Removing the SOE Limitation from your Pilot Certificate
If you want to remove “SUBJECT TO PILOT-IN-COMMAND LIMITATION(S)” on your certificate for a particular aircraft, you’re required to have 25 hours of flight time in that aircraft where you’re doing the flying under the observation of the PIC of that flight.
See 14 CFR 61.64(g) for the full rundown but that’s the gist.
As a note, this process of removing the limitation through IACRA alone will only work if you have a single PIC type rating.
“Removal of the SOE limitation can only be accomplished in IACRA if the applicant only holds one type rating limited to SOE. If they hold more than one, it will have to be completed on a paper application.”
At the time that I had my SOE limitation removed, I had two type ratings but one was SIC Only while the other was PIC and there were no issues.
You may find the steps I outline below to be a bit overkill but I like to be thorough. I went back and forth with an FAA representative to make sure I wouldn’t encounter any issues because I treat IACRA like I’m going to the DMV. I bring every document I might ever need because I don’t want to miss something and have to start the whole process over.
IACRA Application
Log in to IACRA as an Applicant and select “Start New Application” at the top of the console.
Select “Administrative Action” as the Type of Application and then select “Remove Limitation without a Practical Test” from the next section.
From there, a new section will expand and the limitation will most likely be automatically selected.
Then click “Start Application”.
On this Application Process page, it’s all the normal stuff you’re used to. Confirming or updating your Personal Information, Residential Address, Certificate information, etc.
Pilot Time (Section III) is the one we’ll focus on. The representative I worked with recommended “blanking” out all of the flight time.
The reason for that is to save time when having the Certifying Officer process your application. If you both agree to spend the time reviewing your logbooks in order to lock in your current flight hours, that’s fine, but we didn’t have that much time available and I already have multiple copies of my logbooks saved that I can use as reference later.
The only category that you HAVE to put flight time in under Section III is 25 hours of Pilot in Command (PIC) time. The application cannot be submitted without that.
Review and submit your application when everything is in order and you’re ready for the next step.
Note: When reviewing the final copy of your application and see “See Comments” under Section I for Other Information/Requests; Limitation Removal but also see a blank Comments section on the final page of the application, don’t be alarmed.
The Comments section will populate automatically after the CO does their part:
Supporting Documents
Letters from PIC/s
The regulations say the “pilot in command who observed the flight attests in writing to each flight” so I kept track of the flights where it was my leg and shared them in this letter:
If you didn’t fly 25 hours with one single PIC, prepare multiple letters as appropriate. In my case, I had to prepare three different letters. The total hours combined was more than 25 but that wasn’t an issue.
I then sent the letter to each captain I flew with, through Docusign, as you get three free documents to have others sign digitally. I wanted to make it as simple as possible for them.
Logbook Excerpt
While the letters themselves could possibly be all you need, it’s best to provide an excerpt from your logbook highlighting the specific flights you’re referencing.
I use ForeFlight as my primary logbook so I simply exported a single-page logbook showing only the specific date range I referenced in the letters. Then I used the Shape tool in Apple Preview on my Mac, to create a border around the relevant entries.
Conclusion
That’s really about it. While the regulation outlines the requirements for removing the SOE Limitation, there’s no real guidance on how to do it. Luckily a few others have shared tips online that gave me a head start. And when I got this limitation removed, it was the first time this CO has ever done one using IACRA, so he was a bit unfamiliar with the process as well.
From this point on, it’s pretty much the process you’re no doubt familiar with by now. Schedule a meeting with your local FSDO or appropriate Recommending Instructor (RI) or Certifying Officer (CO) and bring your identification, pilot certificate, logbook/s, etc. all the usual stuff. A pretty painless process and when complete, you’ll be given a new temporary airman certificate withe the limitation removed.