Anyway, I ended up getting a Special Issuance Class 1 after some paperwork back and forth with the FAA. My question is does a Special Issuance degrade the same way as a "standard" issued license does? I do not need a Class 1 right now and I am wondering if I can just let it downgrade to a Class 2 (eventually to a Class 3) without any repercussions.
Most Authorizations are valid for 12 months or so. I say "or so" because the first time the FAA reviews medical records for special issuance, it takes MANY months for the case to be resolved. (That's another discussion, totally!), That airman who is maintaining a first class for ATP privileges or because of employer requirements would still return to the AME for another First Class physical after six months, and the AME would be authorized to reissue a new certificate valid for another six months if the application is otherwise qualified and is complying with all the requirements of the Authorization.
For second and third class, normally valid for 12, 24, or 60 months, depending upon age, the one year authorization will coincide with the month of examination and the required follow up reports will be due after twelve months, The difference being that the first class pilot will get to go to the AME after the first six months and will be reissued but won't have to provide any specialty reports until the NEXT exam, 12 months after the special issuance is granted.
The key point is that the medical issued under an Authorization does NOT lapse to the lower class as does a "regular" medical issued under the other sections of Part 67 and 61.23. The Authorization is a discretionary issuance and subject to any restrictions or limitations explained in the Authorization letter.
The FAA doesn't always do a great job of explaining the requirements and limitations of an Authorization in the letter that accompanies the medical certificate, but after two or three close, careful reads of the letter, it makes more sense.
Sorry for the hefty response, but context is always important!
I appreciate the response 👍
Special Issuances do not downgrade. They are only issued for the class that you have applied for. The authorizations are usually only valid for one year and require annual documentation to renew. If you have any other questions please give us a call here at 1-800-872-2672.
Boomer At AOPA:
Special Issuances do not downgrade. They are only issued for the class that you have applied for.
A First Class Special Issuance is only valid as First Class for six months. If that "not valid after" date is only six months from the exam date, then yes, it's no good for anything after six months. But if the "not valid for any class after" date is the typical SI one year, it's still good as a Second Class for another six months, after which it's invalid even as a Third. Read what it says on the certificate!
Boomer At AOPA:A first class can be issued where they are only required to supply information once a year. However, it can't downgrade to a lower class, as that would invalidate the restriction on the certificate.
Sorry -- I was living in my over-40 world. Yes, if you're under 40 when you get the SI First Class with a one-year limit, it remains valid for First Class privileges for the full 12 months. However, for old farts like me (i.e., over 40 when we take the exam), it's only valid for First Class (ATP) operating privileges for six months. After that, even though it's still technically a First Class medical certificate, it's good only for Second Class (Commercial) operating privileges for the next six months. Either way, after 12 months, that 12-month-limit SI medical turns into a pumpkin. See the table in 14 CFR 61.23(d) for details.
Boomer At AOPA:
It still would not downgrade to a 2nd class after the first six months. After the first six months he would still need to have a new physical for a 1st class medical. He still would only need to provide the Special Issuance requirements on an annual basis.
I think you should review 61.23(d). Unless that SI First Class says "Not valid for any class after [six months]"...
- For an under-40, it remains valid for ATP privileges for a full 12 months without a new physical.
- For an over-40, it is valid for ATP privileges for six months only, but remains valid for Commercial privileges for another six months without further ado, although a new exam and First Class issuance would be required to keep exercising ATP privileges for the second six months.
Or do you have written FAA guidance which overrides 61.23(d) on this matter?
BTW, I hope we're not just quibbling over semantics. Yes, a First Class medical certificate is still a First Class medical certificate no matter how old it is. Time doesn't change that paper into a Second or Third Class certificate. However, the pilot privileges which may be exercised on its basis do degrade with time according the schedule in 61.23(d). As such, pilot over 40 at examination can only use a First Class medical certificate for 6 calendar months to exercise ATP privileges, but can still use that certificate to exercise Commercial privileges for another six months without any further exam or issuance. Likewise, a pilot under 40 at examination can (unless there's an additional limitation, like the one under discussion), can use a First Class medical certificate for ATP or Commercial privileges for 12 months, and then for Private privileges all the way out to 60 months. Again, it's still a First Class certificate, although the privileges which may be exercised on its basis degrade with time.