Student Pilot Certificate and Personal Limits

A student pilot holds a student pilot certificate and a medical certificate. Four rules in Part 61 keep them valid. No rule in Part 61 measures whether the pilot can fly well today.

The student pilot certificate

An applicant for a student pilot certificate must be at least 16 years old, for anything other than a glider or balloon 1. The applicant must be able to read, speak, write, and understand English. The same section sets 14 as the age for gliders and balloons only.

The certificate is a plastic card, and it does not expire. Since April 1, 2016, the FAA issues student pilot certificates without an expiration date. Like any pilot certificate it stays valid unless it is surrendered, suspended, or revoked 2. Paper student certificates issued before that date expired with the medical. The plastic card is permanent. Only the medical certificate has an expiration date.

The private pilot certificate

A private pilot must be at least 17 years old for an airplane rating 3. The rule requires four things before the FAA issues the certificate:

• a logbook endorsement that says the student is ready for the knowledge test
• a passed knowledge test
• a second endorsement that says the student is ready for the checkride
• a passed checkride with an examiner.

The endorsements come from the instructor. The student must earn each one before the test it permits.

A private certificate with an airplane single-engine rating takes at least 40 hours of flight time 4. At least 20 of those hours are flight training with an instructor, and at least 10 are solo flight. Inside those hours are smaller requirements:

• 3 hours of cross-country training
• 3 hours at night, with one flight over 100 nautical miles and 10 full-stop landings
• 3 hours of flight by reference to instruments only
• 3 hours of checkride preparation within the 2 calendar months before the test
• a solo cross-country of 150 nautical miles with landings at three points.

Forty hours is the minimum, not the plan. The national average at the checkride is well above 40 hours. The night cross-country and the 150-mile solo each take a whole flight of their own.

Three classes

A medical certificate comes in three classes, and the class matches the flying 5:

• first class, for airline transport pilot privileges
• second class, for commercial privileges
• third class, for private, recreational, and student pilot privileges.

An Aviation Medical Examiner issues each one. An AME is a physician the FAA designates, and the exam is against the standards in Part 67.

14 CFR 61.23 says which class a pilot needs. A person must hold at least a third-class medical when exercising the privileges of a private, recreational, or student pilot certificate 6. The same requirement applies when taking a checkride for those certificates. "At least" means any class works for a private pilot. The exception written into the same sentence is BasicMed.

How long it lasts

Paragraph (d) of 61.23 sets duration in a table. For a third-class medical the table has two rows. A pilot under 40 on the exam date holds private privileges through the end of the 60th month after the exam month. A pilot 40 or older on that date holds them through the end of the 24th month 6.

The handbook rounds these periods to five years and two years. That approximation is sufficient for conversation. It is not sufficient for the day the certificate expires.

The age test is on the day of the exam. A pilot examined at 39 gets the 60-month row. Turning 40 the following week does not shorten it.

A higher class keeps working as a lower one

The table's third column says the certificate expires "for that operation." A first-class medical has a row for airline privileges, 12 months. It has a separate row for private privileges, and that row reads the same as the third-class row: 60 or 24 months. When an airline pilot's first-class medical passes its 12th month, it keeps working as a third-class medical for the third-class duration. A pilot who met the higher standard also met the lower one 5. A first- or second-class exam taken for a future job does not shorten the duration of a pilot's private privileges.

The flight of N81839

On January 13, 2017, a 79-year-old private pilot took off alone from North Bend, Oregon, in a Piper Dakota he had owned since 1992. His medical certificate expired on September 30, 2011. His last flight review was in October 2011. For years he suffered sudden episodes of vision loss, and he reported none of them on a medical application. Fifty minutes into the flight he lost the vision in one eye. The airplane struck a beach near Port Orford, and he died.

He held a private pilot certificate with an instrument rating and about 1,300 hours, nearly all in the Dakota. He kept it in a hangar at North Bend, next to the hangar of a flight instructor who knew him for fifteen years. That instructor did the annual inspections on the Dakota.

His last medical exam was in September 2009. He was over 40, so the 24-month row applied to the third-class certificate issued that day. It expired on September 30, 2011.

On the application he reported occasional heartburn. He did not report the episodes of vision loss, sometimes in one eye and sometimes in both. His doctors attributed them to a condition called multiple chemical sensitivity. He never reported those episodes on any medical application.

His last flight review was on October 27, 2011, a month after the medical expired. The instructor who gave it said his judgment and skills were good but a little "rusty." A few years before the accident, the pilot told that instructor he would not fly anymore, because his medical certificate expired.

He kept flying. The annual inspections recorded how much. Between October 2011 and March 2016 the airplane flew 11.5 hours, then 1.7, then 4.2, then 13.7.

About a year before the accident the instructor flew with him again. The pilot had trouble with basic flying, was confused on the radio, and was "well behind the airplane." The pilot agreed and said he could get current with a little more instruction. The instructor never saw him take any.

That same year, driving on a highway, he lost his vision completely. He got off the road by feeling the rumble strips through the wheel.

On January 13, 2017, the weather cleared. He told his son he wanted to fly along the coast on a clear day. He took off from North Bend at 10:16 in the morning, alone. The sky was clear, with ten miles of visibility and four knots of wind. He flew north, then asked the tower for a transition back south along the shoreline.

At 11:03 the tower asked for his position. He answered: "I'm having trouble with, err, headphones, err, say again." The next transmission was muffled. Ten minutes later a Coast Guard helicopter crew and an Air Force crew heard him on the emergency frequency. He said he lost the vision in one eye.

At 11:22 a radar target squawking 7700 appeared for 24 seconds along the coast west of Port Orford, 44 miles from North Bend. It descended through 1,300 feet at about 100 knots. At 1:07 that afternoon the helicopter found the Dakota on a sandspit, fifty feet from the ocean, four miles north of that last target. The damage showed a high-speed, left-wing-low impact.

The NTSB's probable cause is the pilot's loss of vision during cruise flight, which resulted in a loss of control. Contributing was "the pilot's decision to fly with a known medical condition" 7. The airplane flew 1 hour after its last annual inspection.

Where the accident chain could have been broken

The accident was six decisions. Each is listed below with its PAVE category and the decision that would have ended the chain. Most of the decisions were about a document, and each document recorded a fact about the pilot's fitness to fly.

61.53: whoever knows is grounded

A medical certificate says a doctor found the pilot fit on the day of the exam. It does not say the pilot is fit today. 14 CFR 61.53 is the rule for today.

Paragraph (a) applies to each pilot who holds a Part 67 medical. You must not act as pilot in command, or sit in a required pilot seat, in two conditions 8. The first condition is a medical problem that you know, or have reason to know, fails the standard for your certificate. The second condition is medication or treatment for such a problem. "Knows or has reason to know" is the test. The test does not require a diagnosis, and it does not depend on the medical certificate.

This paragraph grounded the Port Orford pilot from the first episode of lost sight, years before his medical expired.

Paragraph (b) applies to pilots who need no medical: glider and balloon pilots, and pilots flying on a driver's license. They must not act as PIC while they know, or have reason to know, of a condition that prevents safe operation. Paragraph (c) applies paragraph (b) to a BasicMed pilot. Under BasicMed, 61.53 is the medical standard between physician exams. The online course requires a signed statement in the first person: "I understand that I cannot act as pilot in command, or any other capacity as a required flight crew member, if I know or have reason to know of any medical condition that would make me unable to operate the aircraft in a safe manner" 9.

Temporarily disqualified

61.53 covers ordinary conditions as well as heart disease and seizures. The AIM's chapter on medical facts lists them 10. Even a minor illness can degrade the tasks vital to safe flight, and the medication taken for it can degrade them further. A head cold is the common case. A blocked eustachian tube on descent produces an ear block, with severe pain and a possible ruptured eardrum. Other examples:

• a new prescription the pilot has not flown on before
• a dental anesthetic that has not worn off
• fatigue, which the AIM calls one of the most treacherous hazards to flight safety, because it is often not apparent until serious errors occur
• stress from everyday living, which the AIM says impairs pilot performance in subtle ways.

The AIM's personal checklist is IMSAFE: Illness, Medication, Stress, Alcohol, Fatigue, Emotion. The checklist is not only advice. Illness, Medication, and Stress are conditions 61.53 covers. A pilot who flies with one of them, when it fails the standard, violates 61.53.

BasicMed

Since 2017 a pilot can be medically qualified for private flying without a Part 67 certificate. The alternative is BasicMed, in 61.23(c)(3) and Part 68. Four conditions apply 11:

• You held an FAA medical certificate of any class at some time after July 14, 2006.
• You hold a valid U.S. driver's license and obey each restriction on it.
• Each 24 calendar months you complete the free online medical course and keep the certificate 9.
• Each 48 months a state-licensed physician examines you against the FAA checklist and signs it 12.

A pilot diagnosed with a condition that can affect flying must also be under that physician's care.

The first condition affects students. BasicMed requires a past FAA medical. A new student who never held one cannot start on BasicMed. The first medical must come from an Aviation Medical Examiner. After that, the rule for students is the same as for private pilots. A student can exercise student privileges without a Part 67 medical by holding a valid U.S. driver's license and meeting the BasicMed conditions 13.

Expired is fine, denied is not

The most recently issued medical can be expired. That condition is why BasicMed is useful to pilots whose medicals lapsed years ago. The FAA must not have suspended or revoked the medical, and must not have denied the most recent completed application 11. A special issuance that expired is fine. One the FAA withdrew is not. BasicMed is open to a pilot the FAA once found fit and closed to a pilot the FAA denied.

A student can take the private pilot checkride under BasicMed. The sentence in 61.23 that requires a third-class medical for the checkride makes an exception for 61.113(i) 6. The permission covers a student whose first medical expired.

The BasicMed envelope

BasicMed is medical qualification for a defined kind of flying, and the definition is in 61.113(i) 14. Three limits describe the aircraft:

• authorized to carry not more than 7 occupants
• a maximum takeoff weight of 12,500 pounds or less
• operated with no more than 6 passengers on board.

Each training airplane at this school fits inside those limits.

Three more limits describe the flight:

• at or below 18,000 feet above mean sea level
• at an indicated airspeed of 250 knots or less
• inside the United States, unless the other country authorizes the flight.

A flight outside any one of those limits is a flight without medical qualification. The violation is the same as flying with no medical at all.

The paperwork is in the logbook

No rule requires a BasicMed document in the airplane. The completed physician's checklist and the course completion certificate must be available in the pilot's logbook 14. No rule requires a certificated private pilot to carry the logbook in flight. The FAA also holds the course record electronically. In a ramp check under BasicMed, the inspector asks for the documents that establish medical qualification. The pilot produces the logbook on a reasonable request.

Three documents, one standard

14 CFR 61.3 names three documents a pilot carries, with one carriage standard for all of them. To exercise the privileges of a pilot certificate, the certificate must be in the pilot's physical possession or readily accessible in the aircraft 15. Paragraph (a)(2) requires a photo identification to the same standard. The photo identification can be:

• a driver's license issued by a state
• a government identification card
• a U.S. Armed Forces identification card
• an official passport
• an airport security badge
• another form the Administrator finds acceptable.

Paragraph (c) requires the medical certificate, when one is required, to the same standard: physical possession or readily accessible in the aircraft.

"Readily accessible" means in the airplane, within reach. A wallet in the car in the parking lot does not meet the standard. A wallet in a pocket does. Carry the certificate, the medical, and the driver's license together, on your person, on each flight.

Who can ask

Paragraph (l) says who can ask to see the documents. A pilot must present the certificate, the medical or BasicMed documents, and the photo ID on request from any of these 15:

• the Administrator, which means any FAA inspector
• an authorized representative of the NTSB
• any federal, state, or local law enforcement officer
• an authorized representative of the TSA.

That request is a ramp check. It is short when the pilot carries the three documents.

The logbook is different

A logbook is a record, not a certificate, and the rule treats it differently. A pilot must present it for inspection upon a reasonable request from the FAA, an NTSB representative, or a law enforcement officer 16. "Reasonable request" means a pilot asked for the logbook on the ramp can say it is at home and bring it to the office. No rule requires a certificated private pilot to carry the logbook in flight. The logbook is the only record of a pilot's flight time, and a burned airplane destroys it.

A student pilot is the exception. A student pilot must carry the logbook and the student pilot certificate in the aircraft on all solo cross-country flights 16. They are the evidence of the required instructor clearances and endorsements. The solo cross-country endorsements are in the logbook and nowhere else. On those flights the logbook carries the endorsements that make the flight legal.

Each 24 calendar months

One rule keeps a private certificate usable: the flight review. The pilot must have completed the review since the beginning of the 24th calendar month before the month of the flight 17. The pilot must also hold a logbook endorsement from the instructor who gave it. Without both, a pilot cannot act as pilot in command.

The minimum is 1 hour of flight training and 1 hour of ground training. The ground hour covers the current general operating and flight rules of Part 91. The flight hour covers the maneuvers and procedures the instructor decides are necessary to show safe exercise of the certificate's privileges.

Students do not do flight reviews. Paragraph (g) excuses a student who is in training and holds a current solo endorsement. The rule first applies after the checkride. From then on it applies each two years for the rest of a pilot's flying.

What counts instead

Two events substitute for a flight review. A passed checkride for any certificate or rating, given by an examiner, counts 17. The private checkride starts the first 24-month period.

A completed phase of the FAA's WINGS pilot proficiency program also counts. The WINGS advisory circular says each time a pilot earns a new phase of WINGS, it satisfies the flight review requirement 18. WINGS is a set of online courses and flight tasks flown to standard with an instructor, at faasafety.gov. It is free.

Not a test

AC 61-98E tells the instructor that the flight review "is not a practical test, but rather a training event in which proficiency is evaluated" 19. There is no pass or fail. The instructor tailors the review to the flying the pilot does. The instructor then either endorses the review as satisfactorily completed or logs the training given and schedules more. Neither outcome enters the pilot's FAA record.

The Port Orford pilot's last flight review found him "a little rusty." The review found the problem and gave an instructor a reason to say so. Each decision after that review was the pilot's.

Three takeoffs, three landings, 90 days

The flight review keeps a pilot legal to fly at all. A second rule, 61.57, keeps a pilot legal to carry other people. A pilot in command of an aircraft carrying persons must have made at least three takeoffs and three landings within the preceding 90 days 20. The pilot must have been the sole manipulator of the flight controls. The takeoffs and landings must have been in an aircraft of the same category, class, and type, if a type rating is required. For a student here those words mean an airplane, single-engine land.

Landings in a helicopter do not count toward carrying passengers in a Warrior. Landings from the right seat while someone else flew them do not count either. If the airplane has a tailwheel, the pilot must have made the three takeoffs and landings to a full stop in a tailwheel airplane. A touch-and-go in a Luscombe does not count.

Night

Night has its own paragraph and its own 90 days. The night period runs from 1 hour after sunset to 1 hour before sunrise. To carry persons in that period, a pilot needs three takeoffs and three landings to a full stop in that period 20. They must be within the preceding 90 days, as sole manipulator, in the same category, class, and type. Each one must be a full stop. A night landing that rolls out and takes off again is a touch-and-go, and touch-and-goes do not count at night.

Day currency does not give night currency. Night currency does give day currency, because three full-stop night landings are also three takeoffs and landings in the preceding 90 days.

Persons, not passengers

The rule says "carrying persons." Until December 2024 it said passengers. Part 61 now defines a passenger as "any person on board an aircraft other than a crewmember, FAA personnel, manufacturer personnel required for type certification, or a person receiving or providing flight training, checking, or testing as authorized by this part" 21. An instructor is not a passenger, and neither is the examiner on a checkride. The FAA reworded the currency rule to "persons" so that it covers everyone on board. The FAA added two exceptions at the same time so that a pilot can regain currency without violating the rule.

Getting it back

A pilot without currency can still fly day VFR or day IFR with no one else aboard. Three trips around the pattern alone regain day currency. The rule also has two exceptions for training and testing 20. The 90-day requirements do not apply to a person receiving flight training from an authorized instructor, in three conditions:

• the training is limited to meeting the 90-day requirements
• the person is otherwise qualified to act as pilot in command
• the instructor and the person are the sole occupants.

The requirements also do not apply to the examiner or the applicant during a checkride. A non-current pilot can regain day or night currency with an instructor on board. A checkride applicant whose last night flight was four months ago violates nothing by flying with the examiner at night.

Calendar months end at month-end

Three rules in Part 61 count in calendar months, and a calendar month is the whole month. A period counted in calendar months ends on the last day of a month. 61.23 says the medical expires "at the end of the last day of the" 60th or 24th month after the month of the exam 6. A pilot under 40 examined on September 23, 2026, holds a valid medical through September 30, 2031, not September 23. The exam month itself does not count. The count starts with the next month.

The Port Orford pilot's exam was September 10, 2009, and his 24 months ran to September 30, 2011.

The flight review counts the same way in the other direction. The window runs from "the beginning of the 24th calendar month before the month" of the flight 17. A flight review on October 27, 2011, covers flying through October 31, 2013. For a flight in November 2013, the 24th calendar month before is November 2011, and the review was one month too early. The 90-day currency rules are different. They count in days, not calendar months, and the period is counted to the day.

Three different nights

"Night" has three different definitions in three different rules, and the examiner asks about all three on the checkride oral:

• Position lights go on at sunset and stay on until sunrise. The lights rule uses sunset and sunrise 22.
• Night flight time begins when evening civil twilight ends and lasts until morning civil twilight begins 23. That definition governs logging and the 3 hours of night training in 61.109. Civil twilight ends roughly half an hour after sunset at this latitude.
• Night currency landings count only between 1 hour after sunset and 1 hour before sunrise 20.

A pilot who lands 40 minutes after sunset has the position lights on, logs the landing as night, and gains nothing toward night currency.

Two separate questions

The rule for logging pilot-in-command time is not the rule for acting as pilot in command. Under 61.51(e) a private pilot can log PIC time in two cases 24. The first is sole manipulator of the controls of an aircraft for which the pilot is rated. The second is sole occupant of the aircraft. Acting as PIC means holding final authority under 91.3. The two rules can name different pilots on the same flight.

The Chief Counsel settled the question in 2009. Two private pilots fly IFR. One has an instrument rating and acts as PIC, and the other has no instrument rating and flies a leg. The non-instrument pilot can log PIC for the time as sole manipulator. "Rated" refers to the aircraft ratings on the certificate, "rather than for the conditions of flight." Only the instrument-rated pilot can act as PIC 25.

A student pilot's rule is narrower. A student logs PIC only as sole occupant, with a solo endorsement, in training 24. A student logs dual lessons as training received, not PIC, even when the student's hands are on the controls for the whole flight.

Rated is not endorsed

The same letter defines "rated" as category, class, and type, the ratings printed on the certificate. Endorsements are not ratings. A complex airplane has retractable gear, flaps, and a controllable propeller. A high-performance airplane has an engine of more than 200 horsepower. Each requires ground and flight training and a one-time logbook endorsement before a pilot can act as PIC 26. The endorsement rules say nothing about logging.

A private pilot with an airplane single-engine land rating and no high-performance endorsement can log PIC in a Dakota while sole manipulator. An endorsed pilot acts as PIC beside them. The unendorsed pilot cannot act as PIC of the Dakota until the endorsement is in the logbook.

The address on file

A pilot who changes permanent mailing address must notify the FAA Airman Certification Branch in writing within 30 days 27. After 30 days without the notice, the pilot cannot exercise the privileges of the certificate. The FAA's airmen services website takes the notice online, and the online notice counts as writing.

What a private pilot cannot be paid for

A private certificate permits flying, not earning. 61.113(a) says no private pilot can act as pilot in command of an aircraft carrying passengers or property for compensation or hire 28. The same paragraph says no private pilot can act as PIC for compensation or hire in any case.

Paragraph (c) permits one arrangement, expense sharing. A private pilot cannot pay less than the pro rata share of the operating expenses of a flight with passengers. Fuel, oil, airport expenditures, and rental fees are the only expenses the pilot can share. Four people on board means four equal shares, and the pilot pays one of them. Insurance, the annual inspection, and the charts are the pilot's alone.

Compensation is not only money

The FAA's advisory circular on expense sharing defines compensation as "the receipt of anything of value that is contingent on the pilot operating the aircraft" 29. Compensation does not require a profit, a profit motive, or any payment of money.

Logged flight time counts. Goodwill, in the form of expected future economic benefit, counts. A benefit to someone other than the pilot counts. A business owner lets a pilot fly the company airplane free so that the pilot can build hours. The hours are compensation, and 61.113(a) applies.

The common purpose test

Cost sharing is legal only on a shared trip, and the FAA calls its test for a shared trip common purpose. The pilot must have a reason of their own for going to the destination, apart from payment for the flight 30.

When the pilot chooses the destination, the FAA takes that choice as a sign of a real shared trip. The passengers can have different business there. The test is whether the pilot would have made the flight anyway. A pilot who would not have flown except for the chance to split the cost does not share expenses. That pilot carries passengers for hire on a private certificate.

Only from the people on board

The Chief Counsel answered a second question in 2009. A private pilot flew coworkers to a business meeting in his own airplane and asked whether his employer could reimburse the flight. 61.113(c) "allows a private pilot to seek reimbursement only from his or her fellow passengers, not a third party, such as your employer" 31. When he flew himself to the meeting alone, his employer could reimburse him under paragraph (b). That flight was incidental to his job and carried no one for hire. With coworkers aboard, the only money he could take was their pro rata share.

The narrow exceptions

Paragraphs (b) through (h) of 61.113 list the other flights for which a private pilot can accept compensation, and each is narrow 28:

• a flight in connection with a business, if the flight is only incidental to it and carries no passengers or property for hire
• a charitable or community event flight under 91.146, which requires among its conditions that the private pilot have at least 500 hours 32
• reimbursed fuel and rental for search and location work under a sanctioning agency
• towing a glider, with the 61.69 training
• demonstrating an aircraft to a buyer, if the pilot is an aircraft salesman with 200 hours.

The 500-hour figure applies to a pilot who takes no money. A pilot who donated a sightseeing flight to a school auction, taking no money himself, asked the Chief Counsel whether the rule applied. It did. The auction proceeds compensated the school, and the pilot needed 500 hours 31.

Holding out

Advertising a flight to the public is holding out, and social media posts are advertising. Holding out is what makes a common carrier, and a common carrier needs a commercial operating certificate. "Advertising in any form raises the question of holding out" 33. A pilot can invite people to share a flight, but the invitation must go to "a defined and limited group comprised of people with whom he or she has an ongoing, pre-existing relationship": family, friends, close acquaintances. Posts on social media are subject to the same test.

A message in a private group of friends the pilot already knows can be expense sharing. A public post that anyone might answer is holding out. A pilot who holds out needs a commercial pilot certificate and must fly for a Part 119 operator.

Two different measurements

Currency is the legal minimum, on paper, checkable by an inspector. Proficiency is actual skill, and the rules never measure it. The FAA's advisory circular on the subject says pilots must design a currency program "which should emphasize proficiency beyond the minimum currency requirements" 34. The handbook says safe pilots understand "the difference between what is 'legal' in terms of the regulations, and what is 'smart' or 'safe' in terms of pilot experience and proficiency" 35.

Meeting 61.57 does not by itself make a pilot safe for a given flight. Three landings in 90 days is a minimum. A pilot whose last three landings were 89 days ago still meets it. Whether tonight's flight, with this crosswind, to that airport, is a flight the pilot can fly well is a different question. The rules leave that question to the pilot. The tool that answers it is the personal minimums check, written on a calm day, with no trip planned.

Why the FAA repeats the point

Loss of control in flight was the number one cause of general aviation fatalities from 2012 through 2021 36. Loss of control is not a weather accident or a mechanical one. It is an accident "in which a pilot should have maintained (or should have regained) aircraft control but failed to do so." The fix is proficiency training beyond the minimums. That need is why the flight review is a training event and why WINGS exists.

The Port Orford pilot was neither current nor proficient. The report's defining event is not the vision loss. It is loss of control in flight.

The unfamiliar airplane

Proficiency is specific to the airplane. Before flying an unfamiliar make and model, a pilot gets a checkout. The checkout covers the POH numbers, the systems, and the handling compared with the airplane the pilot knows. The FAA's transition advisory circular says "the predominant factor in fatal airplane accidents is pilot performance, particularly when transitioning to an unfamiliar airplane" 37. It advises training in the specific airplane the pilot plans to fly, with an instructor who has recent experience in that make and model. It adds that there is as much risk in moving down in performance as in moving up.

Nothing in Part 61 requires a checkout. The endorsements in 61.31 are the only ones. A move from a Warrior to an Archer, or from a Cessna 172 to a Cherokee, needs no signature. The discipline is the pilot's. This school has a checkout for each airplane on the line for that reason.

Round dials to glass

No rule requires an endorsement to move between a round-dial airplane and a glass-cockpit version of the same model. The NTSB studied that transition in 2010. Light single-engine airplanes with glass cockpits had lower total accident rates but higher fatal accident rates than the same airplanes with analog instruments 38. The FAA had no specific training requirements for the equipment.

The screens are better instruments. To a pilot without training on them, the airplane is unfamiliar. The pilot must ask for training on the screens.