If you are monocular, if one of your eyes is truly or legally blind or has a substandard vision, due to a condition, like an amblyopia, but you still want to be a commercial pilot and obtain Class 1 Medical certificate in the USA, please proceed further.
If you haven’t already done so, please first read the introduction and learn about my eye-sight condition first, to understand the situation and assess if it’s relevant to you.
| Class 1 | Monocularity or Substandard Vision in One Eye |
|---|---|
| Visual acuity of the “bad” eye | Below corrected 6/6 (excl.) |
| Initial issue | 🟢possible |
| Revalidation / Renewal issue | 🟢possible |
If you researched the topic, you probably already know about the USA. You will find lots of evidence on the Internet of pilots successfully completing the review process and being granted a Class 1 with all kinds of a single eye dysfunction. Ceteris paribus, in the USA you can fly commercially even if you’re truly monocular / completely blind in one eye!
The position of the FAA is identical to the position of ICAO: that binocular vision is not a pre-condition for safe flying. But they do want to see that, you personally are safe to fly.
In terms of the process, the FAA doesn’t seem to make a distinction between substandard and monocular applicants. Every applicant who’s unable to achieve visual acuity of 1.0 (6/6, or 20/20) in each eye separately for any reason (CFR § 67.103), may apply for so-called special / discretionary issuance of a medical certificate (CFR § 67.401).
Special Issuance and Special Medical Flight Test
Here is the process you are likely to face if your condition is similar to mine.
(1) Apply for Medical Class 1 and visit an AME like you would do normally. Obviously, your AME is not going to grant you a medical certificate upon completion of the examination. They will defer your case to the FAA Aerospace Medical Certification Division in Oklahoma for further review.
(2) Some time after that, the FAA will contact you and ask to do an eye evaluation and to have a Form 8500-7 filled. Any English-speaking eye doctor (doesn’t have to be an American one) can do that after inspecting your eyes: there’s no rocket science there. The form needs to be submitted back to the FAA.
TIP: I realized that this form could have been filled in by an eye doctor prior to medical examination at AME’s office and submitted together with the rest of medical paperwork to the FAA, if I knew it would be necessary. It wouldn’t have hurt if it turned redundant or incorrect, but would have saved several months otherwise.
TIP: You can communicate with the FAA directly. You don’t necessarily have to do so through your AME. In my case, that was very handy, as my AME was slowing things down for some reason and eventually stopped reacting to any communication whatsoever.
(3) If the report is satisfactory, the FAA will reach out to you again and suggest a special medical flight test (SMFT). This is a flight onboard a training aircraft conducted under supervision of the FAA Aviation Safety Inspector (ASI) or, since recently, an authorized designated pilot examiner (DPE). The purpose of a SMFT is to give a candidate an opportunity to demonstrate that his health defect is unlikely to affect the safety of flight. You have to arrange a SMFT yourself in consultation with an ASI/DPE from a regional FSDO of your choice. In response to the FAA, you have to let them know if you want to undergo an SMFT and, if so, mention the FSDO you are choosing.
(4) Once the FAA receives your FSDO preference, they will send you a Letter of Authorization (LoA). A LoA auhorizes you to participate in a SMFT with an ASI or DPE from the chosen FSDO within 6 months from the date of the letter. You can’t do a SMFT with an ASI / DPE from any other FSDO. For that, you will need another LoA.
There is no apparent limit on how many times you can apply for a LoA. As I applied from Europe and was subject to COVID-19 border and consulate closures (needed a visa to travel to the USA), I could not travel to the USA to fly a SMFT. The travel was necessary as there are no overseas ASIs (and there were no authorized overseas DPEs back then). So, I asked the FAA at least 3 times to re-issue a LoA, explaining the reasons. Never had any issues with that.
(5) Contact your FSDO and discuss what is needed to arrange a SMFT. The documents, aircraft requirements, desired dates and locations, you name it! That’s where your experience might start getting drastically different from mine. I found it useful to communicate with the US flight school and ASI simultaneously, due to so many interconnected arrangements required!
(6) Arrange an aircraft and schedule your SMFT. The FAA doesn’t have their own fleet or flight schools. The inspector may, upon mutual agreement with you and the aircraft owner (if that’s not you, but e.g., a flight school), visit your base airfield. Or you may have to fly to a location of their choice.
(7) Fly a SMFT. Make sure to bring all the paperwork. The inspector will let you know what’s needed, of course, but you may expect at least the following:
- Letter of Authorization from the FAA
- Your FAA student / pilot certificate (if you don’t have one, make sure you obtain it well in advance, as it also takes time to be issued)
- Your ID / Passport
Also, make sure that all the aircraft’s paperwork is in order as well.
During the flight, the inspector expects you to demonstrate certain tasks pertinent to flying and to your health defect. That’s the syllabus that was applicable to my situation:
Observe an applicant with a visual defect (one eye missing or one eye blind) demonstrate the following in an aircraft:
- The ability to select emergency landing fields at a distance, from high altitude, and preferably over unfamiliar terrain.
- The ability to simulate forced landings in difficult fields; note the manner of approach, rate of descent, and comparative distance at which obstructions (stumps, boulders, ditches, etc.) are recognized.
- The ability to recognize other aircraft (which may be present by prearrangement) approaching at a collision course (particularly aircraft approaching from the far right or far left).
- The ability to judge distances and to recognize landmarks (compared with the ASI’s estimate).
- The ability to land the aircraft.
- The ability to read aeronautical charts in flight and tune the radio to a predetermined station accurately and rapidly.
- The ability to read instrument panels (including an overhead panel, if any) quickly and correctly.Generally, you are not expected to act as PIC during this flight. After-all, even a pre-solo student might be required to undergo a SMFT. In my case, the inspector was acting as PIC. For me, it was of no difference to a regular training flight under instruction.
Certain online evidences suggest that people had various experiences on this aspect. Like, sometimes a candidate acted as PIC, or, if unable, an instructor was onboard as well (so there had to be at least 3 persons onboard, and a suitable aircraft was needed).
Upon completing the flight, your inspector will forward his observations to the FAA for the final review.
Worth noting is that if you are flying with an ASI, SMFT service is going to be free of charge. You only pay for the costs of a flight (fuel, rent, etc.), but not for the ASI’s duty time. That’s not the case with DPEs, though.
(8) If everything goes well, after some while (3 months in my case) you will receive two documents: a hard-earned Medical Certificate Class 1 and a Statement of Demonstrated Ability (SODA). A SODA may be time-framed or permanent, if the condition is non-progressive (which is, for the most monocular people). You are expected to carry SODA together with your Medical Certificate at all times and present it on every subsequent medical examination.
Congratulations! You may now pursue your commercial pilot license!
Final Tip
Please allow plenty of time to complete the process.
Each step took me several months. The FAA communicates solely by post or by fax. There’s no publicly known e-mail to reach to them. As I applied from Europe during COVID-19 times, an average turnaround time with the FAA was even longer for me (about 2-3 months).
If you’re a member of American AOPA, you may use their medical status check, document review and personal advocacy services. They helped me once to figure out the status of application once the FAA took way too many months to react, and I started to think that my post was lost. It took AOPA just a few days to get back to me with the status from the FAA.
In total, it took me a long 2.5 years to complete the whole thing. In fact, once I got my medical and SODA, the Class 1 arrived expired as it is only 1 year valid since the examination date. But it could have taken significantly less if I resided in the USA and if I haven’t been affected by COVID-19 disruptions.
The good news is that I don’t have to go through all the hurdle never again, as the condition is not progressive.
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