial ASEL, add an airplane-instrument, then later take an ATP checkride for that.

Had a DPE a long time ago who only had helo ratings, but got a solo endorsement for a 172 about 25 years ago, no expiration. Technically, could hop in solo and fly today on that endorsement.
 
61.31(d)(2) endorsement is what's needed for someone to act as PIC in an additional category/class without holding the appropriate rating. Additionally they need to be in compliance with 61.56 as well. For example the holder of a private pilot certificate, rated in ASEL cat/class, hasn't flown in 10 years. They want to add Glider category to their certificate, so their CFI would need to ensure that they have 61.31(d)(2), the appropriate 61.31(j) endorsement, as well as meeting one of the requirements of 61.56. In such a scenario the easiest way to comply with 61.56 is a Wings Phase.
 
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