Flight review required?

[Terry Pitts]

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/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/beard%20-%20(2015)%20legal%20interpretation.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.

[Bill T]

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

[N97MT]

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

http://www.faa.gov/licenses_certificates/airmen_certification/sport_pilot/media/proficiency_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.

[Bill T]

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

[N97MT]

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.

[tomcatvf51]

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.

[Glider RN]

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.

[Bill T]

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

[Glider RN]

Have a look at this Robinson letter.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/robinson%20-%20%282015%29%20legal%20interpretation.pdf

Is it consistent with the Beard letter?

[N97MT]

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.

[N97MT]

>
> 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.

[Brian[_1_]]

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

[[email protected]]

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.

[Charlie M. (UH & 002 owner/pilot)]

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.........

[Jim Lewis[_2_]]

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.

[Glider RN]

Have a look at Advisory Circular 61-35F Appendix 1 issued 2/25/16.
http://www.faa.gov/documentLibrary/media/Advisory_Circular/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/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/robinson%20-%20%282015%29%20legal%20interpretation.pdf

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/beard%20-%20%282015%29%20legal%20interpretation.pdf

[N97MT]

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...

[Bill T]

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

[N97MT]

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/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/robinson%20-%20%282015%29%20legal%20interpretation.pdf
>
> http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/beard%20-%20%282015%29%20legal%20interpretation.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.

[Glider RN]

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.

[Burt Compton - Marfa Gliders, west Texas]

> 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.

[Bill T]

RN, I agree, the CFIG under 61.31 is only endorsing a rated pilot to fly a glider as PIC in solo operations, not provide a flight review for that pilot to go fly his king air. But the FAA is telling us that an airplane qualified rated pilot must have a flight review in airplane before we can use 61.31 for his glider PIC solo operation toward a rating. The FAA is not trusting that with our endorsement under 61.31 we would have reviewed all current regulations, airspace requirements, and glider flight skills for his PIC glider only flights.

Burt, we hope that the SAA and Safety Foundation can quickly resolve this. I have a "student" under 61.31 that is now grounded based on the legal interpretation in that letter until he can get an airplane flight review. He has no medical and has not flown powered airplanes for 17 hrs. He was back into flying with his son's interest in learning to fly and both were quickly advancing toward dual check rides this spring.

BillT.

[Robert Ballou]

On Friday, April 15, 2016 at 8:54:16 PM UTC-7, Glider RN wrote:
> 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.

Well, sort of. Now that this pilot has his glider add on and therefore re-started his flight review 2 year cycle, he now has to comply with 61.57(a). It clearly states, "The required [3] takeoffs and landings were performed in an aircraft of the same category, class, and type . . . ." This hypothetical King Air and glider are different categories (see Part 1, "catagory (1), examples"). Three landings in a glider does not make one current in airplanes or vice versa for that matter. Okay, so there is one more hurdle to overcome but still it is not a roadblock. My advice is for everyone to keep the keys to their King Air well hidden!

[Bill T]

Robert, with a new completed glider rating, he can go do those King Air landings (and takeoffs) solo before carrying passengers.
No more instruction required according to the FARs.

BillT

[Burt Compton - Marfa Gliders, west Texas]

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

[Bob Pasker]

On Friday, April 15, 2016 at 10:10:00 PM UTC-4, N97MT wrote:
> 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).

This has always been true.

The flight review is a review for your *certificate*, not of your ratings:

61.56(a)(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.


BTW, I am one of those people who solo'd gliders with a Commercial certificate and no flight review before passing the checkride.

--bob

[Bob Pasker]

61.57(a) is clearly ONLY for carrying passengers.

with a flight review in gliders, you can solo that King Air 350 all you want. you can even do 3 touch and goes, fill it with passengers, and take them on a nice jaunt.

--bob


------------------------------------------------------------------
> Well, sort of. Now that this pilot has his glider add on and therefore re-started his flight review 2 year cycle, he now has to comply with 61.57(a).. It clearly states, "The required [3] takeoffs and landings were performed in an aircraft of the same category, class, and type . . . ." This hypothetical King Air and glider are different categories (see Part 1, "catagory (1), examples"). Three landings in a glider does not make one current in airplanes or vice versa for that matter.

[[email protected]]

Terry said "Most training gliders fit in light sport.". The 2-33 certainly does, but the Blanik L-23 or the Ask 21 does not due to Vne - or am I missing something?

[Bruce Hoult]

On Friday, April 22, 2016 at 1:05:28 PM UTC+12, wrote:
> Terry said "Most training gliders fit in light sport.". The 2-33 certainly does, but the Blanik L-23 or the Ask 21 does not due to Vne - or am I missing something?

Light Sport Aircraft have a 120 knot limit on speed in level flight. NOT a limit on Vne (that I can see).

Gliders can't do level flight at all.

[Bill T]

Light sport aircraft directly limits gliders to a Vne of 120kcas to qualify as light sport.

BillT

[Jim Lewis[_2_]]

On Thursday, April 21, 2016 at 6:05:28 PM UTC-7, wrote:
> Terry said "Most training gliders fit in light sport.". The 2-33 certainly does, but the Blanik L-23 or the Ask 21 does not due to Vne - or am I missing something?

It is kind of a curious circumstance with the ASK-21. The POH specifies a max all-up weight of 1320 lbs - on the button for the max weight of a light sport aircraft, but the Vne is specified as 151 kts.. - more than a little faster than the 120 kts. Vne the FAA (14 CFR 1.1) limits a light sport aircraft to.

[N97MT]

As well, the Grob 103 does not qualify as Light Sport due to too high of a stall speed with the spoilers extended.

Aside from the 2-33, I have not yet seen a popular training glider that fits into Light Sport.

[Bruce Hoult]

On Friday, April 22, 2016 at 6:11:19 AM UTC+3, Bill T wrote:
> Light sport aircraft directly limits gliders to a Vne of 120kcas to qualify as light sport.

Seems very inconsistent, as I don't recall a Vne limit for non-gliders.

In any case, what is to prevent you from simply re-placarding your glider to a 120 knot Vne?

[[email protected]]

120 knots is not Vne for Light Sport. The limit is 120 kts max speed in level flight (Vh). I believe this is also at sea level on a standard day. Vne is probably tailored to the individual aircraft model accounting for structural and flutter concerns.

[[email protected]]

This is a direct copy from 14 CFR 1.1 under the definition of Light Sport Aircraft:

(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS for a glider

[Bruce Hoult]

On Saturday, April 23, 2016 at 3:07:43 AM UTC+12, wrote:
> 120 knots is not Vne for Light Sport. The limit is 120 kts max speed in level flight (Vh). I believe this is also at sea level on a standard day. Vne is probably tailored to the individual aircraft model accounting for structural and flutter concerns.

That's what I said.

[Jim Lewis[_2_]]

Yes, that's what you said but it is still not correct. 120 kts. is the specified Vne for Light Sport aircraft. See 14 CFR 1.1.

[[email protected]]

Here is the link to 1.1

http://www.ecfr.gov/cgi-bin/text-idx?rgn=div8&node=14:1.0.1.1.1.0.1.1


See the entire definition of Light Sport Aircraft, specifically item 3 under the definition.

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

(1) A maximum takeoff weight of not more than--

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or

(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.

(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.

(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS for a glider.

(4) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 knots CAS at the aircraft's maximum certificated takeoff weight and most critical center of gravity.

(5) A maximum seating capacity of no more than two persons, including the pilot.

(6) A single, reciprocating engine, if powered.

(7) A fixed or ground-adjustable propeller if a powered aircraft other than a powered glider.

(8) A fixed or feathering propeller system if a powered glider.

(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyroplane.

(10) A nonpressurized cabin, if equipped with a cabin.

(11) Fixed landing gear, except for an aircraft intended for operation on water or a glider.

(12) Fixed or retractable landing gear, or a hull, for an aircraft intended for operation on water.

(13) Fixed or retractable landing gear for a glider.

[Vaughn Simon[_2_]]

On 4/22/2016 9:08 AM, Bruce Hoult wrote:
> In any case, what is to prevent you from simply re-placarding your glider to a 120 knot Vne?

Because the FAA already thought of that dodge! Notice the words "since
its original certification" in the excerpt below.

"Light-sport aircraft means an aircraft, other than a helicopter or
powered-lift that, since its original certification, has continued to
meet the following:"

Now if you are certifying a new glider, I see nothing stopping you from
doing something like that. In fact, I think it happens every day in the
Light Sport world. That explains how they can sell a 2-seat Light Sport
airplane that (on paper) has barely enough useful load to carry one
USA-sized pilot. Obviously there is an official gross weight, and
another, higher "wink wink" gross weight.

[Jim Lewis[_2_]]

On Friday, April 22, 2016 at 9:37:04 AM UTC-7, Jim Lewis wrote:
> Yes, that's what you said but it is still not correct. 120 kts. is the specified Vne for Light Sport aircraft. See 14 CFR 1.1.

On the other hand, the POH for the ASK-21 and for the DG500 both indicate that the Vne is rather like a TAS, so the Vne CAS decreases with altitude. The 120 kts. Vne limit for Light Sport Aircraft (14 CFR 1.1) is a CAS.

[Bruce Hoult]

On Saturday, April 23, 2016 at 2:33:15 PM UTC+12, Jim Lewis wrote:
> On Friday, April 22, 2016 at 9:37:04 AM UTC-7, Jim Lewis wrote:
> > Yes, that's what you said but it is still not correct. 120 kts. is the specified Vne for Light Sport aircraft. See 14 CFR 1.1.
>
> On the other hand, the POH for the ASK-21 and for the DG500 both indicate that the Vne is rather like a TAS, so the Vne CAS decreases with altitude. The 120 kts. Vne limit for Light Sport Aircraft (14 CFR 1.1) is a CAS.

It's all rather ridiculous.

The normal cruising speed for gliders is 60 - 80 knots. Even if you have a 160 knot Vne, you very rarely go over 100 knots. The Vne is there mostly for safe recovery from upsets.

Penalizing pilots for buying a safer, stronger aircraft is crazy.

[Terry Pitts]

So, doesn't this work:

Commercial includes light sport.

Train to proficiency with a CFI-G in a 2-33. Pass a proficiency check with a different CFI-G - this doesn't count as a flight review, but the commercial pilot is now cleared to utilize his/her light sport privileges in a glider as soon as she/he completes a Flight review with any CFI-G.

This probably requires five or six more dual flights than otherwise required to solo, but that's not the worst thing in the world. It's still glider flight training which is eminently more useful in the case I shared than getting power current.

At a place doing a couple weekend add-on, some of this could likely even count as the recommendation flights for the commercial checkride and not really be much of a burden at all.

If the SSA can't work this out with the FAA, will 2-33's suddenly become more valuable?

Break, break.

Did you see the AOPA story about the 16 year old who soloed a single engine airplane a few minutes after midnight the day he turned 16? Later that day he soloed a twin engined airplane and a glider. All with just a student pilot certificate. However, a lapsed pilot can't solo a glider in an add-on program.

[[email protected]]

Terry - I absolutely think that's the interim path until the FAA goes through rule making to fix the core issue of rated pilots not being able to solo a glider without a flight review in an aircraft for which they hold a rating.

1 - Train to proficiency IAW the Light Sport Glider PTS in the 2-33 and get an instructor recommendation to take the proficiency check. Get the appropriate endorsement in the logbook and sign off on form 8710-11.

2 - Successfully pass a proficiency check in the 2-33 with another instructor to the Light Sport Glider PTS and get the appropriate logbook endorsement and signature on the 8710-11.

3 - The instructor that completed the Proficiency Check sends the 8710-11 to Oklahoma City.

4 - Complete a flight review in the 2-33 with any instructor.

5 - At this point, one should be able to get a solo endorsement in any glider that they are training in as the Flight Review requirement has been met and they are training for an additional category to add to their Private, Commercial, or ATP certiciate.

It would be interesting to hear a DPEs thoughts on this.

[N97MT]

>
> 2 - Successfully pass a proficiency check in the 2-33 with another instructor to the Light Sport Glider PTS and get the appropriate logbook endorsement and signature on the 8710-11.
>

Who is the PIC during the Sport Pilot proficiency check? Is it the applicant or the check instructor?

If the applicant is the PIC, he will need a Flight Review before doing this, because according to the Beard interpretation, he needs a Flight Review before acting as PIC.

I too would like to hear from a DPE or FSDO on this.

BTW no one has mentioned the FAA Wings Program in lieu of a Flight Review. I think that is the cryptic "For questions, and to discuss possible approaches for dealing with this, please contact SSA Chairman Ken Sorenson at " on the SSA page.

So I would also like to hear someone comment here about the FAA Wings Program path to clear the air on this.

Burt????? Please chime in Sir!

[Bill T]

Doesn't the Sport Pilot require solo time in the glider prior to the double instructor sign off on the 8710-11? How does he do that without a flight review?
Because when it comes down to the bottom line, he is still a rated pilot doing an add-on, solo time, in an aircraft he is not rated for, even if the rating in Sport Pilot, Private, or Commercial.

Questions still need deeper research.

BillT

[[email protected]]

I'm assuming this discussion is about an airplane (or other non-glider) pilot who has chosen not to renew a medical for some reason, and is now also more than 24 months since the last flight review.

Best I can tell, there is no requirement that a person receiving a flight review must be legal to fly as PIC in the airplane (have a current medical). So as long as the instructor is current for carrying a passenger, and willing to sign off this pilot, then a flight review can be done in an airplane prior to soloing the glider.

Am I missing something?

Tom

[Bill T]

FAA Wings program for a flight review qualification still requires flying with a CFI.

[[email protected]]

Agreed that during the proficiency check the CFIG would act as PIC.

Here is my reference as to why I think this is legal

https://www.faa.gov/licenses_certificates/airmen_certification/sport_pilot/media/proficiency_check.pdf

Specifically -





III. RECORD OF PILOT TIME.
There is no minimum pilot experience required by for the proficiency check. Enter only the pilot time that is acquired in an N-numbered aircraft. DO NOT ENTER TIME THAT IS ACQUIRED IN AN ULTRA LIGHT VEHICLE. If decimal points are used, be sure they are legible. You should fill in the blocks that apply and ignore the blocks that do not.

[Terry Pitts]

Adding a "rating" to light sport requires training to proficiency (dual) and proficiency check with a different instructor (dual). No solo time required. Still not legal to fly until a flight review is completed.

A flight review can only take place in a class/category combo someone already has. Ditto - I think - for WINGS. There is no requirement to be 24-month or 90-day current for a flight review.

[Terry Pitts]

On Sunday, April 24, 2016 at 12:33:18 AM UTC-4, wrote:
> I'm assuming this discussion is about an airplane (or other non-glider) pilot who has chosen not to renew a medical for some reason, and is now also more than 24 months since the last flight review.

Maybe a safe assumption, but all I know is that the guy is a formerly active commercial pilot who DOESN'T WANT TO FLY POWERED AIRCRAFT ANY MORE...

>
> Best I can tell... So as long as the instructor is current for carrying a passenger, and willing to sign off this pilot, then a flight review can be done in an airplane prior to soloing the glider.

The 90-day currency for carrying passengers doesn't apply to one CFI and one "student" in the airplane/glider. For a training flight both are "required crew members," and neither one is a passenger with respect to the other.

>then a flight review can be done in an airplane prior to soloing the glider.

Of course it can. But, why spend the money getting PTS proficient when the guy doesn't want to fly powered aircraft anymore. The money can best be spent becoming a better glider pilot.

I suppose the guy could also throw his certificate in the mail with a note to the FAA, then follow the new process to get a Student Pilot Certificate...

[N97MT]

I agree with Terry and Roger.

In

"§61.321 How do I obtain privileges to operate an additional category or class of light-sport aircraft?"

there is no reference to 61.313 which spells out the hourly requirements for, what I believe are, the initial Sport Pilot certificate. Since the Commercial Pilot certificate covers Sport Pilot privileges, there is no initial Sport Pilot certificate to acquire in this case.

Also, there is no regulation that I can find that says an applicant MUST be Acting PIC on either a Proficiency Check with an instructor or during a Practical Exam with an Examiner or Inspector.

If using it as a guide, the DPE Handbook strongly discourages a DPE from acting as a PIC during an exam. But I would assume than a Proficiency Check instructor would be more amenable to acting as PIC.

[Terry Pitts]

On Sunday, April 24, 2016 at 10:18:45 AM UTC-4, N97MT wrote:

>But I would assume than a Proficiency Check instructor would be more amenable to acting as PIC.

I can ask the one super knowledgeable Light Sport school guy I'm acquainted with, but I'd "assume" that the proficiency checking instructor must be PIC because 1) he/she's NOT a DPE and 2) the applicant is not yet rated in the new aircraft.

[N97MT]

On Sunday, April 24, 2016 at 9:26:42 AM UTC-5, Terry Pitts wrote:
> On Sunday, April 24, 2016 at 10:18:45 AM UTC-4, N97MT wrote:
>
> >But I would assume than a Proficiency Check instructor would be more amenable to acting as PIC.
>
> I can ask the one super knowledgeable Light Sport school guy I'm acquainted with, but I'd "assume" that the proficiency checking instructor must be PIC because 1) he/she's NOT a DPE and 2) the applicant is not yet rated in the new aircraft.

OK, so what that implies is that a Proficiency Check instructor is NOT an Examiner. However, if he is not an Examiner, then the Proficiency Check does not count as a Flight Review as is discussed in 61.56(d)(1). In such case, the newly-rated Sport glider pilot will have to do a Flight Review following the Proficiency Check, if he has not already done so within 24 months before flying as PIC in his other rating(s).

Of course, he just added the Sport glider rating privilege, so he can now legally do the Flight Review in the glider. After THAT he can go and fly solo, get currency to fly with 1 passenger, etc.

Nuts.

[N97MT]

On Saturday, April 23, 2016 at 11:34:24 PM UTC-5, Bill T wrote:
> FAA Wings program for a flight review qualification still requires flying with a CFI.

Found this in the FAA Wings Program:

"What is the WINGS Profile?

The selections you choose on your WINGS Profile page are used to assist in searching for Accredited Activities that interest you. The activities we display on FAASafety.gov will match these selections. Your selections do not have to match your current certificates and ratings. You should select any certificate and/or rating in which you are interested in pursuing training. For instance, if you are an Airplane Private Pilot who is interested in pursuing a Glider or Commercial certification, you should choose that selection to view activities available on our system pertaining to those certifications."

Here is the website: https://www.faasafety.gov/OnlineHelp/faq.aspx

So, it would appear that you can do this without the Sport Pilot gymnastics.. Just complete a Phase of the Wings program using the Glider Category for the Flight Portion of that Wings Phase, and in lieu of a Flight Review, and you should be set to solo the Glider as PIC. Just check the Glider Category in you Wings Profile and let the system generate the Wings Checklist of training you need to do, and then complete the program with the CFI-G and submit the completed Wings paperwork. There is also a ground portion that needs to be credited, but many of us attend those FAA-Sponsored Safety Seminars anyway which will count. You did remember to get credit for those, right?

[Bill T]

The Flight Review credit is only awarded in the aircraft you are rated. An airplane rated pilot, completing wings courses for gliders will not apply to the flight review needed to solo the glider. He/she needs to complete the Wings courses, 3 ground and 3 flight modules to Practical Test Standards level of proficiency for flight review credit.

BillT
FAASTEAM Lead

[Paul Agnew]

BTT

PA

[[email protected]]

As a student pilot, I used to find the FARs incredibly dull. But now I regard them as a very entertaining, complicated, work of art.

[jp]

On Wednesday, April 27, 2016 at 7:52:26 PM UTC-7, Bill T wrote:
> The Flight Review credit is only awarded in the aircraft you are rated. An airplane rated pilot, completing wings courses for gliders will not apply to the flight review needed to solo the glider. He/she needs to complete the Wings courses, 3 ground and 3 flight modules to Practical Test Standards level of proficiency for flight review credit.
>
> BillT
> FAASTEAM Lead

This is fascinating stuff. As I read the WINGS documentation from the FAA, and 14 CFR 61.56(e) the WINGS phases are not a way to accomplish the Flight Review but rather are an alternative to the Flight Review. If the WINGS path is chosen the "Flight Review" requirements do not apply. On the other hand I am likely to be wrong about anything I interpret from the FAR's.

[jp]

On Wednesday, April 27, 2016 at 7:52:26 PM UTC-7, Bill T wrote:
> The Flight Review credit is only awarded in the aircraft you are rated. An airplane rated pilot, completing wings courses for gliders will not apply to the flight review needed to solo the glider. He/she needs to complete the Wings courses, 3 ground and 3 flight modules to Practical Test Standards level of proficiency for flight review credit.
>
> BillT
> FAASTEAM Lead

Thank you BillT. This issue has caused us, and our add-on students, a lot of confusion. I confess I am still confused about it. 14 CFR 61.56(e) states:

(e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily accomplished one or more phases of an FAA-sponsored pilot proficiency award program need not accomplish the flight review required by this section.

I interpret this to say that a WINGS phase, for whatever category of aircraft, eliminates the Flight Review requirement and rather is not a way to accomplish the Flight Review. They would not be held to completing what is described by the FAA as a Flight Review. Is this not correct?

We have out-of-currency SEL pilots who wish to solo in gliders but have not a practical way to complete an SEL Flight Review. We, and they, are looking for a reasonable way to go forward with their glider training.

Thank you.

[SoaringXCellence]

However a WINGS phase has both knowledge and flight elements. What flight elements are you planning on doing in the glider?

[SoaringXCellence]

On Thursday, April 25, 2019 at 3:28:07 PM UTC-7, SoaringXCellence wrote:
> However a WINGS phase has both knowledge and flight elements. What flight elements are you planning on doing in the glider?

I just went back and reviewed the WINGS program process to confirm my understanding.

FYI: I am a FAAST WINGS representative and I do a lot of validation for pilots in my area. I'm also a pilot examiner for airplanes and gliders.

The WINGS flight activities are related to the current pilot certificate you hold. You cannot do glider flight activities to complete a WINGS phase if you do not hold a glider rating. That's the rub. You CAN use the glider knowledge activities to fill the required 3 knowledge credits, but the flight activities need to be in the category/class of aircraft for which you CURRENTLY hold a certificate.

As noted in the WINGS program brochure: there is no requirement for the flight activities to be done on separate days (but it is recommended) nor is it required that the activities be done in separate flights or for longer than is needed for the CFI to determine that you skills are appropriate for your certificate level. It actually might be cheaper to do a short flight in the SEL to show proficiency than to do a few more tows in the glider.

My short answer (I know too late) is to participate in the SSA webinars (and others) while you train. Refresh your flight skills during glider training time then find a CFI in airplanes that is willing to do a short airplane review flight and sign off your WINGS activities. You can then be signed off to do PIC flights in a category/class aircraft for which you are not rated (glider) and get your solo requirements completed to take the practical test.

Whew!

[jp]

On Thursday, April 25, 2019 at 4:02:21 PM UTC-7, SoaringXCellence wrote:
> On Thursday, April 25, 2019 at 3:28:07 PM UTC-7, SoaringXCellence wrote:
> > However a WINGS phase has both knowledge and flight elements. What flight elements are you planning on doing in the glider?
>
> I just went back and reviewed the WINGS program process to confirm my understanding.
>
> FYI: I am a FAAST WINGS representative and I do a lot of validation for pilots in my area. I'm also a pilot examiner for airplanes and gliders.
>
> The WINGS flight activities are related to the current pilot certificate you hold. You cannot do glider flight activities to complete a WINGS phase if you do not hold a glider rating. That's the rub. You CAN use the glider knowledge activities to fill the required 3 knowledge credits, but the flight activities need to be in the category/class of aircraft for which you CURRENTLY hold a certificate.
>
> As noted in the WINGS program brochure: there is no requirement for the flight activities to be done on separate days (but it is recommended) nor is it required that the activities be done in separate flights or for longer than is needed for the CFI to determine that you skills are appropriate for your certificate level. It actually might be cheaper to do a short flight in the SEL to show proficiency than to do a few more tows in the glider.
>
> My short answer (I know too late) is to participate in the SSA webinars (and others) while you train. Refresh your flight skills during glider training time then find a CFI in airplanes that is willing to do a short airplane review flight and sign off your WINGS activities. You can then be signed off to do PIC flights in a category/class aircraft for which you are not rated (glider) and get your solo requirements completed to take the practical test.
>
> Whew!

Thank you. To be honest, this makes sense to me. To my student maybe not so much. I'll pass along the info.

[Piet Barber]

> The WINGS flight activities are related to the current pilot certificate you hold. You cannot do glider flight activities to complete a WINGS phase if you do not hold a glider rating. That's the rub. You CAN use the glider knowledge activities to fill the required 3 knowledge credits, but the flight activities need to be in the category/class of aircraft for which you CURRENTLY hold a certificate.

I can find no such prohibition in AC-61-91J.
I can find no such prohibition in the FAA WINGS pilot proficiency guide.
I can find no prohibitions in the software running the FAA WINGS page.
I can find no such prohibition in reading 14 CFR 61.56
I can find no such prohibition in AC-61-98D
I can find no such prohibition as a flight instructor validating activity credit in the FAA WINGS page.
I have received no such guidance as a DPE.
I have received no such guidance from my FSDO.

Unless you can correct me with chapter and verse, I believe you are in error on this specific point.

Please back up the following claim [but the flight activities need to be in the category/class of aircraft for which you CURRENTLY hold a certificate. ] with a specific document from the FAA that says this.

While I agree that a certificated pilot can not do a 61.56 flight review in a category he does not hold, WINGS activity credit is not 61.56 flight review activity. Remember that 61.56 flight activity is not required with successful completion of a phase of the FAA WINGS program. Do not conflate the two points, which I believe you have done.

My position: If an airplane-rated private pilot with no glider category rating (Let's call him Joe Pilot), hasn't flown in several years wishes to have solo privileges in a glider, he must accomplish the requirements of 61.56.. This was the finding of the Beard interpretation, as annoying as it is to us. Joe Pilot is unable to do a 61.56 flight review in a glider since he does not hold a rating in gliders. Our ASEL pilot friend is faced with some crappy options:

1) Surrender his ASEL pilot certificate, then apply for a student pilot certificate, go through the TSA background check and waiting period. Once he has the new student pilot certificate in hand, Joe Pilot gets the instructor to do a 61.87 endorsement. This is a terrible option and I sincerely hope that none of us ever recommend this.

2) Go get a BFR in airplanes. Come back with his fresh BFR, and then he can solo gliders after he gets a 61.31 category sign-off. If Joe Pilot has no desire to ever touch an airplane again, this option sucks, too.

3) Complete WINGS credit with flying gliders as the activity credit. The glider flying portion sections that would qualify are: A070405-135, A070405-26, and A100125-31. These are all glider-related activities. Accomplish the knowledge portions as necessary. After doing the knowledge portion and the flying portions, Joe Pilot gets a sign-off from his instructor. The FAA WINGS page says "Congratulations" and gives him a PDF to print out, both frame-size and wallet sized. Joe Pilot prints this out, and now he's OK with regard to 14 CFR 61.56(e).

Once he has the WINGS certificate, he does not need the 1 hour of flying in an airplane and one hour of ground instruction required in order to accomplish the 61.56 flight review. Joe Pilot then gets a 61.31 endorsement for solo flight in an additional category and enjoys that solo flight in a glider. He never had to touch an airplane again unless he's hooking up the rope to the tow plane.

What I believe your post describes of my three options:
1) not mentioned
2) The only option
3) not possible, since he does not have a rating in gliders, he can not do glider activity credits in gliders, so Joe Pilot is stuck with only Options #1 and #2.


Full disclosure: I have accredited the flying portions of WINGS credit for an airplane pilot in this position. I know that the FAA WINGS page does not prohibit this activity, there are no warnings against it, and there was no dialog in the page that I was signing indicating that it would be a problem.