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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
June 4, 2020
NAAA Urges FAA to Extend Expiration Dates of Certain Aviation Requirements Granted in SFAR 118 for 1 to 3 Months
NAAA joined in another letter last week to the FAA requesting extension of certain exemptions expiring June 30, 2020, due to continued shutdowns of government facilities and limited access to CFIs, DPEs and AMEs based on the coronavirus quarantine. In April, NAAA and other general aviation associations were successful in urging the FAA to issue SFAR 118 (Relief for Certain Persons and Operations during the Coronavirus Disease 2019) to allow affected pilots, aircraft owners and manufacturers to continue their important role to the U.S. and worldwide economy and overall public benefit. This recent request to the FAA is to extend the relief provided in SFAR 118 beyond June 30, 2020, to include:
  1. An additional one month of flexibility for pilots, operators and certificate holders to comply with certain training, recent experience, testing and checking requirements provided in SFAR 118.
  2. Additional relief until Sept. 30 for duration, medical and renewal requirements provided in SFAR 118.
  3. Relief for pilots, operators and certificate holders who face expiring experience, testing, checking, duration, medical and renewal requirements in July, August and September 2020

NAAA joined the other aviation groups justifying these extensions by stating, “The Centers for Disease Control announced the U.S. reached 100,000 COVID-19 related deaths on May 28, 2020, and continues to recommend limited contact with those outside of your household. Even though some restrictions are beginning to ease or disappear, many states and local governments still enforce social distancing requirements.” The letter to the FAA may be read here


The original relief in SFAR 118 issued in April included the following:

  • Medical Certificates: The FAA extended the validity periods of medical certificates expiring between March 31 and May 31 through June 30.  This is an important distinction between the FAA’s previous decision to simply suspend enforcement actions against expired medical certificates, which could have potentially caused insurance complications.
  • Flight Reviews: The FAA is offering a three-calendar-month “grace period” for those whose flight review expire between March 1 and June 30. However, there are two conditions to be eligible for this extension: The pilot must have logged at least 10 hours of pilot in command time (PIC) within the 12 calendar months preceding the month the flight review was due, in an aircraft for which that pilot is rated. Eligible pilots must complete FAA Safety Team online courses totaling at least three Wings credits. The courses must have been completed in January or later to meet this requirement, according to the rule. For Robinson R-22 and R-44 pilots, the 10 hours of PIC time noted above must be in an R-22 or R-44, provided the pilot has at least 200 hours of helicopter time with at least 50 hours in an applicable Robinson helicopter.  R-22 or R-44 pilots with less than the above level of experience may extend their flight review an additional three months provided that of their 10 hours of PIC time in an R-22 or R-44, 3 hours has occurred in the 3 calendar months preceding the month the flight review was due, and  they complete a minimum of three hours of self-study that includes specific subjects as denoted in the SFAR.
  • Knowledge Tests: Applicants whose knowledge tests expire between March and June will have their knowledge tests’ validity extended by three months.
  • Flight Instructors: Unlike pilot certificates, flight instructor certificates expire every two years. The FAA will  extend the validity of flight instructor certificates that expired between March 31 and May 31 until June 30.
  • Inspection Authorization:  Airframe and powerplant mechanics with inspection authorization who were not able to meet the first-year renewal requirements by March have until June 30 to complete one of the listed activities to meet the first-year renewal requirements. 
The FAA justified the need for the SFAR 118 writing, in part, “… the associations stressed the importance of general aviation operations for lifesaving air medical missions, the movement of essential personnel and medical equipment, aerial applications for crops, forestry treatments, firefighting, and eradication of mosquitoes and other disease-carrying pests.”

NAAA will keep the membership apprised of the FAA’s actions to extend these expiration dates.


You can get the very latest policy guidance on the COVID-19 pandemic important to agricultural aviators at

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This newsletter is intended for NAAA members only. NAAA requests that should any party desire to publish, distribute or quote any part of this newsletter that they first seek the permission of the Association. The views, thoughts, and opinions expressed herein do not necessarily represent those of the National Agricultural Aviation Association (NAAA), its Board of Directors, staff or membership. Items in this newsletter are not the result of paid advertising and are only meant to highlight newsworthy developments. No endorsement by NAAA is intended or implied.
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