Take flight lessons although medical was denied

I didn't think you could just add on through 141 unless you had acquired previous ratings through 141. The reason for 141 was to build upon previous foundation.
 
I didn't think you could just add on through 141 unless you had acquired previous ratings through 141. The reason for 141 was to build upon previous foundation.
Your thinking is incorrect. In any event, it is possible to do a Part 141 additional airplane category rating course at the CP level with 55 hours of dual and no solo time -- see Part 141 Appendix I paragraph 4(a)(3).
 
So, in theory, you *could* get a commercial airplane certificate 0 PIC in category. I'm wondering if they really wrote it the way they meant it.
 
So, in theory, you *could* get a commercial airplane certificate 0 PIC in category. I'm wondering if they really wrote it the way they meant it.

Now that I think about it, there is an easier way to get all of the aeronautical experience you need with a denied medical certificate:

(1) Get a glider or balloon sport pilot certificate (or recreational, private, and/or commercial, if you prefer--doesn't matter). No medical is required for the check ride.

(2) Via § 61.321, get ASEL light sport privileges via a proficiency check and two instructor logbook endorsements. No solo time requirement applies. Just make sure that the instructor is acting as PIC for the proficiency check, and there is nothing that I can see in § 61.23 that would require a medical.

(3) Fly a bunch in ASEL with your instructor (with the instructor acting as PIC). Log all the time you want as PIC, PIC cross country, PIC night, supervised "solo" (for the commercial rating), real/simulated instrument, etc. This way, you can get all of the aeronautical experience you need for the ASEL commercial, instrument airplane, and ASEL ATP. If you like, throw in the 50 hours of AMEL you would need to do the AMEL ATP under the new rules.

(4) Get the commercial in glider and/or balloons. Take the instrument, commercial, and ATP written exams for airplanes.

(5) Once you've accumulated your 1500 hours for the ATP, get your third class medical. In one busy weekend, take the ASEL (or AMEL will also work) commercial, instrument airplane, and ASEL and AMEL ATP practical tests.

No need to deal with Part 141, just the ability of sport pilots to log PIC without acting as PIC.

This might even be practical for someone who really wants a professional flying career, has access to cheap flight time and CFI time (or non-CFI simply acting as PIC time, e.g., a family member willing to do it for free), and is confident they will ultimately be able to get the required medical.
 
So, in theory, you *could* get a commercial airplane certificate 0 PIC in category. I'm wondering if they really wrote it the way they meant it.

I think there are a few parts of Part 141 Appendix I that make things possible that the authors of the regs probably didn't think through. For example, I think you can get a full ATP airplane with just a bit over 1200 total time by getting the ATP helicopter first and then taking a Part 141 ATP airplane add-on course. Of course, getting the ATP helicopter is so hard and expensive that this really isn't a practical "loophole" for people who don't already have a pile of helicopter time for other reasons.

Some of the Part 141 add-on hour requirements are just laughably short. You can get a commercial glider add-on, having only spent 3.2 hours in a glider in your entire life, none of them solo. You can add a commercial hot-air balloon add-on (which gives you privileges to instruct), having only spent 7 hours (in as few as two total flights) in a balloon, none of them solo. You may well be able to meet the PTS in that short a time if you are really sharp and did your homework, but can you possibly be seasoned enough to be carrying paying customers?
 
(3) Fly a bunch in ASEL with your instructor (with the instructor acting as PIC). Log all the time you want as PIC, PIC cross country, PIC night, supervised "solo" (for the commercial rating), real/simulated instrument, etc. This way, you can get all of the aeronautical experience you need for the ASEL commercial, instrument airplane, and ASEL ATP. If you like, throw in the 50 hours of AMEL you would need to do the AMEL ATP under the new rules.

While you are at it, build a bunch of complex, multi, or even turbine time. As long as it doesn't require a type rating, you can even log it all PIC. (I think you could even get an SIC type rating under § 61.55(d), since no practical test is required, and possibly even log PIC time in a turbojet using that SIC type rating--though the FAA may think that is pushing it, and would probably refuse to actually issue you a sport pilot certificate with a B747 SIC type rating, regardless of how much multi and/or turbine time you'd logged.) Knock out your complex, high performance, tailwheel, high altitude, and night vision google endorsements. Get ready to knock out your Category II and Category III approach authorization practical tests on that same busy check ride weekend. Throw in a PIC type rating or two as part of your ATP practical tests.

The point is, I think there is a way to log any type of aeronautical experience you could need in an airplane for a rating above the private certificate or for an endorsement, with a denied medical. You just can't take the actual practical tests or use the privileges.
 
Now that I think about it, there is an easier way to get all of the aeronautical experience you need with a denied medical certificate:

(1) Get a glider or balloon sport pilot certificate (or recreational, private, and/or commercial, if you prefer--doesn't matter). No medical is required for the check ride.

(2) Via § 61.321, get ASEL light sport privileges via a proficiency check and two instructor logbook endorsements. No solo time requirement applies. Just make sure that the instructor is acting as PIC for the proficiency check, and there is nothing that I can see in § 61.23 that would require a medical.

(3) Fly a bunch in ASEL with your instructor (with the instructor acting as PIC). Log all the time you want as PIC, PIC cross country, PIC night, supervised "solo" (for the commercial rating), real/simulated instrument, etc. This way, you can get all of the aeronautical experience you need for the ASEL commercial, instrument airplane, and ASEL ATP. If you like, throw in the 50 hours of AMEL you would need to do the AMEL ATP under the new rules.

(4) Get the commercial in glider and/or balloons. Take the instrument, commercial, and ATP written exams for airplanes.

(5) Once you've accumulated your 1500 hours for the ATP, get your third class medical. In one busy weekend, take the ASEL (or AMEL will also work) commercial, instrument airplane, and ASEL and AMEL ATP practical tests.

No need to deal with Part 141, just the ability of sport pilots to log PIC without acting as PIC.

This might even be practical for someone who really wants a professional flying career, has access to cheap flight time and CFI time (or non-CFI simply acting as PIC time, e.g., a family member willing to do it for free), and is confident they will ultimately be able to get the required medical.



Why?:confused: Why would anyone do this if they can't get a medical? What would be the point?
 
So, in theory, you *could* get a commercial airplane certificate 0 PIC in category.
Yes, provided you do it in a 141 school with examining authority. Otherwise, you'll only get to the practical test that way, not through it, since per 61.47 you will be PIC on the practical test.

I'm wondering if they really wrote it the way they meant it.
:dunno:
 
(5) Once you've accumulated your 1500 hours for the ATP, get your third class medical.
How will you get your Third Class medical if you've been denied? Or are we assuming you've fixed whatever problem there is, in which case you could have done that up front. In any event, outside of a Part 141 school with self-examination authority, per 61.39, you're going to need a third class or better to take the CP and ATP practical tests since you'll be PIC with a passenger, and there are no complex LSA's in which to take the CP practical test and CP is a prerequisite for ATP.
In one busy weekend, take the ASEL (or AMEL will also work) commercial, instrument airplane, and ASEL and AMEL ATP practical tests.
Gonna be a very long weekend -- I'm figuring at least five practical tests here.
 
Last edited:
While you are at it, build a bunch of complex, multi, or even turbine time. As long as it doesn't require a type rating, you can even log it all PIC.
Not possible since you aren't "rated" in anything complex/multi/turbine because there are no complex/multi/turbine LSA's.

(I think you could even get an SIC type rating under § 61.55(d), since no practical test is required,
But acting as SIC of that type-rated aircraft is, and that requires a medical.
and possibly even log PIC time in a turbojet using that SIC type rating
That's a question the Chief Counsel has not yet been asked, but if they were, I think they'd say "rated" for logging PIC time means PIC-rated, not SIC-rated.

--though the FAA may think that is pushing it, and would probably refuse to actually issue you a sport pilot certificate with a B747 SIC type rating, regardless of how much multi and/or turbine time you'd logged.)
There's no provision for that in the regulations since you're not rated in category/class. See 61.55(a)(1).
Sec. 61.55

Second-in-command qualifications.

(a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command pilot flight crewmember only if that person holds:
(1) At least a private pilot certificate with the appropriate category and class rating; and
61.55(f) allows you to act as SIC during training without having the paragraph (b) familiarization requirements done, but not without PP or better and appropriate category/class ratings.
 
How will you get your Third Class medical if you've been denied? Or are we assuming you've fixed whatever problem there is, in which case you could have done that up front. In any event, outside of a Part 141 school with self-examination authority, per 61.39, you're going to need a third class or better to take the CP and ATP practical tests since you'll be PIC with a passenger, and there are no complex LSA's in which to take the CP practical test and CP is a prerequisite for ATP.
Gonna be a very long weekend -- I'm figuring at least five practical tests here.

Well, one example would be someone who has a waiting period to go through, after heart attack, or discontinuing SSRI treatment, or trying for the SI to fly on SSRIs. Such a person could work toward their commercial and CFI, for example, while waiting for the medical waiting period to run.

Actually doing the CP or ATP (or recreational or private, for that matter) practical tests will require a third class under 61.23(a)(3)(vi), whether or not the test could be done in a light sport.
 
Not possible since you aren't "rated" in anything complex/multi/turbine because there are no complex/multi/turbine LSA's.

I went slightly overboard here. You clearly can't log multi PIC, because you have no rating in the AMEL class. Anything requiring a type rating clearly isn't going to work, either. (But, I'm not aware of any rating that requires logged PIC time in a multi or in a type-requiring aircraft, so that isn't really a big deal.)

But, I think you could log PIC in something like a PC-12 (which is both complex and turbine), because it is in the ASEL category and class, and you have "sport pilot privileges for that category and class of aircraft" (61.51(e)(1)(i)).

But acting as SIC of that type-rated aircraft is, and that requires a medical.

No question there. This hypothetical airman with a denied medical can't act as PIC or SIC of anything other than a glider or balloon. The goal is just to be able to log time for the purposes of obtaining a certificate should the medical problem get sorted out.

I think you can get an SIC type rating without ever legally acting as SIC, if you are doing it in something like a Citation Mustang which has both single-pilot and crew type ratings, and the pilot providing the training has the single-pilot type rating. Like I said, though, the FAA will never give you a piece of plastic with a sport pilot certificate (only) and an SIC type rating.

That's a question the Chief Counsel has not yet been asked, but if they were, I think they'd say "rated" for logging PIC time means PIC-rated, not SIC-rated.

Yeah, who knows. The logic of the PIC logging rules is a little strained. A brand new sport pilot can log PIC for a flight he takes with an instructor in a P-51 (complex, multi, tailwheel, and clearly beyond the abilities of a fresh sport pilot, but the sport pilot has sport pilot privileges in the category and class), but a highly experienced B777-typed captain can't log time he is sole manipulator in a B767 (assuming no B767 type rating). Where's the logic in that?

There's no provision for that in the regulations since you're not rated in category/class. See 61.55(a)(1).

Yes, the B747 example was a bad one. A better one would be a single-engine aircraft requiring a type rating and for which an SIC type rating exists. But I'm not sure that any such beast exists. (Are there any single-engine airplanes that require a type rating, other than single-engine turbojets? Do any of the single-engine jets require more than one crew?) But, since as I understand things a sport pilot doesn't have category or class ratings (i.e., things listed on the pilot certificate), only category and class privileges (reflected by endorsements in the log book), that probably doesn't really help.

Anyway, the FAA is never going to give you the piece of plastic with an SIC type rating on a sport pilot certificate (since you could never actually use any of the privileges of the type rating), it's a little moot.

61.55(f) allows you to act as SIC during training without having the paragraph (b) familiarization requirements done, but not without PP or better and appropriate category/class ratings.

I think the bigger issue is the need for a medical certificate to act as a required crew member, so you'd need to do this in an aircraft that had both single-pilot and crew type ratings.

I know some of what I suggest above is impractical and absurd, but in its less extreme form--building PIC time for an instrument rating or commercial rating--this could actually be helpful for someone stuck waiting things out to get their medical certification problems fixed.
 
Why?:confused: Why would anyone do this if they can't get a medical? What would be the point?

There are many medical certification issues that are temporary, and can be fixed by the passage of time or through treatment (e.g. surgery). Alan Shepard and Deke Slayton would both be examples of guys who were medically grounded for years but later able to fly again (though I don't know if they had civilian medical certificates at the time or if they were ever denied them).

Now, if you are on medical thin ice to begin with, I probably wouldn't invest a whole lot in an airline career, as the risk of getting medically grounded down the road is probably pretty high. There are much easier and more secure paths to make a living. But going for the commercial rating, either for personal flying or to work as a part-time CFI, or the like, doesn't seem too crazy to me.
 
I went slightly overboard here. You clearly can't log multi PIC, because you have no rating in the AMEL class. Anything requiring a type rating clearly isn't going to work, either. (But, I'm not aware of any rating that requires logged PIC time in a multi or in a type-requiring aircraft, so that isn't really a big deal.)
For an additional class rating, that is true, although you won't be able to take the practical test for that rating without a medical.
But, I think you could log PIC in something like a PC-12 (which is both complex and turbine), because it is in the ASEL category and class, and you have "sport pilot privileges for that category and class of aircraft" (61.51(e)(1)(i)).
No, you don't. Those Sport Pilot privileges apply only to LSA's. For something not licensed as an LSA, you must hold the rating, not just Sport Pilot privileges. The wording is " or has sport pilot privileges for that category and class of aircraft," and a Sport Pilot has no privileges outside an LSA.

I think you can get an SIC type rating without ever legally acting as SIC, if you are doing it in something like a Citation Mustang which has both single-pilot and crew type ratings, and the pilot providing the training has the single-pilot type rating. Like I said, though, the FAA will never give you a piece of plastic with a sport pilot certificate (only) and an SIC type rating.
That's an interesting idea.

Yeah, who knows. The logic of the PIC logging rules is a little strained. A brand new sport pilot can log PIC for a flight he takes with an instructor in a P-51 (complex, multi, tailwheel, and clearly beyond the abilities of a fresh sport pilot, but the sport pilot has sport pilot privileges in the category and class),
As I said above, a Sport Pilot has no privileges outside an LSA, and thus cannot log PIC time in that P-51 unless s/he has been signed for solo in it IAW 61.87 and is the sole occupant of the aircraft -- and that requires a medical certificate. See 61.23(c)(1)(ii).

but a highly experienced B777-typed captain can't log time he is sole manipulator in a B767 (assuming no B767 type rating). Where's the logic in that?
It is what it is.
 
Last edited:
No, you don't. Those Sport Pilot privileges apply only to LSA's. For something not licensed as an LSA, you must hold the rating, not just Sport Pilot privileges. The wording is " or has sport pilot privileges for that category and class of aircraft," and a Sport Pilot has no privileges outside an LSA.

Hmmm, that would be an issue (though I think you could still get all the PIC time you'd need for any rating in an LSA, assuming the LSA was legal to fly at night). But are you sure that the the sport pilot needs privileges for the airplane in question in order to be able to log PIC? The literal wording of the rule just requires privileges in the applicable category and class, not in the specific airplane. Does the sport pilot get to log PIC in an LSA with VH less than 87 knots CAS before they get the endorsement required under § 61.327?

It seems to me that a sport pilot flying a non-LSA (let's say a Cessna 152, to use a more reasonable example than a PC-12) is just like a private pilot without a high-performance endorsement flying a Cessna 182. They have a rating in category and class (and LSAs are not a separate category or class for the purposes of pilot certification), so they can log PIC but not act as PIC.

Are you aware of any guidance from the FAA suggesting otherwise?
 
Hmmm, that would be an issue (though I think you could still get all the PIC time you'd need for any rating in an LSA, assuming the LSA was legal to fly at night). But are you sure that the the sport pilot needs privileges for the airplane in question in order to be able to log PIC?
Yes.

The literal wording of the rule just requires privileges in the applicable category and class, not in the specific airplane.
As I pointed out, the regulations say that Sport Pilots have privileges only in LSA's.

Does the sport pilot get to log PIC in an LSA with VH less than 87 knots CAS before they get the endorsement required under § 61.327?
That's a requirement for an endorsement, not for a rating, and the Chief Counsel has specifically stated that a requirement for a rating is not a requirement for an endorsement.

It seems to me that a sport pilot flying a non-LSA (let's say a Cessna 152, to use a more reasonable example than a PC-12) is just like a private pilot without a high-performance endorsement flying a Cessna 182. They have a rating in category and class (and LSAs are not a separate category or class for the purposes of pilot certification), so they can log PIC but not act as PIC.
Except that the Chief Counsel has specifically said numerous times over about the last 25 years that a requirement for an endorsement is not a requirement for a rating/privileges. However, the regulations clearly state that Sport Pilot privileges are limited to LSA's.
 
The only practical reason I can think of for taking flying lessons after you have been denied a medical certificate would be to develop the skills so you can fly a plane with another certified pilot on board acting as PIC.

I know a man that lost his medical and had his wife get her pilot certificate. He flew for years with her in the plane.........
 
The only practical reason I can think of for taking flying lessons after you have been denied a medical certificate would be to develop the skills so you can fly a plane with another certified pilot on board acting as PIC.

I know a man that lost his medical and had his wife get her pilot certificate. He flew for years with her in the plane.........

Yeah, I can see learning to fly, no worries, plenty of opportunity to use the knowledge and ability. It's the Commercial and ATP stuff that seems like a huge waste of money.
 
Back
Top