U.S. Department 

of Transportation 

Federal Aviation 

Administration 

JAN 9 201j 

Daniel Beard 

371 Crestview St. NE 

Palm Bay, FL 32907 

Office of the Chief Counsel 800 Independence Ave., S.W. 

Washington, D.C. 20591 

Re: Section 61.3l(d) solo endorsement requirements for additional category and/or class 

ratings 

Dear Mr. Beard: 

This letter responds to your request for legal interpretation dated July 27, 2014. You have 

asked several questions regarding solo endorsements required to act as pilot in command of 

an aircraft for which a pilot does not hold the appropriate category and/or class ratings. 

Specifically, you have asked whether the solo endorsement requirements for student pilots in 

14 C.F.R. part 61, subpart C also apply to pilots who hold higher certificates and are seeking 

an additional rating. The answer is no. Section 61.81 states that subpart C "prescribes the 

requirements for the issuance of student pilot certificates, the conditions under which those 

certificates are necessary, and the general operating rules and limitations for the holders of 

those certificates." As such, by its express language, subpart C to part 61 applies only to 

those persons who are seeking or hold a student pilot certificate. 

Section 61.63 contains the requirements for pilots who hold a higher level pilot certificate 

and are seeking an additional category and/or class rating. For example, a pilot who applies 

to add a category rating to a pilot certificate must, among other things, complete the required 

training and aeronautical experience required for that rating. 14 C.F.R. § 61.63(b)(l). 

Generally, to meet the aeronautical experience requirements for a new category of aircraft, a 

pilot must accomplish solo flight time. Because the pilot does not hold the ratings necessary 

to act as pilot in command, a pilot must receive an endorsement for solo flight from an 

authorized instructor under 14 C.F.R. § 61.3 l(d). To receive that endorsement, a pilot must 

have received the training required under part 61 "appropriate to the pilot certification level, 

aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to 

be flown." 14 C.F.R. § 61.3l(d)(2). Unlike solo endorsements for student pilots,§ 61.3l(d) 

does not contain any time limitation for the endorsement. 

Finally, you have also asked whether a person operating in solo flight under a§ 61.3 l(d) 

endorsement must comply with the flight review requirements in§ 61.56(c). With a few 

listed exceptions, no person make act as pilot in command of an aircraft unless within the 

previous 24 calendar months that person completed a flight review with an authorized 
2 

instructor. 14 C.F.R. § 61.56(c). Section 61.56(g) provides an exception for student pilots 

provided the student pilot is undergoing training for a certificate and has a current solo flight 

endorsement as required under §61.87. Because this exception applies to student pilots, a 

pilot who holds a higher level pilot certificate and has an endorsement for solo flight under 

§ 61.31 ( d) must comply with the flight review requirements in § 61.56 before acting as pilot 

in command of any aircraft. 

This response was prepared by Anne Moore, an attorney in the International Law, 

Legislation, and Regulations Division of the Office of the Chief Counsel and coordinated 

with the General Aviation and Commercial Division of the Flight Standards Service. If you 

have any additional questions regarding this matter, please contact my office at (202) 267-

3073. 

Sinc~rely, ' / ' 

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" i i L/ / ;f l«fFl/ ,/· .. ··~·l.; /~,/ 

'·Mark W. my 

i 

Assistant Chief Counsel for. Yntemational Law, 

Legislation, and Regulation~