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61.31 flying airplane category without rating

Asked by: 1116 views FAA Regulations, Private Pilot

Part 61.31 states you must hold a category, class, and type rating (if required) to act as PIC of an aircraft carrying another person. My question is: does this mean you could fly a multiengine airplane if you are not carrying another person, with just a SEL rating? Could you fly a seaplane without another person onboard with only a SEL rating?

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2 Answers



  1. Bryan on Dec 20, 2022

    The purpose of 61.31 is to prohibit pilots from taking on the external pressures of passengers/cargo/hire without having appropriate ratings to be PIC. 61.31 is not intended to indicate through absent text when you can act as PIC.

    The answer to your question is on your pilot certificate. It lists your level of privileges (private, commercial, ATP, sport, etc.) and then the category and class(es). That means you have pilot privileges in those categories and classes only.

    For any other type of aircraft, you essentially have only student privileges so you could fly AMEL or a helicopter as long as you are with an instructor or have been endorsed by an authorized instructor to act as PIC in an aircraft for which you are not rated under 61.31(d)(2).

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  2. Mark Kolber on Dec 20, 2022

    Watch out for only reading one part of a long regulation and missing other parts, like the very next paragraph:

    (d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must –

    (1) Hold the appropriate category, class, and type rating (if a class or type rating is required) for the aircraft to be flown; or

    (2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.

    Notice that (d)(2) allows a pilot to act as PIC without the appropriate rating if they are being trained for that certificate or rating and receive a solo endorsement. But even then, the part you quoted from (c) says, they can’t carry other persons or fly as PIC for compensation.

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