CFI Checkride as Flight Review

midlifeflyer

midlifeflyer

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That is why you never ask the question unless you ALREADY know the answer. I can tell you that the any examiner REQUIRES the demonstration from the RIGHT seat to be within Com Pilot standards, even though it's about INSTRUCTION not flying.

Sigh.
 
What? Give me a break... an intense 6- to 8-hour checkride with maybe about 1.5 or 2.0 of flight doing every possible maneuver does not COUNT? :mad:

I suppose the FAA is saying it is possible for an applicant to take the CFI checkride without ever touching the controls? (Where's my PTS...) But in my experience all the CFIs I know spent plenty of time demonstrating maneuvers with their hands at the controls!

IMO because of the way the CFI checkride is conducted, it should automatically qualify for a flight review. It goes way above and beyond the level of detail & time of the 2-hour minimum flight review. It includes a (long!) discussion of regulations plus lots of maneuvers. It requires a high level of knowledge.

I guess I never paid close attention to the wording of the reg where it says getting a new PILOT certificate qualifies, and I suppose "instructor" is not the same as "pilot." So I'll give the FAA that -- OK maybe they win.

Still, I dunno, I am really in disagreement with the idea that a CFI checkride shouldn't automatically count as a flight review, just like other certificates and ratings. Everyone I've dealt with interprets the regs in this manner. I guess we've all been wrong. What about anyone who's treated CFI checkrides as automatic flight reviews in their logbook without proper signatures? Or on another topic, the CFII checkride?

I guess the even broader question is, if someone has done something a certain way for a long time, and then the FAA issues a letter of interpretation declaring that method illegal, now what?
 
gibbons said:
This would include just about every instructor I've ever talked to about this.
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To answer Kate's question, technically they are in violation of the flight review reg.

I agree it is pretty silly, but by the letter of the law...
 
midlifeflyer said:
Did I just miss the thread or does Ron not even know it yet? The FAA Legal Counsel, in a letter to Ron, finnally resolved the age-old question about whether the CFI rude automatically satisfies the flight review requirement. In accord with the disowned FAQ and the Eastern Regional opinion, it doesn't.

http://www.faa.gov/about/office_org...00/interpretations/data/interps/2008/levy.pdf
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However, it does qualify for all the flight portions of a WINGS basic phase (and the advanced and master phases too), and some of the knowledge credits too, so you only have a little ground training to accomplish to have it count for a flight review. Source: FAASafety.gov, digging through the WINGS required credits and searching for matching activities. ATP counts for most of the same things.
 
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bbchien said:
That is why you never ask the question unless you ALREADY know the answer.
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I suspect Ron already knew the answer when he asked. My own view was that this is what the regs actually say (with an unusual amount of cross consistency) and I would have been surprised if it went the other way.

The only real problem to me was uneven enforcement - where the chance that a CFI might face an enforcement action for not being current would depend on what part of the country the incident that caused the logbook check happened.
 
midlifeflyer said:
Did I just miss the thread or does Ron not even know it yet? The FAA Legal Counsel, in a letter to Ron, finnally resolved the age-old question about whether the CFI rude automatically satisfies the flight review requirement. In accord with the disowned FAQ and the Eastern Regional opinion, it doesn't.
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I have not seen a thread on this before, but I know it has been discussed in chat at least a couple times. I always figured a practical test for a CFI rating did count as a BFR but I was outvoted, and for good reason I see.
 
You hair-splitters out there might somehow contort this FAA interpretation into a logical position, but that doesn't mean it isn't ridiculous on its face.

The real world significance is trivial though. Even if an examiner is such as jackass that he wouldn't endorse a BFR on a CFI checkride, it seems unthinkable that the CFI who recommended the applicant for the ride would not do so.

Jon
 
The point is that without a written endorsement, from either the DPE or the endorsing CFI, the CFI ride does not count as a flight review on it's own.

For what it is worth, I personally don't agree with the interpretation, as most of you don't. But this IS the FAA and they make the rules, to be interpreted by Legal, and that is what we have to abide with.
 
4CornerFlyer said:
You hair-splitters out there might somehow contort this FAA interpretation into a logical position, but that doesn't mean it isn't ridiculous on its face.
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Actually it's only ridiculous on its face in the sense that a police officer waving you through a red traffic signal makes the law that says stop at red light ridiculous in its face.

Really. If you read through the regs, you'll find that the separation of pilot certificates and privileges from instructor certificates and privileges is incredibly consistent. If the FR reg uses "pilot" to mean "instructor," it's, as far as I can tell, the only reg in the whole FAR that does.

The opinion might not make sense based on the way the practical test is actually conducted 90+% of the time, but it does from a reading of the regs.
 
After I first had Tony say the CFI initial did not qualify as a Flight Review, I dug in further and read the FARs. Prior to that, I was convinced it qualified. My understanding from further reading dictated it does not.

61.56(d) states:
(d) A person who has, within the period specified in paragraph (c) of this section, passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege need not accomplish the flight review required by this section.
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I then asked myself the exact purpose of the CFI initial checkride.​

From the CFI PTS, Page 7:​
The term "instructional knowledge" means the instructor applicant is
capable of using the appropriate reference to provide the "application or
correlative level of knowledge" of a subject matter topic, procedure, or
maneuver. It also means that the flight instructor applicant's
discussions, explanations, and descriptions should follow the
recommended teaching procedures and techniques explained in​
FAA-H-8083-9, Aviation Instructor's Handbook.
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The purpose of the CFI ride is specifically to determine the candidate's instructional knowledge level and ability to apply that knowledge in a teaching environment among other aspects as described below.

Further in the CFI PTS, Page 13:
Satisfactory Performance
The practical test is passed if, in the judgment of the examiner, the
applicant demonstrates satisfactory performance with regard to:​
  1. knowledge of the fundamentals of instructing;​
  2. knowledge of the technical subject areas;​
  3. knowledge of the flight instructor's responsibilities concerning the
    pilot certification process;​
  4. knowledge of the flight instructor's responsibilities concerning
    logbook entries and pilot certificate endorsements;​
  5. ability to demonstrate the procedures and maneuvers selected
    by the examiner to at least the COMMERCIAL PILOT skill level
    while giving effective instruction;​
  6. competence in teaching the procedures and maneuvers selected
    by the examiner;​
  7. competence in describing, recognizing, analyzing, and correcting
    common errors simulated by the examiner; and​
  8. knowledge of the development and effective use of a course of
    training, a syllabus, and a lesson plan.​
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Note the word "knowledge" is constantly used as are other terms associated with teaching.

It's quite bit different from the PPL PTS:
Satisfactory Performance
Satisfactory performance to meet the requirements for certification is
based on the applicant’s ability to safely:​
  1. perform the TASKs specified in the AREAS OF OPERATION for
    the certificate or rating sought within the approved standards;​
  2. demonstrate mastery of the aircraft with the successful outcome
    of each TASK performed never seriously in doubt;​
  3. demonstrate satisfactory proficiency and competency within the
    approved standards;​
  4. demonstrate sound judgment; and​
  5. demonstrate single-pilot competence if the aircraft is type
    certificated for single-pilot operations.​
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There's quite a difference between them. Satisfactory Performance for CPL is identical to PPL.

However, every aspect of my CFI ride did meet the requirements of a Flight Review. I'm pretty sure the oral exam covered the ground portion of a Flight Review. :)

Since there is no specific requirement for the flight portion of a Flight Review, the two hours spent demonstrating maneuvers as a CFI candidate would indeed qualify as showing proficiency.

But, simply a "Satisfactory Performance" sign-off as a CFI does not qualify. I have to ask the DPE to issue a Flight Review endorsement separate from the CFI sign-off. And, I forgot to ask Ben to do that.

However, I'll be training with a new school next week to go through their standardization and learn the Diamond aircraft. Between the ground periods and flight showing proficiency and learning the plane, that would satisfy Flight Review requirements and qualify for an endorsement.
 
When I did my CFI ride the examiner told me to remind him and he would sign off on my flight review. I promply forgot all about it:(
 
Don Jones said:
When I did my CFI ride the examiner told me to remind him and he would sign off on my flight review. I promply forgot all about it:(
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Reminder to self.... Put a sticky in the logbook reminding self to ask for proper endorsements!:yes:
 
I thought I'd posted this before, but yes, I have the letter, and no, I didn't think that's what it would say. Personally, I thought surviving the CFI oral would be enough to meet the ground portion requirement, and "demonstrat[ing] the procedures and maneuvers selected by the examiner to at least the COMMERCIAL PILOT skill level" should satisfly the flight portion requirement. Frankly, I thought the FAA lawyers twisted and contorted the language of the regulation to an almost unrecognizable extent in order to justify their position. However, at least now we know what the law is officially interpreted to mean, so we can teach folks how to comply.
 
Ron Levy said:
I thought I'd posted this before, but yes, I have the letter, and no, I didn't think that's what it would say. Personally, I thought surviving the CFI oral would be enough to meet the ground portion requirement, and "demonstrat[ing] the procedures and maneuvers selected by the examiner to at least the COMMERCIAL PILOT skill level" should satisfly the flight portion requirement. Frankly, I thought the FAA lawyers twisted and contorted the language of the regulation to an almost unrecognizable extent in order to justify their position. However, at least now we know what the law is officially interpreted to mean, so we can teach folks how to comply.
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Interesting. I had the opposite view. I though that the surprisingly consistent separation in the FARs between "pilot" certificates and privileges and "instructor" certificates and privileges (which Kenny in part described in his post) almost required this answer from a regulatory interpretation standpoint. I think they would have needed to do a bit of twisting to make the word "pilot" equal the word "instructor" in only this one regulation.

Whatever...

But my biggest concern, given the fact that FSDOs were going every which way, was that a pilot/cfi with an incident that led the FAA to check his logbook might have his currency judged based upon where the incident happened. So, like you, I'm happy there is finally an answer, whichever way it went.
 
OK, wait, to sum up--

I got my commercial in Sept. 06, and my CFI in Oct. 07. So I need a BFR this Sept.?
 
Don Jones said:
When I did my CFI ride the examiner told me to remind him and he would sign off on my flight review.
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To throw another stick on the fire, how is it legal for an examiner to use the CFI ride as a legal "option" since it isn't covered in any of the 61.56(d) options. If it isn't in one of these optional ways to substitute the "pilot" proficiency check, then the only 'legal' option is to complete 1 hour dual flight and 1 hour ground training.

Does anybody think an examiner is going to sign off an hour dual and an hour ground instruction to make the Flight Review legal? Nope. This isn't the way to do this. The recommending instructor is the one that should be signing off a flight review before a CFI checkride.
 
nosehair said:
To throw another stick on the fire, how is it legal for an examiner to use the CFI ride as a legal "option" since it isn't covered in any of the 61.56(d) options. If it isn't in one of these optional ways to substitute the "pilot" proficiency check, then the only 'legal' option is to complete 1 hour dual flight and 1 hour ground training.

Does anybody think an examiner is going to sign off an hour dual and an hour ground instruction to make the Flight Review legal? Nope. This isn't the way to do this. The recommending instructor is the one that should be signing off a flight review before a CFI checkride.
Click to expand...
Since a DPE is also a qualified CFI, why would it be improper?
 
nosehair said:
To throw another stick on the fire, how is it legal for an examiner to use the CFI ride as a legal "option" since it isn't covered in any of the 61.56(d) options. If it isn't in one of these optional ways to substitute the "pilot" proficiency check, then the only 'legal' option is to complete 1 hour dual flight and 1 hour ground training.

Does anybody think an examiner is going to sign off an hour dual and an hour ground instruction to make the Flight Review legal? Nope. This isn't the way to do this. The recommending instructor is the one that should be signing off a flight review before a CFI checkride.
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It counts as both a CFI ride and FR if the DPE puts two signatures in your log book - or at least the 61.56 signature. You can double up and count (post-PP) hood time while flying XC towards both the IR simulated instrument and 50 hours of PIC XC - why would you not be able get a signature that says flight review after the CFI ride?

FWIW - my DPE never signed my logbook when I completed the CFI ride.
 
nosehair said:
To throw another stick on the fire, how is it legal for an examiner to use the CFI ride as a legal "option"
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The easy answer is because FAA Legal says its legal.

But I don't really understand the question. Assuming the Examiner is also an instructor (is it even possible for an examiner to let his CFI lapse?) he's just signing off based on "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."

What other "option" are you looking for?
 
midlifeflyer said:
What other "option" are you looking for?
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I'm looking for the 1 hour dual flight training and 1 hour ground instruction that must be logged in the logbook aside from the Flight Review Completed sign-off.

Unless it is one of the exceptions in 61.56 using a 'pilot evaluation', then the full dual flight and ground requirement comes into play - including a signed dual flight instruction and ground instruction - and the examiner ain't doin' that.

Where is the regulation, or FAA official policy, that allows an examiner to substitute the CFI ride as dual instruction?
 
nosehair said:
I'm looking for the 1 hour dual flight training and 1 hour ground instruction that must be logged in the logbook aside from the Flight Review Completed sign-off.

Unless it is one of the exceptions in 61.56 using a 'pilot evaluation', then the full dual flight and ground requirement comes into play - including a signed dual flight instruction and ground instruction - and the examiner ain't doin' that.

Where is the regulation, or FAA official policy, that allows an examiner to substitute the CFI ride as dual instruction?
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All that is needed is to ask before starting that you would like a BFR also. Anything that is covered in one will not need to be covered in the other.

Dan
 
nosehair said:
I'm looking for the 1 hour dual flight training and 1 hour ground instruction that must be logged in the logbook aside from the Flight Review Completed sign-off.

Unless it is one of the exceptions in 61.56 using a 'pilot evaluation', then the full dual flight and ground requirement comes into play - including a signed dual flight instruction and ground instruction - and the examiner ain't doin' that.

Where is the regulation, or FAA official policy, that allows an examiner to substitute the CFI ride as dual instruction?
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Since there are other options that can substitute the ground or flight, is it important to idenitify those sections? During any previous FR, has your logbook ever been endorsed with more than the following words?:



AC 61-65E said:
I certify that (First name, MI, Last name), (pilot certificate), (certificate number), has satisfactorily completed a flight review of section 61.56(a) on (date).​



/s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05
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Only the date of the endorsement is shown as of the date it was issued. Since the specific portions must not be identified, it's assumed you've accumulated the required ground and flight in some fashion.

Now, the question continues....

Since it is not forbidden, does the oral portion (ground) of any CFI ride qualify as the ground portion of the FR? Likewise, does the flight portion of any CFI checkride qualify as the flight portion of a FR?

Under a FR, you can have ground discussion over flight planning, fuel management, weather services interpretation or many other basic functions of a private pilot. During a completelty separate time and date, a CFI could attend a FIRC and satisfy the ground portion requirement.

However, the flight portion could be demonstrated maneuvers and procedures in a Citation X, provided the pilot is rated for such. These meet the basic requirement of 61.56.

Something I'm taking away from that... A checkride for issuing a type rating would not qualify for a FR flight portion as the pilot was not already rated in that aircraft. Is that correct?

I became certain before the letter's issuance a satisfactory checkride completion did not automatically take the place of an endorsement. The key part there is "endorsement." You do not receive the above endorsement in your logbook when you complete a checkride for a pilot certificate or rating. It's substituted by the examiner's "Satisfactory" entry.

So, I interpret the issue to be one of "paperwork." A completely separate endorsement must be made apart from the examiner's Satisfactory entry in the log. There's nothing to state this not legal nor inappropriate.

But, it's going to be the inspector's opinion that matters until it reaches an ALJ.

It sounds like time for another letter to supplement the prior interpretation. Who's volunteering?
 
No one is answering my question. Every response is to the substance of the flight or the common sense of it or the examiners willingness to 'sign-off' a flight review.

LISTEN UP: I am talking about the FLIGHT TRAINING that must be logged and the GROUND TRAINING that must be logged in accordance with 61.56:

"A flight review consists of 1 hour of flight training and 1 hour of ground training..."

Kennyflys, you have the mis-understanding that only an endorsement is required, but the flight and ground training must also be logged. You use the word "assumed" to indicate that the required training is done.

61.189(a) requires that an instructor signs the logbook on any flight or ground instruction given.

Flight review, currency, etc. must be logged and signed.
 
nosehair said:
No one is answering my question.
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I thought I did when I said
The easy answer is because FAA Legal says its legal.
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When the individual taking a flight instructor practical test requests that the test be taken in conjunction with a biennial flight review, the activities related to the flight instructor practical test may be evaluated by the examiner for demonstrating the maneuvers and procedures necessary to accomplish a flight review. ....
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nosehair said:
No one is answering my question. Every response is to the substance of the flight or the common sense of it or the examiners willingness to 'sign-off' a flight review.

LISTEN UP: I am talking about the FLIGHT TRAINING that must be logged and the GROUND TRAINING that must be logged in accordance with 61.56:

"A flight review consists of 1 hour of flight training and 1 hour of ground training..."

Kennyflys, you have the mis-understanding that only an endorsement is required, but the flight and ground training must also be logged. You use the word "assumed" to indicate that the required training is done.

61.189(a) requires that an instructor signs the logbook on any flight or ground instruction given.

Flight review, currency, etc. must be logged and signed.
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After a FIRC, have you gotten your logbook signed? From what I read, only a certificate of completion is required. Some FIRCs are completed on-line and only a certificate is available. Hence, there is no notation in the logbook regarding ground instruction.

I have to go with Mark on this one (excerpt from the letter):

However, 14 CFR 61.56(a)(2) states that the person giving a flight review has the discretion
to determine the maneuvers and procedures necessary for the pilot to demonstrate "safe
exercise of the privileges of the pilot certificate." When the individual taking a flight
instructor practical test requests that the test be taken in conjunction with a biennial flight
review, the activities related to the flight instructor practical test may be evaluated by the
examiner for demonstrating the maneuvers and procedures necessary to accomplish a flight review.​
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It qualifies pretty much without exception provided the Examiner/CFI deems the maneuvers and material covered appropriate for Flight Review requirements. My earlier statement regarding a letter is mute.
 
gprellwitz said:
Moot, too!:D :yes:
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ROFL.gif
Well, I was being somewhat quiet on the matter. :)
 
KennyFlys said:
After a FIRC, have you gotten your logbook signed? From what I read, only a certificate of completion is required. Some FIRCs are completed on-line and only a certificate is available. Hence, there is no notation in the logbook regarding ground instruction.
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True, but this is a specifically-addressed exception to the requirement for 1 hour of ground training, so there's no need for a ground training log entry. OTOH, as far as a practical test is concerned, the FAR's specifically address practical tests saying that the examiner is acting merely an observer, not an instructor, and the DPE Handbook (an FAA Order) specifically prohibits giving instruction during a practical test. Since the examiner isn't acting as an instructor, and isn't giving training, there cannot be training log entry to make. However, the interpretation letter from the Chief Counsel's office clearly states that the examiner may sign the FR endorsement based on the events of the practical test, without saying the examiner must also give and log "training." Based on Administrator v. NTSB and Merrell, if Ms. McPherson says it's OK, it's OK, and that's the end of that unless one can show her interpretation is "arbitrary, capricious, or otherwise not according to law" -- and I don't see that happening on this issue.

Like I said, the basic idea that a successfuly completed CFI practical test doesn't sufficiently cover "the current general operating and flight rules of part 91 of this chapter" and "maneuvers and procedures that ... are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate" to sub for a 61.56(a) FR is already utterly absurd, so any further absurdity is merely spitting in the ocean.
 
Well,

I would tend to say that the entire thing is arbitrary and capricious, but then again, that can be said about good portions of the FARs.

I have a question brought up by all of this: Does a type rating count for a BFR? I was thinking that next BFR (in a year or so), I might get a type rating in a jet of some type (and depending on my time, take my ATP). Would this satisfy the BFR requirements?

~ Christopher
 
jwriteclub said:
Well,

I would tend to say that the entire thing is arbitrary and capricious, but then again, that can be said about good portions of the FARs.

I have a question brought up by all of this: Does a type rating count for a BFR? I was thinking that next BFR (in a year or so), I might get a type rating in a jet of some type (and depending on my time, take my ATP). Would this satisfy the BFR requirements?

~ Christopher
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ANY check ride for a pilot rating eliminates the need for a separate flight review. Does not need to be the same class, nor even the same category of aircraft as any certificates you may already hold. You can get a balloon rating and it does away with the need for a flight review for another 24 calendar months. I yet to have a flight review, 6 years after starting my training, and I don't plan on getting one this year either. Seaplane rating most likely.
 
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