Legal Interpretations
Grayson-1 2010
Summary
The Question
Are the additional training and endorsement requirements of 14 CFR 61.31(e) through (j) ratings limitations that 14 CFR 61.31(l)(2) excuses student pilots and checkride applicants from?
Background
A requester asked whether student pilots and practical test applicants, to whom the ratings limitations of 14 CFR 61.31 do not apply under paragraph (l)(2), formerly (k)(2), must still obtain the additional training and endorsements required by 14 CFR 61.31(e) through (j).
The FAA’s Interpretation
No. Under the plain language of the regulation, the ratings limitations of 14 CFR 61.31 are in paragraphs (c) and (d), not (e) through (j). Because a pilot must be properly rated and authorized to conduct the flight to act as PIC, student pilots and checkride candidates must complete the additional training and hold the endorsements before acting as PIC of the aircraft designated in 14 CFR 61.31(e) through (j).
- Requester
- Grayson
- Issued
- January 4, 2010
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
Jt.M - 4 2010
Taylor Grayson
Dear Mr. Grayson:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington. D.C. 20591
This letter responds to the request for a legal interpretation that you mailed to this office on August 25, 2009. You have requested clarification regarding the additional training requirements set forth in 14 CFR § 61.31 (e) through 0). In particular, you have asked whether those requirements are considered "ratings limitations" under paragraph (1)(2), formerly paragraph (k)(2), of§ 61.31.
Section 61.31 (e) through G) prohibits a pilot from acting as pilot in command of certain aircraft without first receiving additional flight training and obtaining an endorsement. Section 61.31 (1)(2) directs that the "ratings limitations" of the section do not apply to certain pilots, including student pilots and applicants for practical tests given by an examiner. You have asked whether student pilots and checkride candidates are thus required to obtain the additional training and endorsements for the aircraft designated in § 61.31 (e) through G) before they may act as pilot in command of those aircraft cir whether paragraph (1) renders those training requirements inapplicable to them.
Under the plain language of the regulation, the additional training requirements specified in § 61.3 l(e) through G) are not ratings limitations. The ratings limitations in§ 61.31 are contained in paragraphs (c) and (d) of that section. As such, because a pilot must be properly rated in the aircraft and properly rated and authorized to conduct the flight in order to act as pilot in command, student pilots and checkride candidates are required to comply with the additional training requirements and hold the appropriate endorsements prior to acting as pilot in command of the aircraft designated in§ 61.31(e) through (j). This response was prepared by Anne Moore, an Attorney in the Regulations Division of the Office of the Chief Counsel and coordinated with the Certification and General Aviation Operations Branch of Flight Standards Service. We hope this response has been helpful to you. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.
Sincerely, ')fJ---'
~~ersonAssistant Chief Counsel Regulations Division, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.