Legal Interpretations
Nolan 2013
Summary
The Question
May an instructor give a high-performance endorsement under 14 CFR 61.31(f) in a multiengine airplane to a pilot who does not hold a multiengine rating?
Background
A requester asked whether an authorized instructor may issue a high-performance endorsement using a multiengine airplane with engines of more than 200 horsepower to an airman without a multiengine rating on his certificate.
The FAA’s Interpretation
Yes. 14 CFR 61.31(f) contains no requirement that a pilot hold a multiengine or other rating before obtaining the high-performance endorsement, so the endorsement may come first. However, the pilot may not use it to act as pilot in command of a multiengine airplane until obtaining a multiengine rating.
- Requester
- Nolan
- Issued
- March 13, 2013
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
MAR 13 2013
Mr. Michael D. Nolan
Dear Mr. Nolan:
Office of the Chief Counsel
Office of the Chief Counsel
800 Independence Ave., SW.
Washington, DC 20591
This is in response to your letter requesting a legal interpretation of whether an authorized instructor may issue a high performance endorsement to an airman using a multi-engine aircraft with engines of more than 200 horsepower, if that airman does not hold a multi-engine rating on his airman certificate.
The provisions of 14 C.F.R. § 61.31(f) for the training required for a high-performance endorsement make no mention of any requirement that a pilot must hold a rating (such as a multi-engine rating) on his airman certificate before obtaining the high-performance endorsement. The relevant portion of§ 61.3 l(f)(l) reads as follows:
"No person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless that person bas (i) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane, and bas been found proficient in the operation and systems of the airplane; and (ii) ... Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane" In the absence of language requiring a pilot to have a multi-engine rating prior to obtaining a high-performance endorsement, it means that a pilot may obtain a high-performance endorsement prior to obtaining a multi-engine rating on the pilot's airman certificate. Of course, that pilot may not use that high-perfoIIDance endorsement to fly as pilot-incommand of a multi-engine airplane until such time as the pilot obtains a multi-engine rating on his or her pilo't certificate.
Page 2
We hope this response is helpful to you. If you have additional questions on this matter, or ~eed additional information, please contact my staff at (202) 267-3073. This response was prepared by Neal O'Hara, an attorney in the International Law, Legislation and Regulations Pivision of'the Office of the Chief Counsel, and was coordinated with the General Aviation and Commercial Division of the Flight Standards Service.
ar W. Bury Acting Assistant Chief sel for International Law, Legislation and Regulations, AGC-2 0
Regulations Referenced
Snapshot retrieved August 6, 2026.