Type Rating Limitation Question

bafanguy

Well-Known Member
Got a license/type rating question. I’ll try to give the Reader’s Digest version of the ramp up to the question.

Many years ago, pre-1500-hour rule but post-Part 121-SIC-type rating required, a guy gets a DHC-8 rating on his CPL with this limitation: “DHC-8 SIC PRIVILEGES ONLY”.

He later moves on and down the road gets a full ATPL, to which the DHC-8 rating is transferred, with a few other type ratings but the DHC-8 rating still carries the above limitation.

So the question: Is there a way to have that SIC limitation removed via FAA paperwork or is a full sim rating ride required ?

I’ve seen FAR Part 61.64(g) which mentions something perhaps related to my question but I’m not sure it’s exactly the same situation.

I tried to find an FAA interpretation on this but couldn’t.

Any official, documented wisdom on this ?

[yes, I tried the forum search function]
 
Last edited:

MikeFavinger

Hubschrauber Flieger
Got a license/type rating question. I’ll try to give the Reader’s Digest version of the ramp up to the question.

Many years ago, pre-1500-hour rule but post-Part 121-SIC-type rating required, a guy gets a DHC-8 rating on his CPL with this limitation: “DHC-8 SIC PRIVILEGES ONLY”.

He later moves on and down the road gets a full ATPL, to which the DHC-8 rating is transferred, with a few other type ratings but the DHC-8 rating still carries the above limitation.

So the question: Is there a way to have that SIC limitation removed via FAA paperwork or is a full sim rating ride required ?

I’ve seen FAR Part 61.64(g) which mentions something perhaps related to my question but I’m not sure it’s exactly the same situation.

I tried to find an FAA interpretation on this but couldn’t.

Any official, documented wisdom on this ?

[yes, I tried the forum search function]
I don't know the answer, but to jump on - I have a "CL-65 is subject to pilot in command limitations" limitation on my ATP. It was supposed to be removed with 25 hours (or something close) in the aircraft. The paperwork never happened and the ADP for my new company/type wouldn't touch it. I really wouldn't care except that limitation forces a second FAA certificate to carry around because it won't fit on the first.

Or how about this - why do I need "B-737, CL-65 CIRC APCH VMC only" right below "ATP CIRC APCH VMC only"? It's just wasting space!
 

deadstick

Well-Known Member
Essentially you either have to be trained under an approved upgrade program or complete a full initial. I went down that rabbit hole a few years back trying to remove it from my BE-1900 type. If you think about it, you can get an SIC type after some systems training and 3 circuits (ref 61.55).
 

MidlifeFlyer

Well-Known Member
Essentially you either have to be trained under an approved upgrade program or complete a full initial. I went down that rabbit hole a few years back trying to remove it from my BE-1900 type. If you think about it, you can get an SIC type after some systems training and 3 circuits (ref 61.55).
I don't have a link to an official answer so I don't have one, but this one makes sense. The SIC type rating is so limited I wouldn't expect it to grow into a full PIC rating all by itself.

For removal under 61.64(g), you might take a look at section 5-324 in FSIMS. https://fsims.faa.gov/wdocs/8900.1/v05 airman cert/chapter 02/05_002_005rev1.htm to see if you think anything applies.

Other than that, you might contact the airman certification branch at Flight Standards (not you local FSDO) with your question. They've been surprisingly responsive despite CV-19.
 

bafanguy

Well-Known Member
Thanks for the info, Folks. Appreciate it. I was steered to this link. See Paragraph C. Seems pretty clear...or as clear as FARs can be to us jailhouse lawyers:

C. Removal of the Type Rating Limited to SIC Privileges. Removal occurs when the applicant accomplishes the appropriate type rating practical test for PIC privileges. Any other removal must follow due process rules in accordance with FAA Order 2150.3, FAA Compliance and Enforcement Program.

 

CFI A&P

Exploring the world one toilet at a time.
I don't know the answer, but to jump on - I have a "CL-65 is subject to pilot in command limitations" limitation on my ATP. It was supposed to be removed with 25 hours (or something close) in the aircraft. The paperwork never happened and the ADP for my new company/type wouldn't touch it. I really wouldn't care except that limitation forces a second FAA certificate to carry around because it won't fit on the first.

Or how about this - why do I need "B-737, CL-65 CIRC APCH VMC only" right below "ATP CIRC APCH VMC only"? It's just wasting space!
You have a couple things going on here. For the PIC command limitations, was that because you did not meet the requirements of 14 CFR 61.64(e) ? If you now have the requirements, you can document the 25 hours of required supervised operating experience and have the FSDO remove it. There is this advisory circular referencing this process and using the Eclipse Jet type rating as an example. It is fairly easy, if your FSDO inspector knows what to do. Just have the supervising PIC sign your logbook, or create a document that shows the supervising PIC, >25 hours and present it for removal.


The second issue of "CIRC APCH VMC only" is because the operator in which you were training for did not have a circling approach at minimums in your curriculum and it wasn't demonstrated during the checkride(s). Pretty common when the certificate holder wants you to have higher minimums for circling, say 1000-3, which is really VMC conditions and not a circling approach below VMC minimums. As far as I know, you'd have to demonstrate a circling approach at minimums to have the "CIRC APCH VMC only" removed.
 
Top