Flight review required?

This came up today on askacfi.com.

Most of us have seen someone who used to fly but hasn't for years and decides to take up soaring. These people have no medical, no flight review, and no 90-day currency. They cannot fly whatever it is they used to fly, but with some - maybe a lot - of time and money they could.

The specific issue was whether a "lapsed" commercial pilot could do a glider add-on rating without getting an ASEL flight review. I was of the opinion that 61.31 lets the pilot solo as part of a training program to add an additional category/class to an existing ticket. The guy does not want to do any more powered flying.

In 2014 the FAA wrote in the Beard Letter "because this exception [not needing a flight review for solo] applies to student pilots, a pilot who holds a higher level certificate and has an endorsement for solo flight under 61..31(d) must comply with the flight review requirements in 61.56 before acting as pilot in command of any aircraft."

(Link to letter: http://www.faa.gov/about/office_org/...rpretation.pdf)

Does this mean that if an ex Air Force pilot had a military competency ticket with ME commercial and T-37, T-38, and C-17 type ratings he/she would have to find a multi-engine jet to use for a flight review before doing glider add-on training because all he/she had ever flown was multi-engine jets? Not to mention the V-22 Osprey pilot...

Based on the letter, this seems to be the case. A 14 year old could solo a glider, but not the former military pilot?

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.

It would be interesting to see if your light sport glider solution would work. I will have to research further.
You are not treating the light sport glider as an "add-on" rating. Is there solo requirements before the "check ride "?

I think it takes more than a log book endorsement for a rating, it takes an 8710-11(?) which would issue a sport pilot certificate, but that would be for someone with no pilot certificate. Yes, more research required.

For many years, many new soaring pilots have achieved their glider add-on from a "non-current" certificate. But now that some asked the question and got a "legal interpretation " now all DPEs are forwarned to check for a current flight review, that they never looked for before. Again the soaring community takes a hit.

BillT

Indeed, it appears that there is no minimum hourly requirements for an add-on Sport rating.

http://www.faa.gov/licenses_certific...ency_check.pdf

So I think the question would revolve around who is the PIC during the add-on Proficiency Check. If the PIC is the applicant, it would appear that he Beard interpretation holds, and he needs a Flight Review before taking the Proficiency Check.

61.313 identifies that the sport pilot applicant with more than 20hrs in airplane or not still requires solo time.
Are we running into the same problem with the flight review requirement?

BillT

On Wednesday, April 13, 2016 at 11:10:09 PM UTC-5, Bill T wrote:
61.313 identifies that the sport pilot applicant with more than 20hrs in airplane or not still requires solo time.
Are we running into the same problem with the flight review requirement?

BillT

I believe since the subject applicant is already a Commercial Pilot, he is not applying for a Sport Pilot certificate. So 61.313 does not apply, only 61.309 and 61.311. He would be applying for a Sport Pilot Flight Proficiency Check, not a Sport Pilot Practical Test. The sample CFI endorsement in AC 61-65F does not call out 61.313 for the Sport Pilot Proficiency Check, whereas it does for the Sport Pilot Practical Test. If this is true, then the way I read it there is no minimum flight time and no minimum solo requirement for this applicant, just the required test prep flights.

Regardless, if he is PIC during any pre-check solo, or during the Flight Proficiency Check, I believe the Beard interpretation would apply here too.

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.

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.