Pilot/Instructor 24 month currency

[need2AV8]

Everything I have been taught says that your pilot certificate currency is separate from your flight instructor currency. For example: within 24 calendar months from your last flight review or new pilot certificate/rating, you must have a flight review. Flight instructor certificates which are earned within that 24 months do not count toward pilot certificate currency. Others contend that the flight instructor checkride counts as a 'proficiency check.'

The question is, do flight instructor checkrides count as proficiency checks toward pilot certificate currency, as outlined in part 61?

Anyone know the position the FAA and airlines take?

(This post also in 'general' forum)

 

[midlifeflyer]

You were taught right.

The answer to this frequently asked question is "No. Earning a CFI certificate or rating does not automatically count as a BFR" The Part 61 FAQ and the FAA Legal Opinion that say so are below.

There are specifics, but the "paradigm" reason is that the FAA treats "pilot certificates" and "operating privileges" differently than "instructor certificates" and "instructing privileges".

In the case of 61.56(d), the regulation talks about a "=pilot= proficiency check ... for a =pilot= certificate, rating, or operating privilege...." A CFI certificate is not a pilot certificate and the privilege of teaching others is not an operating privilege.

You can see this general policy in other ways. For example, although a pilot needs a 2nd class medical in order to exercise commercial pilot operating privileges, and a CFI requires a commercial certificate as a prerequisite, a CFI needs no medical at all, unless she is acting s PIC, in which case she only needs a 3rd class.

The answer to the problem turns out to be pretty simple. While obtaining a CFI certificate doesn't =automatically= count as a BFR, the chances approach 100% that you will be called upon to demonstrate the piloting and knowledge skills that meet BFR standards. So, as the FAA recommends, when you take that CFI check, ask the examiner to sign off on a BFR as well. There should be no problem unless you run across one of those examiners who doesn't know the rule himself, in which case you can politely recommend recurrent training for him.

You will find a whole lot of folks, including some FSDOS that don't follow this interpretation and will insist that it does count. Maybe yours. But, suppose you have an accident or incident - along with everything else. do you want a certificate action for lack of currency to be based on =where= the accident happened?

Here are the FAQ:

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QUESTION: The particular question is whether a flight instructor who passes a flight instructor practical test (for initial issuance or a CFI rating addition or for a reinstatement) is or is not exempt from needing a § 61.56 Flight Review for the next two years, since the reg. specifically says PILOT proficiency check.” § 6l.56 d - allows this exemption for a person who has"... passed a PILOT proficiency check.." not needing to accomplish a flight review for the next 2 years.

ANSWER: Ref. § 61.56(d); If the examiner also evaluates the applicant's piloting skills then YES, “. . . a flight instructor practical test (for initial issuance or a CFI rating addition or for a reinstatement) . . .” would meet the requirements of a § 61.56 Flight Review. However, to make sure the applicant gets credit for successful completion of the Flight Review, the examiner should record that the § 61.56 Flight Review was satisfactorily completed in the applicant's logbook.

§ 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.
QUESTION: Does a Part 141 annual check also count in lieu of a flight review?

ANSWER: Ref. § 61.56(d); As is the case in the Answer to Question 1 above, if the Chief Instructor, Assistant Chief Instructor, or Check Instructor evaluates the flight instructor's piloting skills then the answer is YES, a Part 141 annual check would count for a § 61.56 Flight Review. However, to make sure the applicant gets credit for successful completion of the Flight Review, the Chief Instructor, Assistant Chief Instructor, or Check Instructor who conducts the check should record that the § 61.56 Flight Review was satisfactorily completed in the applicant's logbook.
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and the Legal Opinion

==============================
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

(FAA Regional Counsel, Eastern Region)
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[Ralgha]

Bear in mind I'm not argueing that a successful initial CFI ride does count as a BFR by default, but I am arguing the reasoning behind why it doesn't.

Now, if the examiner doesn't think the applicant performed well enough to qualify for a BFR, then why the **** did he/she give the applicant the CFI certificate?

If the examiner doesn't think they performed enough maneuvers etc. to qualify as a BFR, then why the **** did he/she give the applicant the CFI certificate?

There is no way you're going to be awarded a CFI certificate if you can't fly the airplane well enough to pass a BFR, so I think the FAA saying it doesn't count is a load of crap.

Yes, I KNOW it doesn't count.

 

[lawfly]

You mention CFI currency, so appears you are asking about renewal of CFI by checkride/practical test (as opposed to the other renewal options available). Or you could be asking about a checkride/practical test for initial issuance of CFI or rating on CFI. As to renewal of CFI by practical test, appears that it counts only toward the 1 hour of "ground training" required under FAR 61.56(a) for a BFR. So, flight portion of BFR still applies. I'm basing this on FAR 61.56(f) which states that renewal of a CFI under 61.197 waives the one hour of ground time under 61.56, but is silent as to the one hour flight requirement for BFR. Renewal under 61.197 includes renewal by practical test as well as by the other CFI renewal options. Don't know any official position beyond that. Of course, probably most instructors renew by non-flight options. Also. perhaps it is allowable to combine the BFR and the CFI renewal ride so long as the requirements of 61.56 and 61.197 are each met and the appropriate logbook endorsements are given at the time.