SOE Limitation & How To Remove It

[TXCAP4228]

I haven't posted to FlightInfo in a long time, but I thought I would share this in case others want to make use of it in the future.

In the last couple of years I have obtained a couple of type ratings while working as a right seater at CAE Simuflite at DFW. Because these type checkrides were done in a Level C/D sim and because I did not have the requisite experience in turbojet aircraft (there are three or four ways to avoid having this limit applied, and they all involve having military or civilian experience either in the specific aircraft type or combined experience in turbojet aircraft), my certificate had a limitation on it saying "Pilot in Command Limitation applies to HS-125 and CE650". This language is the new way of saying what used to simply be "SOE 25". After getting my first type rating I started doing contract work in several Part 91 jets, and over time as I got comfortable with some of the captains I was flying with I told them about the SOE limitation and asked them if they wouldn’t mind signing off empty legs so that I could have it removed. What I asked the captains to do was to sign my logbook with “SOE Signoff, ATP# XXXXXXXX, [captain’s signature]”. Once I got the 25 hours signed off, I filled out an 8710 (only needed to fill out Part 1 – the top part). At the very top where all the checkboxes are, I marked “Other” and wrote “SOE REMOVAL”. I did not fill out anything in Part 2 or Part 3 on the front, and I did not fill out anything on the back. Then I took my logbook and the 8710 to the local FSDO Office (had to make an appointment), and I met with a FSDO Officer. I showed him the logbook entries and we chatted for a couple of minutes, and then he filled out the rest of my 8710 for me and gave me a new Temporary Airman Certificate with the limitation removed.

Incidentally, I had all of my SOE signoff’s done in Hawkers, but getting that done got the SOE removed from both type ratings. This makes logical sense considering the intent behind the SOE, but over the last couple of years I got different answers from everybody I asked about whether I would need SOE signoff’s for each specific aircraft type. As it turns out, the FSDO officer just removed the language altogether on the basis of the 25 SOE hours in the Hawker.

So, for anybody in the future who does a search for how to remove an SOE limitation from their certificate, this is how I did it and what to expect, and hopefully it will help you out.

One other quick note, at some point the SOE removal will transition to IACRA, but its not there yet so for now it still requires an 8710.

Best of luck to you!

 

[njcapt]

That's great information, thanks.

 

[Pickle]

You didn't have a clean type rating when you got either of those types. Ergo, the 25 hour SOE was on each type. I don't think that Fed was correct in removing the SOE from your 650 type, it should have only come off of the HS-125 if you ask me. But, I'm not a fed.

(g) The limitation described under paragraph (f)(2) of this section may be removed from the pilot certificate if the applicant complies with the following—
(1) Performs 25 hours of flight time in an aircraft of the category, class, and type for which the limitation applies under the direct observation of the pilot in command who holds a category, class, and type rating, without limitations, for the aircraft;

 

[TXCAP4228]

Hi Pickle. I read the FAR many times too, and I came down on a different side than you did. The reason is that if I had a clean HS125 type before I ever got my CE650 type, then when I got my CE650 type there would have been no SOE to begin with. For your interpretation to be correct, that would necessarily mean that an SOE would have to boil down to when any subsequent checkride took place (i.e. before or after the SOE was removed). After you think about it for a few minutes, that wouldn't make any sense at all. Your interpretation would literally create a theoretical possibility that the same pilot taking the same check ride on subsequent days (or even on the same day but just hours apart) would either have or not have the SOE – where in the intervening period a person got the SOE removed. Anytime it gets down to conditionality over a few hours it becomes pretty ridiculous, and so you have to evaluate the intent of the limitation.

Which in this case is to make sure that some dude who goes out and gets a type in a sim actually have some experience in the airplane before he (or she, sorry ladies) gets turned loose as a captain (notwithstanding whether an insurance company would ever even allow that). So, if the intent is to make sure that a pilot has some experience , it becomes clear that the SOE really only applies to large turbojet (or turboprop) powered aircraft.

And, as it turns out, the FED didn’t even ask me about it. He just removed it altogether. I suspect that if anybody ever actually asked the FAA about it this is the answer they would give.

 

[SENECAII]

I had an SOE removed by the feds in FLL from a HS-125 type rating several years ago and in the 5 type ratings that followed including a single pilot type,there was no longer an SOE attached to any of them.
I had been told that only the initial type would require an SOE and any that followed would not.

 

[TXCAP4228]

Yep. That matches my understanding and also matches what happened for me. I agree that it's confusing though.