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The material consolidates answers attributed to John Lynch (AFS-840 Certification Branch) and maintained by the Pilot Examiner Standardization Team (AFS-640). It includes FAA legal interpretation letters and explains meanings such as “24 calendar months,” “within the preceding 24 months,” and “24 months after or from,” with examples showing start and end dates.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":20,"@type":76,"position":81},"https://docshare.wps.com/document/exam/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/frequently-asked-questions-14-cfr-part-61-arranged-by-section/388817/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/frequently-asked-questions-14-cfr-part-61-arranged-by-section/388817.png","ImageObject",300,407,{"name":92,"@type":93},"Mia  ","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-29","2026-09-25",true,{"@type":102,"interactionType":103,"userInteractionCount":14},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What does “24 calendar months” mean under 14 CFR Part 61?","Question",{"text":112,"@type":113},"The answers state that “24 calendar months” means 24 unit months, and that “24 months” means two years, citing FAA legal interpretations referencing §61.19(b) and §61.58(g).","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"How should “within the preceding 24 months” be interpreted for compliance?",{"text":117,"@type":113},"For compliance under a regulation requiring action “within the preceding 24 calendar months,” the guidance states the individual has from the beginning of the 24th calendar month of the month in which compliance is required, with an example tied to §91.411.",{"name":119,"@type":110,"acceptedAnswer":120},"Can an instructor rely on renewal documentation instead of physically possessing the certificate?",{"text":121,"@type":113},"The material answers that, during the processing period, using a copy of the old CFI certificate and a copy of the completed FAA form 8710-1 is acceptable, referencing §61.3(d)(1) and relevant FAA rulemaking context.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},388817,1790604146,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":19,"category_name":20,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":14,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":139,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},687207024478,"https://ap-avatar.wpscdn.com/davatar_a8503ba1806abce46bf441b54a3ca4cd","FREQUENTLY ASKED QUESTIONS  \n14 CFR, PART 61  \nARRANGED BY SECTION  \nTHE SOURCE OF ANSWERS IS JOHN LYNCH, AFS-840 CERTIFICATION BRANCH, WASHINGTON, DC UNLESS OTHERWISE NOTED  \nMAINTAINED BY THE PILOT EXAMINER STANDARDIZATION TEAM, AFS-640  \nContact: Allan Pinkston phone: (405) 954-6472  \nE-Mail: [K.Allan.Pinkston@faa.gov](K.Allan.Pinkston@faa.gov)  \nTHE ORIGINAL “Q&A” REFERENCE IS NOTED FOLLOWING EACH (GROUP OF) QUESTION (S)  \n\n| | CHANGE NOTICE: |  | |\n| --- | --- | --- | --- |\n| REVISION DATE:  DECEMBER 19, 2000 INCORPORATING Q&A \\#s: 404-412\u003Cbr>WITH ALL PREVIOUS Q&As 1-403\u003Cbr>VERTICAL BAR IN LEFT MARGIN DENOTES CHANGES SINCE:  10/27/2000\u003Cbr>CHANGES HAVE BEEN MADE TO Part 61 sections: 61.3, 61.49, 61.56, 61.58, 61.71,\u003Cbr>61.73, 61.75, 61.109, 61.153,\u003Cbr>TO UPDATE YOUR FAQs\u003Cbr>CURRENTLY: [http://afs600.faa.gov](http://afs600.faa.gov) Select: AFS-640; Then select: Designee Seminars;\u003Cbr>Then select: DPE; Finally select: FAQ\u003Cbr>CHANGE EXPECTED IN FEBRUARY: |  |  |  |\n| | [http://av-info.faa.gov](http://av-info.faa.gov) | Select: “Designee Information” for dropdowns that will include the “FAQ’s” | |\n\nFAQs Part 61 With Chg \\#14, 12/19/2000 All Q&A’s from \\#1 through \\#412  \n\n| \u003Cbr>PART 61 | |\n| --- | --- |\n|  |  |\n\n61.1  \nQUESTION: Explain the meaning of the phrases:  \na. Does the meaning of“24 calendar months” mean two years,(e.g. January 15, 1997, to January 15, 1999)?  \nb. Does the meaning of “24 calendar months” mean 24 unit months,(e.g. regardless ofthe day in January 1997, to January 31, 1999)?  \nc. How to interpret the meaning of“within the preceding 24 months?”  \nd. How to interpret the meaning of“24 months after or from?”  \nANSWER: Ref. §61.19(b) and §61.58(g); Letter of legal interpretation from the  \nFAA’s Office of Chief Counsel addressing these questions are as follows:  \nMr. Sean Conlin  \nQuality Assurance  \nPan American Airways Corp.  \n14 Aviation Avenue  \nPortsmouth, NH 03801  \nDear Mr. Conlin:  \nI am responding to your letter dated September 15, 1999, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding the meaning of“within the preceding 24 calendar months.”  \nYou state in your letter that two interpretations exist within the industry regarding the meaning of“24 calendar months.” One interpretation is that it means two years, e.g.  \nJanuary 15, 1997, to January 15, 1999. The second interpretation is that it means 24 unit months, e.g. regardless ofthe day in January 1997, to January 31, 1999. You state that your local Flight Standards District Office (FSDO) believes the second interpretation, 24 unit months, to be correct. You ask this office to confirm this before you change your policy.  \nThe term “24 calendar months” as used throughout the Federal Aviation Regulations (14 CFR) means 24 unit months. The term “24 months” means two years.”  \nIf you are required to comply with a regulation under 14 CFR “within the preceding 24 calendar months,” you have from the beginning of the 24th calendar month of the month in which you are required to comply. For example, §91.411 (14 CFR §91.411) requires certain altimeter system and altitude reporting equipment tests and inspections to have  \nFAQs Part 61 With Chg \\#14, 12/19/2000 All Q&A’s from \\#1 through \\#412  \nbeen accomplished “within the preceding 24 months” before a person may operate an airplane or helicopter in controlled airspace under IFR. Therefore, if you want to operate an airplane in controlled airspace under IFR on January 15, 2000, you must have, since January 1, 1998, met the requirements of §91.411(a) .  \nIf you are required to comply with a regulation under 14 CFR “24 calendar months after or from,” you have until the end of the 24th month after the month in which the time began to run. For example, §61.19 (14 CFR §61.19) provides an expiration date for a student pilot certificate of 24 calendar months from the month in which the student pilot certificate is issued. Therefore, if you obtain a student pilot certificate on Ja","cbCaivFPFwZOQhXB","https://ap.wps.com/l/cbCaivFPFwZOQhXB","pdf",217225,68,"English","# 61.1\n## Meaning of “24 calendar months” and related timing phrases\n# 61.3\n## Renewal process and physical possession of certificates","[{\"question\":\"What does “24 calendar months” mean under 14 CFR Part 61?\",\"answer\":\"The answers state that “24 calendar months” means 24 unit months, and that “24 months” means two years, citing FAA legal interpretations referencing §61.19(b) and §61.58(g).\"},{\"question\":\"How should “within the preceding 24 months” be interpreted for compliance?\",\"answer\":\"For compliance under a regulation requiring action “within the preceding 24 calendar months,” the guidance states the individual has from the beginning of the 24th calendar month of the month in which compliance is required, with an example tied to §91.411.\"},{\"question\":\"Can an instructor rely on renewal documentation instead of physically possessing the certificate?\",\"answer\":\"The material answers that, during the processing period, using a copy of the old CFI certificate and a copy of the completed FAA form 8710-1 is acceptable, referencing §61.3(d)(1) and relevant FAA rulemaking context.\"}]","FREQUENTLY ASKED QUESTIONS - 14 CFR - PART 61 - Arranged by Section | PDF",1790310537,171]