Legal Interpretations
Patch-Glass Cockpit Aviation 2015
Summary
The Question
Must the 5 hours of solo flight training required by 14 CFR 61.313(d)(1) for sport pilot gyroplane privileges be completed in a gyroplane?
Background
Glass Cockpit Aviation noted that 14 CFR 61.313(d)(1) specifies that the 15 hours of flight training from an instructor be in a gyroplane but does not say the same for the 5 hours of solo flight training.
The FAA’s Interpretation
Yes. Flight training references are generally not limited to a category and class unless the rule says so, but for the sport pilot certificate, the introductory language of 14 CFR 61.311 qualifies required training by the category and class of privileges sought. Read together with 14 CFR 61.313, the solo training must be in the category and class sought, here a gyroplane.
- Requester
- Patch
- Organization
- Glass Cockpit Aviation
- Issued
- April 1, 2015
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
APR -1 2015
Camille Patch
Owner, Glass Cockpit Aviation
11550 NW Touch n Go Avenue
Boise, ID 83716
Dear Ms. Patch:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This letter responds to your request for a legal interpretation of 14 C.F .R. § 61.313 dated September 15, 2014. You asked whether the 5 hours of solo flight training required by§ 61.313(d)(l) must be completed in a gyroplane.
Section 61.313(d)(l) requires "20 hours of flight time, including 15 hours of flight training from an authorized instructor in a gyroplane and at least 5 hours of solo flight training in the areas of operation listed in§ 61.311" (and additional specific aeronautical experience requirements in paragraphs (d)(I )(i) through (iv) that are not relevant to your question) to apply for a sport pilot certificate with rotorcraft category and gyroplane class privileges. You correctly state the regulation specifies that the 15 hours of flight training must be completed in a gyroplane, but there is no similar specificity for the 5 hours of solo flight training. The definition of "flight training" in § 61. l(b) does not include a reference to any particular category and class of aircraft. Generally, any reference to flight training in a regulation, unless specifically qualified, therefore does not include a limitation that the time be obtained in any particular category and class of aircraft. See Legal Interpretation to Larry J. O'Mara (Jul. 5, 2012). However, in the context of the sport pilot certificate, flight proficiency requirements are applicable to the category or class of aircraft for which privileges are sought. The introductory language to§ 61.311 specifically qualifies the required ground and flight training by each type of privileges sought (i.e., by category and class of aircraft). When §§ 61.313 and 61.311 are read together, the 5 hours of solo flight training must be performed in the category and class of aircraft for which privileges are sought. Accordingly, in response to your question, the solo flight training must be completed in a gyroplane. This response was coordinated with the General Aviation and Commercial Division 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.
Regulations Referenced
Snapshot retrieved August 6, 2026.