The “Dirty Dozen”: Airports Student Pilots Cannot Fly

So, this is a shorter little post but I wanted to complain about the seemingly common misconception that student pilots cannot fly solo within certain airspaces. Certainly, as a student who flew at a flight school located under the Boston (KBOS) Class B shelf, it is pertinent to myself.

For my entire flying career that I remember, I was always told that there are twelve airports (colloquially referred to as the “dirty dozen”, though I have also discovered this term apparently refers to human factor errors!) that student pilots cannot fly within while solo, even if given a clearance to enter.

Those airports are located within 14 CFR Part 91 Appendix D:

1. Atlanta, GA (Hartsfield-Jackson Atlanta International Airport)

2. Boston, MA (General Edward Lawrence Logan International Airport)

3. Camp Springs, MD (Joint Base Andrews)

4. Chicago, IL (Chicago-O'Hare International Airport)

5. Dallas, TX (Dallas/Fort Worth International Airport)

6. Los Angeles, CA (Los Angeles International Airport)

7. Miami, FL (Miami International Airport)

8. Newark, NJ (Newark Liberty International Airport)

9. New York, NY (John F. Kennedy International Airport)

10. New York, NY (LaGuardia Airport)

11. San Francisco, CA (San Francisco International Airport)

12. Washington, DC (Ronald Reagan Washington National Airport)

Clearly, these are some busy airports that a student pilot would be crazy to attempt to operate solo in anyways (assuming the controllers even would allow you to land!), but in addition, recreational and sport pilots also cannot operate there. It is important to remember that these only apply if the student is flying solo, as if they are with an instructor, they are flying under their instructors certificate, and are therefore not bound by student pilot limitations. And for the soon-to-be-CFIs out there, remember that if the student has any pilot license greater than a student pilot, such as a PPL or CPL in a different category or class (think commercial helicoper pilot transitioning to fixed wing), they are not student pilots, even if not rated in that aircraft, and as such, not bound by any of the student pilot limitations.

This regulation became pertinent at my training center because another student’s Designated Pilot Examiner (DPE) insisted that they wanted to see the student accept a Bravo clearance and operate within the airspace on their checkride, during the cross country portion of the practical. The CFIs were actively debating whether this was possible, questioning whether a student pilot can exercise the privileges of a Private Pilot License (PPL) on their checkride as the examiner claimed.

However, as I have discovered long after the fact, that train of thought is completely irrelevant, as the claim that student pilots cannot operate solo in these airspaces is incorrect. In fact, the regulations only prohibit operations from, to, and at the primary airport within the airspace. Specifically, those twelve listed above…

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Alright, so you have the answer to the original question, but if you want to learn more about how and why this is the case, feel free to keep reading!

To operate in these airspaces as a solo student pilot, some things do need to be done, but these are generic requirements for all Class B airspace. These are located in 14 CFR 61.95, specifically 61.95(a) which describes the requirements for a student pilot to operate within a Class B airspace:

• 61.95(a)(1): Receive ground and flight training within the specific Class B in question. The flight training can be as simple as receiving a clearance, climbing up into the airspace, and immediately leaving it.

• 61.95(a)(2): The student pilot’s logbook is endorsed with either the A12 or A13 endorsements located within AC 61.65(h). These endorsements are valid for 90 days, and must be provided by the instructor who gave the student the flight training per (a)(1).

• 61.95(a)(3): The endorsement in the logbook required by (a)(2) must specify that the (a)(1) flight and ground training requirements have been met, and the student is proficient to operate in the airspace.

It is important to notice is that 61.95(b) says “A student pilot may not operate an aircraft on a solo flight to, from, or at an airport located within Class B airspace…”, whereas 61.95(a) listed above states “A student pilot may not operate an aircraft on a solo flight in Class B airspace unless… [the required training and endorsements are completed.]”

Now, reference 14 CFR 91.131, which describes operation within Class B airspace. In 91.131(b), which describes pilot requirements to operate in Bravo, it states:

(b) No person may take off or land a civil aircraft at an airport within a Class B airspace area or operate a civil aircraft within a Class B airspace area unless—

(i) The pilot in command holds at least a private pilot certificate;

So it’s pretty clear cut that you must be a private pilot or higher to enter. However:

(iv) The aircraft is operated by a student pilot who has met the requirements of § 61.94 or § 61.95 of this chapter, as applicable.

As we established earlier, a student pilot can be trained and endorsed in that specific Class B. Yet, there are exceptions, as listed in 91.131(b)(2):

(2) Notwithstanding the provisions of paragraphs (b)(1)(ii), (b)(1)(iii) and (b)(1)(iv) of this section, no person may take off or land a civil aircraft at those airports listed in section 4 of appendix D to this part unless the pilot in command holds at least a private pilot certificate.

Those airports listed in section 4 of appendix D are those twelve listed earlier. Notice how at no point does it say that student pilots cannot operate in these airspaces, but rather that they cannot operate in the airports? Well, that is by intention!

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Hopefully you found this little retrospective into a myth that I myself believed for years to be helpful or interesting. If you’re to learn anything from this, it’s that it’s important to check the sources for yourself rather than allowing all your knowledge to come what others say!

And, hey, if you did learn something and want to learn some more, feel free to book a online private tutoring session with me, or shoot me a message as to what other topics you’d like me to tackle next. And, if you liked reading this, you can check out some other articles I’ve written below!