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