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5 Answers

FAA revoked Student Pilot licence due to DUI. Where do I stand as regards the training I have completed to that point?

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FAA Regulations, Student Pilot

Had been training for PPL and I lost my Medical (Student Pilot Licence) during a relocation move so I went to get a new one. FAA have revoked my licence as apparently I failed to disclose to them that I had a DUI on my new medical and also because I failed to report it to them within 60 days of conviction. I had seen the requirement to report a conviction to the FAA within 60 days but it requires a pilot to do that. Because I hadn't completed my training not been qualified as a pilot I therefore cant be considered a pilot and for that reason I didn't report it within the 60 days. FAA seem to disagree with me in that thinking and seem to consider me a pilot even thought I aint qualified as one. I personally don't consider a medical student a doctor until he or she has completed med school training and been qualified as one and likewise don't consider a law student a lawyer until law school has been completed and he or she been qualified as a lawyer.

Anyway the revoke was for a 1 year period which has passed and I now question where it leaves me as regards the training I have already completed? Do my flight hours completed still count or do I have to start from scratch? How does it impact on me?

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5 Answers



  1. Kris Kortokrax on Dec 24, 2014

    First, you stated that you held a combination Student Pilot / Medical certificate. 61.15(e) states: “Each person holding a certificate issued under this part shall provide a written report of each motor vehicle action to the FAA”. It says nothing about a pilot making the report.

    However, if you conducted any solo flights, you were the Pilot-in-Command and in that capacity, you were indeed a pilot.

    To answer your main question, any flight time you have received would still count, although you might be a bit rusty. Since the revocation does not allow you to exercise the privileges of your certificate, you could still have received dual instruction to keep sharp. You just could not have flown solo and you could not apply for any certificate or rating for a 1 year period.

    If you took the knowledge test and it is still valid, you should not need to retake it.

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  2. MPDB on Dec 24, 2014

    Thanks Kris for your detailed answer. What you have quoted under 61.15 was something I hadn’t seen. What I had seen was as follows;
    “Under 14 CFR 61.15, all pilots must send a Notification Letter (MS Word) to FAA’s Security and Investigations Division within 60 calendar days of the effective date of an alcohol-related conviction or administrative action. In 14 CFR 61.15(c), alcohol-related convictions or administrative actions refer to motor vehicle actions (MVA)”
    which I found at the link attached http://www.faa.gov/about/office_org/headquarters_offices/ash/ash_programs/investigations/airmen_duidwi/
    It was because that specifically called out for pilots requirement to report that I felt because I hadn’t completed training nor been qualified I wasn’t a pilot.

    To answer the Solo flight reference I hadn’t actually completed any solo flights. My training pilot felt I was ready to go solo but I never got to do a solo flight as my relocation happened before I could get the chance to fulfil solo flight.

    I’m glad that I don’t lose the hours completed. Never thought of the revoke as limiting me to not allow exercise privileges of only the certificate and never thought of receiving instruction. While the revoke was in place I never did any flight training as regards ground or actual flight training or knowledge exams or flight exams of any kind. I didn’t want to complicate things further than they already had been so I fully complied with doing nothing as regards flight training. Like you suggest I could have done some things but didn’t realise that until now and anyway the revoke timeframe period has now lapsed so I would hope the slate is now clean again. Medical will be the first step and because of the said complication it may have to go to review board to decide on its outcome.

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  3. Mark Kolber on Dec 25, 2014

    I think your insistence about not having completed training. and are therefore not a pilot, misses the point. You had a student pilot certificate. That is a “certificate issued under this part.” and it is definitely a “pilot certificate.” One who holds a student pilot certificate is definitely a “pilot” under the rules. That you only have a student pilot certificate only means that you are a pilot who has only met the requirements for that level of pilot certificate.

    On the reapplication, I urge you to get some advance knowledgeable assistance on the preparation and collection of needed and desirable paperwork. One source of such assistance is AOPA’s Pilot Protection Services.

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  4. MPDB on Dec 25, 2014

    Thanks Mark. My understanding was different but I now see things how they’ve been pointed out to me since I asked this question here. Guess there are differences here in Europe. Students are nothing more than students here and aren’t considered in the professional capacity that they are training for until they have been qualified for that role which is why I was thinking the way I was. I cant say if that applies to the aviation profession here as I really don’t know but every other profession works that way over here.

    I really appreciate the advice I’ve been given on here. Very valid points have been made and my understanding of the situation has changed.

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  5. Mark Kolber on Dec 25, 2014

    I don’t think that’s true with respect to “every other profession” either. Law students who practice law on a limited basis under state student practice rules can be disciplined by licensing boards or even denied licensing at a later date. Same for med students practicing under supervision and I suspect for “every other profession” which allows students some limited form of practice or apprenticeship, even before they have any type of formal license.

    Motor vehicle operators on learners permits are subject to traffic laws and can be fined and have their licenses suspended for infractions.

    I’d be very surprised if the European experience were really substantially different.

    In any event, the bottom line is, when engaged in a regulated activity, one should expect to re regulated and that there will be penalties for violations.

    And of course, my recommendation for obtaining knowledgeable advice (personal, not on an online forum) is with the errors in understanding of system and process depicted (and others maybe even unstated but implicit) in your original post.

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