Flight review required?

See Advisory Circular AC61-65F Appendix 1

70. To act as PIC of an aircraft in solo operations when the pilot does not hold an appropriate category/class rating: § 61.31(d)(2).
I certify that (First name, MI, Last name) has received the training as required by §61.31(d)(2) to serve as a PIC in a (specific category and class of aircraft). I have determined that he/she is prepared to serve as PIC in that (make and model ) aircraft . Limitations: (optional).
/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-19

The Soaring Safety Foundation and local DPE's advise instructors to insert a time limit in the optional limitations. Otherwise you are signing the "student" to act as PIC in a glider for the rest of his/her life.

The local FSDO and DPE's have accepted this endorsement for experience flights and practical tests for add on ratings without having a current flight review in another category and class.

They did in the past, but now with the new legal interpretation. They cannot. The letter is very clear in that regard.
To exercise the add on under 61.31, their certificates must be current.

I agree as a CFIG, I certify that the add-on pilot knows what he needs to know to fly the glider.
Academics and pilot skills.
But the FAA has just now stated they don't trust the instructor.

BillT

Have a look at this Robinson letter.

http://www.faa.gov/about/office_org/...rpretation.pdf

Is it consistent with the Beard letter?

Yes, the Robinson interpretation is missing any reference to any required Flight Review. But it does not directly contradict the Beard interpretation.

Reading these letters is like listening to Bob Newhart talking on the phone. We only hear one side of the conversation. The results can be confusing and sometimes amusing.

Rather than mailing his ticket back to the FAA, I suggested the following: Commercial includes private and light sport privileges. Most training gliders fit in light sport. Train to proficiency with one instructor. Fly with a second instructor to add light sport glider via a log book endorsement. This could count as the flight portion of a flight review. Now, the pilot can "solo" the glider as PIC on light sport privileges, rack up 20 solos, a recommendation ride, and after a check ride be a commercial glider pilot.

So, two parts 1) is there some legitimate way around the first part of the issue? and 2) what do you think of the light sport approach if a flight review is required.

If the ultimate goal is an add-on to the Commercial Pilot level, be careful about the Flight Instructor you pick under Sport Pilot rules. If the Flight Instructor was certified under the Sport Pilot rules only, his instruction time with you does not count towards later getting the Commercial Pilot training. You have to run with a non-Sport Pilot-certified Flight Instructor instead.

Have a look at Advisory Circular 61-35F Appendix 1 issued 2/25/16.
http://www.faa.gov/documentLibrary/m.../AC_61-65F.pdf
=================================
Under Additional Endorsements
70. To act as PIC of an aircraft in solo operations when the pilot does not hold appropriate category/class rating: § 61.31(d)(2).

I certify that (First name, MI, Last name) has received the training as required by §61.31(d)(2) to serve as a PIC in a (specific category and class of aircraft). I have determined that he/she is prepared to serve as PIC in that (make and model ) aircraft . Limitations: (optional).
/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-19
================================
61.31(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must--
(1) Hold the appropriate category, class, and type rating (if a class or type rating is required) for the aircraft to be flown; or
(2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor.
================================

Mr. Bury's letter Feb 13, 2015 to Mr. Robinson states.....

"The regulations, however, permit a person who does not hold category, class,
and type ratings to act as PIC with a solo endorsement from an authorized
instructor. 14 C.F.R. §61.31(d). To receive that endorsement, a pilot must
have received the training required under part 61 "appropriate to the
pilot certification level, aircraft category, class, and type rating
(if a class or type rating is required) for the aircraft to be flown."
14 C.F.R. §61.3l(d)(2). Accordingly, you must receive a solo endorsement
under §61.31(d) to complete the pilot in command requirements for a glider
category rating at the commercial pilot level."

The FAA's Advisory Circular states endorsement 70 authorizes a pilot to act as PIC "in solo operations" and makes no reference other restrictions.
Solo is actually defined in 61.51(d).
==============================
61,51(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crew member, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.
==============================
Based on this, it appears that someone holding a pilot certificate may operate an aircraft for which he does not have a category/class rating as PIC based on 61.31(d)2 and may log it as "solo" per 61.51(d). This is in agreement with Mr. Bury's letter quoted above.

The way our local FSDO explained this when they indicated a current flight review was not required in this situation was that the training required by the endorsement in 61.31(d)2 is equivalent or exceeds the requirements for a flight review, but it cannot be called a flight review because they must be accomplished in a category and class for which the pilot holds a certificate.


If you want to read Mr. Bury's letters referenced in this thread they are available at:

http://www.faa.gov/about/office_org/...rpretation.pdf

http://www.faa.gov/about/office_org/...rpretation.pdf

Yes, but the recent release of the letter says your FSDO was wrong.

As you state was how it was always done. The CFIG endorsement under 61.31(d)(2) that the pilot knew everything needed academic and flight skills to fly a glider.
Now the letter implies that they do not trust the CFIG in his judgment.

BillT

On Friday, April 15, 2016 at 9:07:32 PM UTC-5, Glider RN wrote:
================================

Mr. Bury's letter Feb 13, 2015 to Mr. Robinson states.....

"The regulations, however, permit a person who does not hold category, class,
and type ratings to act as PIC with a solo endorsement from an authorized
instructor. 14 C.F.R. §61.31(d). To receive that endorsement, a pilot must
have received the training required under part 61 "appropriate to the
pilot certification level, aircraft category, class, and type rating
(if a class or type rating is required) for the aircraft to be flown."
14 C.F.R. §61.3l(d)(2). Accordingly, you must receive a solo endorsement
under §61.31(d) to complete the pilot in command requirements for a glider
category rating at the commercial pilot level."

The FAA's Advisory Circular states endorsement 70 authorizes a pilot to act as PIC "in solo operations" and makes no reference other restrictions.
Solo is actually defined in 61.51(d).
==============================
61,51(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crew member, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.
==============================
Based on this, it appears that someone holding a pilot certificate may operate an aircraft for which he does not have a category/class rating as PIC based on 61.31(d)2 and may log it as "solo" per 61.51(d). This is in agreement with Mr. Bury's letter quoted above.

The way our local FSDO explained this when they indicated a current flight review was not required in this situation was that the training required by the endorsement in 61.31(d)2 is equivalent or exceeds the requirements for a flight review, but it cannot be called a flight review because they must be accomplished in a category and class for which the pilot holds a certificate.


If you want to read Mr. Bury's letters referenced in this thread they are available at:

http://www.faa.gov/about/office_org/...rpretation.pdf

http://www.faa.gov/about/office_org/...rpretation.pdf

If you look in the first paragraph of the Robinson interpretation, you see:

"You have asked for clarification on how to accomplish pilot-in-command (PIC)time in gliders to meet the aeronautical experience requirements for a glider category rating at the commercial pilot certificate level."

The way I read this, Bury is narrowly spelling out what the letter is about.. Notice that he is not responding to a request about the Flight Review requirement but only addressing how Robinson can accomplish PIC time in gliders. I still believe this does not contradict the Beard interpretation, but it certainly does confuse us all.

The SSA is working through this issue, and hopefully we'll see this fixed by the end of April.

The SSA is working through this issue, and hopefully we'll see this fixed by the end of April.

This is correct. The Soaring Safety Foundation chairman has taken the lead by direction of the SSA Board.
Progress has been made. Expect to have this rectified and that's the response from the FAA to us.
End of April may be optimistic. Patience is required when working with the government but they are being responsive on the highest level.

Update from our SSA Board Chairman Ken Sorenson and Soaring Safety Foundation Chairman Rich Carlson on the SSA website: http://www.ssa.org/GeneralNews?show=blog&id=4139