Flight review required?

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.

On Thursday, April 14, 2016 at 6:43:04 PM UTC-6, tomcatvf51 wrote:
Your lapsed commercial pilot does not need a Flight Review in a ASEL.
The Beard letter applies to a pilot attempting to use the student pilot
flight review exemption to not do a Flight Review in another aircraft he
or she is rated to fly as a PIC.

The Beard letter also says that you do not need a student pilot
certificate once you have a rating in another aircraft. Training and an
endorsement is required before solo.

A person needs at least an appropriate rating to log PIC time.




--
tomcatvf51

I haven't read the Beard letter,
However the understand/interpretation has always been that holding a certificate at any level is the same a holding any lessor certificate.

ie. if you have a commercial certificate you can use it to exercise the privileges of a Private, Recreational, Sport or Student Certificate.

Again without having read the interpretation, it may be entirely possible that one can not utilize 61.31(d) without a current flight review. However I see no reason why one could not utilize their Student Pilot Privileges that are included with their commercial certificate. It just means the instructor will have to sign them off as if they were a new student, instead of using solo privileges under 61.31(d)

just my 2 cents worth. if worth that much.

Brian

Don't think that works, if you hold a certificate you are never a student pilot. Hence solo endorsements don't self expire and the xc distance student pilots(power) can fly without an endorsement also doesn't apply to rated transition pilots. Flight Reviews or surrenduring their current certificate seem the only options at the moment. It is an unfortunate declaration.

Sorta seems like rules that only a lawyer can understand....only on some days, depends on the wind and moon...... As an ex CFIG, I used to say to students, "The rules are easy, the exceptions are a PITA."

It really sucks that it's this hard to figure out. Especially when when FSDO may say it's fine and another bounces you.
Even the FAA seems to have issues with its own rules.........

I have a feeling it's not hard to understand the rule, only hard to find "common" sense in it sometimes. The requirement that a flight review is required if a pilot is to fly as PIC is pretty straightforward and plain. But, when it is an impediment for a non-current, certificated pilot who is training for a new category the rule can appear to be unreasonable. I have a feeling too that this is a circumstance the FAA folks had not thought about before. I sure could be wrong though.

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

Playing devil's advocate, there is a reasoning behind a Flight Review requirement.

For example, if you do the add-on category for Glider, you are not required to pass another knowledge test if you hold Airplane or Helicopter category ratings. Further, there are portions of the practical test which are skipped: Knowledge of Certificates and Documents, Cockpit Management, Airport Operations (except Traffic Patterns), and Navigation (including Airspace) to name a few.

That, plus as was mentioned, an add-on solo endorsement could last forever.

So, if you have not flown in quit a while, and the rules are changing all the time, the only way the FAA can be sure that you are up to snuff on rules and procedures is if you have had a recent Flight Review.

What would work better is if only the ground portion of the Flight Review would be required for the add-on situation because the above missed bits are covered in that part.

The whole Flight Review bit is weird anyway because a strictly CFI-G, who has no knowledge multi-engine Airplanes, could sign you off in your Glider Flight Review, and you could then immediately legally climb into a King Air and fly away, even though you have not touched one in 50 years. Of course we assume here you are already rated in both category and class of the respective aircraft (Glider and AMEL).

Yes, common sense missing all around. Wait...I think Bob Newhart is calling me...

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.

Bill T says the FAA does not trust the instructors judgement. Have no idea, but the instructor can sign off a certificated pilot without a glider rating to act as PIC per FAA AC 61.31(d).

Agree with most of N97MT's comments. I would claim a devils advocate option on the statements about the glider applicant having a flight review to climb in his King AIr. The CFIG endorsing per AC61.31(d) is authorizing PIC operation of a glider only if that is what he fills in. It is not a flight review. The CFIG can restrict the time of the endorsement as has been recommended by the SSA for quite some time. This endorsement is not a flight review. It just lets the applicant go fly the glider legally.

The example cited becomes more of a concern to the FSDO Inspector or DPE if they issue a glider rating for his certificate. The new rating counts as a flight review and so he can go drag out the King Air and be legal if not smart.

However this is not much different than the issue a CFI faces if a pilot with a glider rating and a MEL rating on his certificate comes in for a flight review in a glider. The CFI may not even be rated for Airplanes, but the flight review in the glider opens the gate for the glider and the King AIr. This has never made sense.