As with the case of Martha Lunken, who had all of her pilot certificates and ratings revoked for dammed fool stunt where she intentionally flew under a bridge, The FAA does allow people to reapply for new certificates not less than a year after the revocation as an enforcement action. That being said, is all the flight time that a pilot has previously accumulated prohibited from being used toward the new certificate? Or does such an aviator essentially have to start from scratch and acquire all of the required aeronautical experience flight hours listed in part 61 again?

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    $\begingroup$ I don't know the FAA legal basis for this, so I'm not gonna post an answer, but the way the enforcement action was reported, it was almost always stated as "it will be a year before she will be able to apply again as a student". I don't believe flight time ever expires, even in the face of enforcement action, but the privileges do. So she'll presumably have to get the endorsements from CFI(I)s, and go through all the check rides, all over again, but will probably be able to use her existing flight time towards it. $\endgroup$
    – mathrick
    Commented Jan 21, 2022 at 20:18
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    $\begingroup$ Can Ms. Lunken log the time she was under the bridge? $\endgroup$ Commented Jan 22, 2022 at 1:46

1 Answer 1


Yes, flight time from before the revocation still counts. This is from Order 2150.3C - FAA Compliance and Enforcement Program:

A person whose certificate has been revoked may be issued a new certificate provided that the person meets the qualification requirements for the new certificate. To be issued an airman certificate following revocation, an individual must retake all tests, whether written, oral, or practical. Any experience requirements for the new certificate may be met with experience obtained before the revocation.


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