RussR
En-Route
In several places in the regulations, there is reference to things being "approved by the administrator" or "authorized by" or that sort of language. And, in typical government/bureaucratic use, it really means "or designated representative" even if it's not explicitly stated. This is normal, of course, because otherwise the Administrator would be busy just signing things.
But in at least one place it reads a little differently. For example, 61.31g, which discusses high-altitude endorsements, says that one is not required if the pilot passed "a pilot-in-command proficiency check under part 121, 125, or 135 of this chapter conducted by the Administrator or by an approved pilot check airman."
This is an example of something where the Administrator is not just "approving" or "authorizing" a paperwork exercise. Rather, it says that he or she can actually conduct the PIC proficiency check.
There may be other examples like this, but I couldn't find any right away.
So, has this ever happened? Do you know someone who did their part 121, 125 or 135 proficiency check with the actual sitting FAA Administrator? Does the Administrator need to be otherwise authorized to perform the check (ratings and so on)? Does he or she need to be a CFI? Or even need to be type rated in the airplane?
Compare this to the paragraphs for the complex and high-performance endorsements, which say that if the pilot has passed a 135.293 competency check in such an aircraft, that meets the requirement - but it doesn't say anything about the Administrator conducting it.
I get it, it's an edge case that I'm sure isn't ever likely to actually happen. But it's written into the rules that way, as compared to many other similar scenarios that aren't written that way. So it's fun (for me anyway) to imagine how this scenario would actually happen.
But in at least one place it reads a little differently. For example, 61.31g, which discusses high-altitude endorsements, says that one is not required if the pilot passed "a pilot-in-command proficiency check under part 121, 125, or 135 of this chapter conducted by the Administrator or by an approved pilot check airman."
This is an example of something where the Administrator is not just "approving" or "authorizing" a paperwork exercise. Rather, it says that he or she can actually conduct the PIC proficiency check.
There may be other examples like this, but I couldn't find any right away.
So, has this ever happened? Do you know someone who did their part 121, 125 or 135 proficiency check with the actual sitting FAA Administrator? Does the Administrator need to be otherwise authorized to perform the check (ratings and so on)? Does he or she need to be a CFI? Or even need to be type rated in the airplane?
Compare this to the paragraphs for the complex and high-performance endorsements, which say that if the pilot has passed a 135.293 competency check in such an aircraft, that meets the requirement - but it doesn't say anything about the Administrator conducting it.
I get it, it's an edge case that I'm sure isn't ever likely to actually happen. But it's written into the rules that way, as compared to many other similar scenarios that aren't written that way. So it's fun (for me anyway) to imagine how this scenario would actually happen.