# Can a FAA “Letter of Authorization” be used when there are no pilots that are current on a type rating?

A pilot has multiple type ratings and wants to train for another aircraft (e.g. DC-4) which is on his Part 125 certificate. Unfortunately, there are no available pilots with currency on this aircraft type, but some do have the rating.

Can the FAA authorize a "Letter of Authorization" for the pilot to train based on his other type ratings? Or, could the FAA issue a letter of authorization to a pilot with the appropriate type rating to be used as a training instructor?

As of today the FAA has a few examiners who can issue the type rating for this aircraft, but have lapsed the currency requirement. Therefore, the question is one of training and how to obtain it; not the actual addition of the rating which they can provide.

• Its a bit unclear (to me) what you are asking, can you provide a specific example with the specific aircraft involved. Based on the tag it seems like you want to know if you can get a rating for a DC-4 when no one at your operation is current on the aircraft. Do you cary a conventional gear checkout and multi-engine (thats the first step) – Dave Apr 14 '18 at 23:27

If I understand the question correctly;

Maybe

The FAA outlines a generic type rating curriculum in this AC which is worth going through as it outlines what training would potentially be required for the type cert,

FAA FAR 61.31 does allow for a waiver

§ 61.31 Type rating requirements, additional training, and authorization requirements.

(b)Authorization in lieu of a type rating. A person may be authorized to operate without a type rating for up to 60 days an aircraft requiring a type rating, provided -

(1) The Administrator has authorized the flight or series of flights;

(2) The Administrator has determined that an equivalent level of
safety can be achieved through the operating limitations on the
authorization;

(3) The person shows that compliance with paragraph (a) of this
section is impracticable for the flight or series of flights; and

(4) The flight -

(i) Involves only a ferry flight, training flight, test flight, or
practical test for a pilot certificate or rating;

(ii) Is within the United States;

(iii) Does not involve operations for compensation or hire unless the
compensation or hire involves payment for the use of the aircraft for
training or taking a practical test; and

(iv) Involves only the carriage of flight crewmembers considered
essential for the flight.

(5) If the flight or series of flights cannot be accomplished within
the time limit of the authorization, the Administrator may authorize
an additional period of up to 60 days to accomplish the flight or
series of flights.


Section 3 is the important one. You would have to show that it is "impractical" for you to obtain the type rating with out the waiver to operate the aircraft and fly the required training time.

You may also have a compounded issue of then needing a second crew member who is typed in the aircraft and can provide training/co-pilot duties. Further more you cant conduct any commercial operations while doing this so you need an empty DC-4 and a lot of time (read money) to fly it. Keep in mind you may only have 60 days to accomplish all the training as well or you will need to get an extension on the waiver.

Just a general note. These kinds of situations are often best suited for an aviation lawyer who has experience dealing with the FSDO. It would be wise in this case to seek the aid of someone like that. You also may want to look for remote training if there is another operational DC-4 flying elsewhere and an arrangement could be made for you to go train with them for some time that situation may, in the long run be simpler.