Question About § 61.101 Recreational pilot privileges and limitations – Do Endorsements need to be Repeated ?

Can anyone here on Askacfi help clarify FAA Regulations in Section 61.101 outlining the Recreational Pilot Endorsements and Limitations.

I am confused.

I am trying to better understand whether three particular Recreational Pilot Endorsements need to be earned only once to become permanently valid, or whether they need to be repeatedly earned again and again at each new departure airport used by a Recreational Pilot Licensee.

• The endorsement and enabling privilege to fly into Class B, C, & D airspace.
• The endorsement and enabling privilege to fly into control tower airports.
• The endorsement and enabling privilege to fly >50 nm from the departure airport.

It is my impression that these three endorsements for privileges are general in nature.  They do not need to be repeated every time a pilot moves. Is this a reasonable interpretation?

Also, please note that the FAA has stated that a Recreational Pilot with a valid Class III Medical Certificate may exercise the full privileges of a Sport Pilot. The Sport Pilot License endorsements and privileges of flight into Class B, C, & D, and flight into control tower airports for example, need only to be earned once and do not need to be repeated.

( I )  Overview - Reference: § 61.101 Recreational pilot privileges and limitations.

#1

FLIGHT INTO CLASS B, C, D AIRSPACE

I believe the one time only rule applies

#2

CONTROLLED TOWER AIRPORT

I believe the one time only rule applies

The regulations state:

(d) A person who holds a recreational pilot certificate may act as pilot in command of an aircraft in Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower, provided that person has -

(1) Received and logged ground and flight training from an authorized instructor on the following aeronautical knowledge areas and areas of operation, as appropriate to the aircraft rating held:

(i) The use of radios, communications, navigation system and facilities, and radar services.

(ii) Operations at airports with an operating control tower to include three takeoffs and landings to a full stop, with each landing involving a flight in the traffic pattern at an airport with an operating control tower.

(iii) Applicable flight rules of part 91 of this chapter for operations in Class B, C, and D airspace and air traffic control clearances;

(2) Been found proficient in those aeronautical knowledge areas and areas of operation specified in paragraph (d)(1) of this section; and

(3) Received from an authorized instructor a logbook endorsement, which is carried on the person's possession or readily accessible in the aircraft, that certifies the person has received and been found proficient in those aeronautical knowledge areas and areas of operation specified in paragraph (d)(1) of this section.

The preceding privileges are described in general terms and are not airport specific. Moreover, the elements described in (d) (1), (2), and (3) which enable the endorsement are also general in nature. They provide privileges which are outlined in the FAR as general in nature as well. They do not mention endorsement retesting, or at which specific airport or regional airspace, if any, the endorsements apply.

For example, I interpret the endorsement enabling the Recreational Pilot the privilege to fly into an airport with a controlled tower as one that does not need to be repeated again and again every time the recreational pilot moves and uses a new departure airport. A new endorsement to fly out of a new airport perhaps, but not a repeat of the flight to a towered airport privilege for example.

#3

FLIGHT >50 NM FROM  AIRPORT

I believe the one time only rule applies.

Again, the FAR addressing the endorsement granting the Recreational Pilot the  privilege of flying > 50 NM from a departure airport are general in nature.

The regulations state:

(c) A person who holds a recreational pilot certificate may act as pilot in command of an aircraft on a flight that exceeds 50 nautical miles from the departure airport, provided that person has -

(1) Received ground and flight training from an authorized instructor on the cross-country training requirements of subpart E of this part that apply to the aircraft rating held;

(2) Been found proficient in cross-country flying; and

(3) Received from an authorized instructor a logbook endorsement, which is carried on the person's possession in the aircraft, that certifies the person has received and been found proficient in the cross-country training requirements of subpart E of this part that apply to the aircraft rating held.

The critical wording for this third element is that the additional >50 nm privileges are granted from the departure airport referenced earlier. Again, elements (c) (1), (2), and (3) which enable these privileges are general in nature, and simply address cross country flying proficiency and training requirements for specific aircraft ratings.  They are silent regarding any specificity of whether the endorsements indeed need to be made or ever repeated for any specific airport. Again, it appears to me that if this > 50 NM endorsement is ever earned anywhere, then the enabling cross country privilege is permanent.

So, I believe that these three specific privileges, namely flight into a tower controlled airport, flight into Class B, C, & D airspace, and flight  >50 NM from the departure airport are earned with a one time Recreational Pilot endorsement.  Once earned these endorsements, as in the case of the Sport Pilot License, do not need to be repeated.

Again, the FAA has stated that a recreational pilot may exercise the full privileges of a Sport Pilot. Sport Pilot privileges of flight into  Class B, C, & D, and flight into control tower airports are earned with a one time endorsement. ( Sport Pilot Reference §61.325 )  There is no limit on > 50 nm from a departure airport with a Sport Pilot License.

I can envisage several scenarios where a potential regulatory paradox is created. Aligning the Sport Pilot and Recreational Pilot endorsement criteria for airspace and towered airport operations helps to avoid these conflicts. Moreover, the  Recreational Pilot >50 NM from departure airport privileges, if interpreted as needing only a one time endorsement, would align the Recreational License privileges with those enjoyed by the Sport Pilot License, whose privileges a Recreational Licensee can exercise at any time anyway in an LSA aircraft.

( II )  Additional FAA Documentation

In February 2016 the FAA published:

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_61-65F.pdf

Advisory Circular AC No: 61-65F  Date:  2/25/16

I call your attention to Paragraph 22 “RECREATIONAL PILOT CERTIFICATION” See Sections (b) and (c) on page 14

Also, AC 61-65F Appendix 1 on pages 9 & 10 offers several written examples of how to provide written endorsements for these three specific Recreational Pilot privileges. Again, the language describing the specific required training prerequisites is general in nature and free of any language addressing airport specificity.

Overall, AC 61-65F is completely silent on any airport specificity in relation to endorsement-related training.  Likewise it is silent regarding any need for repeated endorsements for these three specific additional Recreational Pilot privileges.  The language in AC 61-65F therefore appears completely consistent with my interpretations of the Recreational Pilot Endorsements and Limitations § 61.101. that once earned, no repeated endorsements are required.

(III )  Summary -   My Interpretations

That the following three endorsements are one time only, and once earned do not need to be repeated by the Recreational Pilot. I believe the one time only rule applies to:

• The endorsement and enabling privilege to fly into Class B, C, & D airspace.
• The endorsement and enabling privilege to fly into control tower airports.
• The endorsement and enabling privilege to fly >50 nm from the departure airport.

I hope the FAA’s Recreational Pilot License remains viable. Not everyone has the time or resources to earn their full Private Pilot License. Many pilots have weight issues that make the 1320 Gross Weight limitation of a Sport Pilot License a barrier.  There remains a case to be made for having a viable Recreational Pilot License thereby providing the General Aviation Pilot one more option. Basic Med option may or may not help in some cases.

The Agency spent a lot of time and effort to create this category. It serves no purpose to so restrict the Recreational Pilot License as to make it nothing short of a glorified Student Pilot Certificate requiring an endless continuing chain of multiple endorsements.

I know this has been a bit wordy. I find it all to be very nebulous and open to multiple interpretations. According to FAA data

https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/

as of 2017 are currently only 153 actively licensed Recreational Pilots in the US.  It is therefore unlikely that many CFIs, DPEs, etc.  have a lot of experience with this license, much less the nuances surrounding the endorsements for this particular rating.

Calls to AOPA’s Pilot Information Center have likewise not proven to be all that productive. Yes, I know I can contact the local FSDO. I indeed did that very thing, and they suggested that my inquiry be sent to the FAA Office of the Chief Counsel. I did that in 2017 (twice) and never heard back. It died in their emails somewhere.

If anyone has any experience regarding how to interpret the permanence, if any, of these three Recreational Pilot Endorsements please share.

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