AOPA points out COVID-19 regulatory impediments for GA, but there’s MORE

AOPA letter and specific areas citedAOPA letter and specific areas cited
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AOPA points out COVID-19 regulatory impediments for GA, but there’s MORE

GA Association itemizes FARs which are impacted by Virus pandemic

Immediate Exemptions proposed,return to normalcy not mentioned

Request for GA, but Parts 121, 125,129,135, 145, 183, etc. need similar relief

The FARs were written for normal times and 2020 is not normal. COVID-19 hit the United States in multiple dimensions in unexpected and highly deleterious ways, aviation concluded. AOPA President Mark Baker has written a letter to FAA Administrator Dickson[1] asking his organization to consider regulatory relief for the general aviation sector. The press release includes a number of specific rules which are difficult or impossible under the social distancing health guidelines.

COVID-19 and THE handshake

COVID-19 and THE handshake






The points are well made and the immediate blockage obvious. There will come a time when the virus will have diminished impact and the FARs safety requirements should kick back in. These tests are needed to return to the reduce risks of operating under the rules cited. That is a difficult question; because after X months (hopefully), when normalcy is reestablished, there will be a large backlog of pilots needing testing, for example. How to meter the processing of those requests?

AOPA has raised an important point for its GA members. Consider the recurrent requirements applied to airlines, airports, repair stations, DERs/DARs/etc.? The tasks of identifying all of these COVID-19 impediments and then of defining the solutions are massive and demand immediate high level focus.

Baker urges FAA to lift ‘impossible’ compliance barriers

With life on hold during the coronavirus pandemic, the clock continues to tick toward the dates when pilots’ practical test and knowledge test eligibility ends, currency or instrument proficiency runs out, and flight instructor certificates expire.

In response to the concerns of many members who face obstacles for remaining in compliance, AOPA is urging the FAA to exert a “maximum amount of flexibility” to help keep pilots and aircraft up and running during the crisis.

In a March 17 letter to FAA Administrator Steve Dickson, AOPA President Mark Baker described the impact on general aviation pilots and urged a flexible approach that allows extensions and relief from regulatory time restrictions for the duration of the crisis.

Mark Baker AOPA

Many pilots confront seemingly intractable dilemmas in the face of closures, curtailment of travel, and the recommendations of health officials to practice social distancing. “For example, federal requirements require pilots to renew their medical certificate in person, to complete their pilot certification examinations within a certain amount of time, and to complete knowledge tests at off-site testing facilities,” he wrote. “The current restrictions to the U.S. population create an impossible barrier for these individuals to meet the necessary airman and aircraft requirements.”

AOPA is receiving numerous member inquiries about how to deal with currency requirements during the pandemic. Our government affairs team is working with the FAA to create solutions, said Christopher Cooper, AOPA director of regulatory affairs.

  • One challenging situation confronts instructors whose certificates expire every 24 months and must be renewed by one of several methods within the 90 days before the expiration date (doing so afterward requires starting over with a practical test). Many CFIs renew via online flight instructor refresher courses—but others attend in-person FIRCs, many of which have now been canceled because of the coronavirus. “Without an extension or relief, some individuals’ instructor certificates will expire in the next month or two,” Cooper said.






  • Some existing problems will be exacerbated during the coronavirus crisis: Dealing with limited availability of designated pilot examiners to conduct practical tests has been a work in progress for two years and now faces new obstacles. The FAA is considering waiving some DPE management policies, but some DPEs have canceled appointments with practical test applicants because of the outbreak. “As a result, applicants may run into the issue of not being able to complete their practical within the required time limits,” Cooper said.

FAA designated pilot examiner





  • A related concern for applicants is that airman knowledge tests are valid as a practical test prerequisite for two years from the date they are taken. But if a knowledge test were to expire with testing facilities still closed, applicants would have no way to retake their knowledge tests, leaving them ineligible for the practical test indefinitely without some kind of FAA relief.

aircraft knowledge test


  • Reduced access to aircraft and CFIs could affect pilots’ livelihoods and the ability to exercise their privileges by triggering a wave of expirations of instrument proficiency checks, flight reviews, and recency-of-experience intervals unless the FAA can make exceptions, Cooper added.

instrument proficiency test







  • Medical certificate expiration dates are also looming. AOPA’s medical certification team is monitoring the situation and working with the FAA on contingencies, he said.

faa medical certificate





  • Aircraft maintenance and continuing airworthiness requirements must also be addressed.

aircraft maintenance

The European Union Aviation Safety Agency is addressing the needs of the aviation community in EASA-member countries under the exemption notification provisions of its rules, which permit grant extensions of validity periods of “ratings, certificates, and attestations” for up to eight months.

Dan Namowitz

Associate Editor Web

Associate Editor Web Dan Namowitz has been writing for AOPA in a variety of capacities since 1991. He has been a flight instructor since 1990 and is a 30-year AOPA member.




GA has brought a significant problem to the FAA. How the agency deals with this issue and the broader impact of COVID-19 to all aviation will be closely followed here.


[1] To show how pervasive COVID-19 is, he is self-quarantined due to a handshake

GA comes to FAA

The FAA’s Wilbur Wright Building in Washington, D.C.







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1 Comment on "AOPA points out COVID-19 regulatory impediments for GA, but there’s MORE"

  1. FAA grants airlines extension on meeting slot utilization requirements–

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