Bfr

[A Squared]

Could be but I do have more confidence in their points of view than yours Midlifeflyer (no disrespect intended.)

Yes, but, it *isn't* midlife's point of view, it *isn't* my point of view. It *IS* the point of view of the FAA's Legal counsel. And in legal matters, the FAA's own legal counsel *is* much higher on the authority ladder than your FSDO, your POI, John Lynch, and the Examiner standardization team.

You have yet to address that point. You dismiss it as if it was a letter to the editor from somone's grandmother. It's not. It an official interpretation from the FAA's legal authority, saying in no uncertain terms that a CFI ride does not qualify for the 61.56(d) exemption.

I see that we're still stuck in the second stage from your tag line.

 

[A Squared]

But just to make you happy, in the future, when I write "FAA Flight Instructor practical test passed, Pilot Operations checked and tested - all were satisfactory," I will tell them that this should serve as a FR as per all the sources I have listed, but just in case, they may want to contact a CFI (like you) to have a FR done to be sure. And the reason is because there is some CFI out in Denver named Midlifeflyer who says this won't work as is.

Well, not quite accurate. To be accurate and truthful, you would have to tell the applicant that the FAA's legal authority has said in an official interpretation that it won't work as is, not some CFi in Denver..

 

[A Squared]

Not to add fuel to the fire, but...

The SDL FSDO considers the initial CFI ride acceptable for restarting your flight review clock. Any other CFI rides do not count unless the proper arrangements are arranged and the endorsement is given.

Hmmmmm, that's an interesting twist, the first one counts, but subsequent ones do not.

The problem with this is that I won't always be flying in the SDL FSDO's area...

Yeah, therin lies the rub. Aviation regulations are not supposed to be local phenomenon. Perhaps the FAA, as a public service, cound publish a list of hte FSDOs which consider the CFI ride to fulfil the requyirements of 61.56(d) then you could plan to only fly in those areas, or if you fly into one of the other areas, you could plan not to have a blown tire on landing or other incident that might lead to a logbook review.

 

[UndauntedFlyer]

The FAA's legal authority that you referenced wrote,

"Incorporating a flight review into the CFI practical test could be accomplished, therefore, with little, if any difficulty."

But that means providing 2 hours of instruction during the practical test when such instruction is prohibited per the Examiners Handbook, "The examiner must not give an applicant training during the practical test." (Ref: 8710-3D, page 5-7) There is a conterdiction here.

Does this letter to which you reference so often give the authority for examiners to now give dual instruction during FAA Flight Instructor Practical Tests? It does not.

An examiner's authority is through his or her supervising office and no one else.

In any event I will still endorse CFI applicants as follows: "FAA Flight Instructor practical test passed, Pilot Operations checked and tested - all were satisfactory," I will tell them that this should serve as a FR as per all the sources I have listed, but just in case, they may want to contact a CFI (like you and Midlifecrisis) to have a FR done to be sure.

How is that?

But no matter what I say, legal counsel and all, I doubt that any applicants will contact a CFI for a FR. They will probably just act on whatever source suits them best.

Did you notice my new E-type rating?

Push the Easy button!

 

[midlifeflyer]

But that means providing 2 hours of instruction during the practical test

Actually, it's 1 hour of instruction. The CFI ride does count, in a backhanded way, for the ground requirement:

==============================
61.56(f) A person who holds a current flight instructor certificate who has, within the period specified in paragraph (c) of this section, satisfactorily completed a renewal of a flight instructor certificate under the provisions in § 61.197 need not accomplish the 1 hour of ground training specified in paragraph (a) of this section.
==============================

That avoids the need for the ground portion in most CFI rating add-on rides. And to the extent that you don't feel that you should be signing off on an FR, as I said before, that's fine - so long as you don't lead the pilot to believe that he's covered anyway.

I have a suggested modification for your post-endorsement "disclosure":

==============================
I will tell them that this should serve as a FR as per all the sources I have listed, except for those that are actually written somehwhere
==============================


(BTW, schoolio, this provision is probably the source of the SF FSDO's differentiation between the initial and later rides, although, if anything, the provision is just one of many that shows how the FAA treats "pilot certificates" as separate and distinct from "instructor certificates. In fact, I haven't come across one FAR in which they are treated as the same)

It's truly amazing what you learn when you read rather than take things on faith.

 

[UndauntedFlyer]

Actually, it's 1 hour of instruction. The CFI ride does count, in a backhanded way, for the ground requirement.

It is 2-hours for initial CFI and for reinstatements but in any event it is a mute point because any amount of instruction on a CFI practical test, or any test for that matter, is not permitted. Therefore the FR sign-off you have been advocating from the examiner is NOT PERMITTED following a CFI practical test unless the applicant and the examiner complete the entire process by issuing the temporary certificate and signing the log book. Then they can start at the beginning on the FR, including the ground in most cases and the flight in all cases. This seems to be what you want.

Really, it seems to me that Inspector John Lynch in Washington (who wrote Part 61), my POI, my FSDO and the examiner team are all trying to figure out how to help a guy out so he won't have to go through all that. But you, Midlife, are trying to just make things more difficult for all those CFI's that just want to get renewed and get to work.And all the while, since the flight review started in 1973, there has been not one problem with the way things have been done. No violations, no law suits, no nothing. It is said, "Let sleeping dogs lay."

Maybe the new biggest lie will become, "Hi, I'm Midlifeflyer, I'm from Flight Info.com and I'm here to help you."

Push the easy button.

 

[UndauntedFlyer]

To midlifeflyer: Why don't you losen up and become an E-CFI? Maybe an E-type rating too. It's just part of cyberspace non-reality.

 

[501261]

Really, it seems to me that Inspector John Lynch in Washington (who wrote Part 61), my POI, my FSDO and the examiner team are all trying to figure out how to help a guy out so he won't have to go through all this.

This is very true, and is often how it works in the "real world" however as was pointed out to me by another ASI, "However, if you ask a legal kind of question, you get a legal kind of answer….. "

So use the information presented here as you feel fit. Personally I completely agree with A2 and Midlife, but I also know that a lot of things presented here as "legal" aren't "real world".

It never hurts to be "legal".

 

[midlifeflyer]

it is a mute point

Ohmigosh! It's Avbug!

 

[UndauntedFlyer]

For those who may be interested I have sent an email inquiry on the CFI/FR subjects in this post to Zachary M. Berman, the attorney behind the letter that has been posted here. I have also sent an inquiry to my local FSDO. When I receive a reply I will advise the Board members of their answers. I have asked if it would suffice for the requirement of 61.56(d) to write "FAA Flight Instructor Test Passed, Pilot Operations Checked - All were satisfactory." I have explained in my letter why the examiner can not endorse a flight test as a FR.

I would like for them to say the check ride endorsement as shown above will do the job. But if they say otherwise, then that's that and CFI's will have to just live with this change. As DPE's we are way down on the FSDO/FAA food chain so every examiner just endorses the results of practical tests as instructed by the FSDO. It is only the real FAA that makes policy, not examiners.