On May 4, 2020, the FAA published a Special Federal Aviation Regulation (Special FAR) with updated guidance for Part 107 certificate holders needing to fulfill the knowledge recency requirements under Part 107.65. This SFAR is in response to the fact that many, though not all, testing centers remain closed due to COVID-19 and may remain closed for some time.

What do I need to know?

If your Part 107 knowledge recency lapses between April 1, 2020 and June 30, 2020, you can take one of the two online tests usually reserved for current Part 61 pilots. Passing one of those tests will give you a 6 month extension of your Part 107 knowledge recency. Before the end of those 6 months, you will have to take the recurrent exam in a testing center.

This SFAR is only for current Part 107 certificate holders who need to fulfill the knowledge recency requirement of Part 107.65. The online exam is only a replacement for the recurrent exam you would normally take at a testing center.

Nothing in this SFAR provides relief for those seeking to get their initial Part 107 certification. If you do not already have your Part 107 certificate, this SFAR does not apply to you and you are still required to go to a testing center (when they reopen) and take the initial exam to earn your Part 107 certification.

What is the fine print?

This guidance affects Part 107 certificate holders who were not able to take their recurrent test in March or April 2020, and who may be unable to do so in May or June 2020.

This means that if your knowledge recency lapsed prior to April 1, 2020, you are not eligible for relief under this SFAR. As it stands now, you must take your recurrent exam in a test center, and you are not able to act as Remote Pilot in Command (RPIC) until you do so.

Example 1: If the date of your initial exam or your latest recurrent exam was in February 2018, then your recency of knowledge was valid until the end of February 2020, and your recency of knowledge lapsed on March 1, 2020. You are not allowed to use the relief offered in the Special FAR. You will have to take the exam in a testing center to re-establish your knowledge recency.

Example 2: If your recency of knowledge lapsed in October 2019 and you were waiting until the spring to take your recurrent knowledge test, you are not allowed to use the relief offered in the Special FAR. You will have to take the exam in a testing center to re-establish your knowledge recency.

Example 3: If the date of your initial exam or your latest recurrent exam was in March 2018, then your recency of knowledge was valid until the end of March 2020, and your recency of knowledge lapsed on April 1, 2020. You are allowed to use the relief offered in the Special FAR. You can take the online test to re-establish your knowledge recency and continue operating under Part 107.

How do I take the recurrent exam if I’m eligible for relief?

The online tests are available at faasafety.gov. That website is a very good source for aviation safety information. You will have to create an account on faasafety.gov to receive credit, and creating an account is free.

The specific tests are available for the Recurrent test (ALC-515) here, and the Initial test (ALC-451) here. Passing either test is acceptable to renew your knowledge recency, however, it is important to note that neither is a replacement for the initial Part 107 exam.

Where can I find official FAA information on this topic?

The Special FAR was published in the Federal Register on Monday, May 4. That document can be found here. The portion relevant to Part 107.65 is on pages 26333 and 26334 of that Special FAR.

The FAA answered a variety of FAQs at https://www.faa.gov/uas/media/107_65_SFAR_FAQ.pdf.

If you have additional questions, you can email andrew@kittyhawk.io.

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