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#1
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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. |
#2
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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 |
#3
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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. |
#4
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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 |
#5
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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. |
#6
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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. |
#7
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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 |
#8
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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.
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#9
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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......... |
#10
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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.
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