1 Aviation Plaza
Room 561
Jamaica, NY 11434
RE: Interpretation of FAR 61.56(d)
Dear Mr. Dennstaedt:
This is in response to your letter dated August 25, 2001, wherein you ask whether an airman can satisfy the flight review requirement under 14 C.F.R. (Federal Aviation Regulation [FAR]) 61.56 by passing a practical test to become a certified flight instructor (CFI), as required by FAR 61.183.
Under FAR 61.56(c)(1), one may not act as pilot-in-command of an aircraft unless, within the preceding 24 calendar months, he has "accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor." Under FAR 61.56(c)(2), the airman must receive a logbook endorsement from the authorized instructor certifying that he has satisfactorily completed the review. Under FAR 61.56(a), a flight review must include: (1) a review of the current general operating and flight rules of Part 91; and (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.
Under FAR 61.56(d), however, the flight review requirement of FAR 61.56(c)(1) does not apply to one who has "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."
The issue you raise is whether passing a practical test to become a CFI can fall within the exception to the flight review requirement that is provided by FAR 61.56(d). Under FAR 183(h), to be eligible for a flight instructor certificate or rating, the applicant must "pass the required practical test that is appropriate to the flight instructor rating sought." The FAA Practical Test Standards (PTS) for the airplane flight instructor examiner (sic) requires that the examiner ensure that the flight instructor applicant has the "ability to perform the procedures and maneuvers included in the standards to at least the commercial pilot skill level."
Thus, the instructor has broad discretion in conducting a flight review. A CFI practical test encompasses the demonstration of various basic maneuvers that an instructor is likely to cover in a flight review. Incorporating a flight review into the CFI practical test could be accomplished, therefore, with little, if any difficulty.
Accordingly, a CFI practical test will not per se fulfill the flight review requirement. A practical test for a CFI rating under FAR 61.183, taken within 24 months of a prior flight review, can readily meet the flight review requirement of FAR 61.56(d), however, if the examiner is satisfied that a flight review endorsement can be given. To ensure that the CFI applicant gets credit for successful completion of the flight review, however, he or she should ask the examiner to conduct the CFI oral and practical test so as to satisfy the flight review requirements as well, and to make a logbook endorsement for the flight review upon completion of the examination.
If you have additional inquiries, please contact Zachary M. Berman of this office at (718) 553-3258.
Sincerely,
Loretta E. Alkalay
