Biennial flight review

[flyguy]

Actually, you have it backwards. If he does 3 takeoffs and landings in a Seminole, they would NOT count for pax in the CRJ. However, his CRJ landings WOULD enable him to carry pax in the Seminole.

That's what I was thinking but am being told otherwise. I guess what I'm asking is does anyone know of any reason why training or flying under part 121 cannot be used to meet part 61 requirements for currency?

 

[skydog]

I am a big believer in taking one every year, or perhaps even more often. A little extra instruction never hurts, and you never have to worry about missing one.

 

[NJA_Capt]

But, some instructors at my airline are trying to tell me that anything I do for them does not count toward any general aviation requirements, including landing currency, BFRs, IPCs, etc. They say part 121 training/flying meets no part 61 requirements.

Are these airline instructors or pilots with CFIs telling you this? :banghead: Sounds like they should have spent more time as CFIs.......

If you pass your 135/121 proficiency checks, you have fulfilled your BFR obligation.

Sec. 61.56
Flight review.
(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.

http://rgl.faa.gov/REGULATORY_AND_G...8E5FD1956A15733586256959004BB274?OpenDocument

 

[nosehair]

the checkride for my CL-65 SIC type rating is adding an additional operating privelage on my commercial pilot certificate, so it should count as a BFR.

This is where I would like to get more information about what an operating privilege is. Does anyone know of a solid definition or reference?

Specifically, I want to know how to apply the word 'privilege' in 61.51(e)(1)(i).

 

[tgrayson]

This is where I would like to get more information about what an operating privilege is. Does anyone know of a solid definition or reference?

No. But there is an FAQ saying that an SIC checkride confers one. ;-)

 

[flyguy]

This is where I would like to get more information about what an operating privilege is. Does anyone know of a solid definition or reference?

Specifically, I want to know how to apply the word 'privilege' in 61.51(e)(1)(i).

If you don't like the word privelage, you can use the word rating. Either way it is an additional rating on a pilot certificate so I would think it does count.

 

[flyguy]

Are these airline instructors or pilots with CFIs telling you this? :banghead: Sounds like they should have spent more time as CFIs.......

One was my ground school instructor, the other was my sim instructor. I may have misunderstood what they were saying, but it sure as hell didn't sound right. It could be that they were just trying to cover themselves. They may have simply been saying, "you are current to fly for us, but we make no guarentee that you are current for any and all types of flying you intend to do". That' not how they worded it, but if that's what they meant than I guess it does make sense. I just want to make sure I know what I'm talking about before I do use it for currency.

 

[ClearedToThe]

For what its worth, I have heard first-hand from speaking with an FAA Inspector that any type of CFI checkride DOES count for a BFR as it falls under the category of "operating privilege". Of course, it would be smart to C.Y.A and be on the safe and smart side and complete a BFR before 24mo's after a CFI 'ride.

 

[butt]

A instructor checkride does not count as a BFR because the examiner is legally supposed to be only checking your instructing abilities, not your piloting abilities. In the real world, the examiner is indeed checking both, so I was always told you could just ask the examiner after a instructor checkride if he could sign your logbook for a BFR as well. But no, an instructor checkride doesn't legally fit the requirements listed for BFR's.

 

[tgrayson]

For what its worth, I have heard first-hand from speaking with an FAA Inspector that any type of CFI checkride DOES count for a BFR as it falls under the category of "operating privilege".

"Operating privilege" is not defined in the regulations and there's no suggestion from the FAA the a flight instructor certificate is one. Whatever an "Operating privilege" is, it probably isn't a certificate or rating, since we already have names for those things.

 

[tgrayson]

I was always told you could just ask the examiner after a instructor checkride if he could sign your logbook for a BFR as well.

That was the suggestion of the old Part 61 FAQ's, but others have pointed out that a BFR requires an hour of instruction and a DPE isn't supposed to instruct, so he may or may not be willing to do that. Most likely, though, the DPE will think the checkride does count as a FR, so he will think the endorsement unnecessary. Best no to argue when someone is typing out your temporary.

Easiest thing is to get the endorsing instructor to sign off for a flight review.

 

[B767Driver]

"Operating privilege" is not defined in the regulations and there's no suggestion from the FAA the a flight instructor certificate is one. Whatever an "Operating privilege" is, it probably isn't a certificate or rating, since we already have names for those things.

At one point in time I had a letter from the FAA as a proficiency check pilot for a part 121 airline. I'm supposing that might be an operating privilege? I'll make some phone calls to see if I can find out. I believe the SIC checkout was mentioned previously as well, all though that checkout is specifically spelled out in the flight review regs...so no question it counts.

Good topic, though.

 

[tgrayson]

I'll make some phone calls to see if I can find out.

Cool.

I'm thinking in the most recent NPRM on Part 61, I made a comment requesting a definition of the term.

I believe the SIC checkout was mentioned previously as well, all though that checkout is specifically spelled out in the flight review regs...so no question it counts.

Yes. Although now there is an SIC type rating. Is a type rating an operating privilege? With no definition, heck, why not?

 

[flyguy]

Yes. Although now there is an SIC type rating. Is a type rating an operating privilege? With no definition, heck, why not?

Well, even if it is not an operating privelage, it is a rating, and ratings count.

 

[flyguy]

For what its worth, I have heard first-hand from speaking with an FAA Inspector that any type of CFI checkride DOES count for a BFR as it falls under the category of "operating privilege". Of course, it would be smart to C.Y.A and be on the safe and smart side and complete a BFR before 24mo's after a CFI 'ride.

I had an inspector tell me the same thing, but once again you must keep in mind that DPEs and inspectors are not lawyers and their personal interpretations of the regulations are not necessarily the official interpretations. Even FSDOs don't know what they are talking about sometimes, so take what you hear with a grain of salt.

 

[mtsu_av8er]

One was my ground school instructor, the other was my sim instructor. I

Wow - sad.

 

[tgrayson]

Well, even if it is not an operating privelage, it is a rating, and ratings count.

True.

BTW, in response to your other questions:

But, some instructors at my airline are tyring to tell me that anyting I do for them does not count toward any general aviation requirements, including landing currency, BFRs, IPCs, etc. They say part 121 training/flying meets no part 61 requirements.

You hear that kind of stuff from Part 121/135 people all the time, but it demonstrates that they don't understand the relationship between Part 61 and other parts of the CFR's. Logging is controlled by Part 61 for everybody.

As for your takeoff and landing currency question, I agree with your reasoning, but I can't find any FAA letter of interp or FAQ that specifically addresses it, so I can't offer any supporting evidence.


For instrument currency, see the LOI I'm posting below.

February 9, 1999

Bill Carpenter
12808 E. Pacific Drive, #302 Aurora, Colorado 80014

Dear Mr. Carpenter:

Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)

You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.

Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.

There is a distinction between actingas pilot in command and loggingof pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:


2

(e) Logging pilot-in-command flight time.

(1) A recreational private or commercial pilot may log pilot-in- command time only for that flight time during which that person -- (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated_ (ii) Is the sole occupant of the aircraft: or (iii) Except for a recreational pilot is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time whileacting as pilot-in-command of an operation requiring an airline transport pilot certificate.

While it is not possible for two pilots to actas PIC simultaneously, it is possible for two pilots to logPIC flight time simultaneously. If the pilot is designated as PIC by the certificate holder, as required by FAR 121.385(c), that person is PIC for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft. The pilot who is the sole manipulator of the controls of the aircraft for which the pilot is rated may also log that flight as PIC.

It is important to remember that we are dealing with loggingof flight time only for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the SIC is fully qualified as a PIC, or only as an SIC. This is important because even though an SIC can log PIC time, that pilot may not be qualified to serveas PIC under Part 121.

I hope this satisfactorily answers your questions. If we can be of further assistance, please contact us.

D. Brent Pope
Attorney, ANM-7H

 

[nosehair]

If you don't like the word privelage, you can use the word rating.

Not in this context. I'm trying to find the difference in the two words as used in 61.51(e)(1)(i) Logging pilot in command time.
"Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges.

The word privilege has a different meaning from rating as used here.

I'm thinking it means something like a catagory rated (helicopter) pilot gets signed off for solo in an airplane, he now has privileges in that airplane and can log PIC when he is the sole manipulator when dual.

 

[tgrayson]

Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges.

The word privilege has a different meaning from rating as used here.

I believe that refers to sport pilot privileges.

 

[flyguy]

Not in this context. I'm trying to find the difference in the two words as used in 61.51(e)(1)(i) Logging pilot in command time.
"Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges.

The word privilege has a different meaning from rating as used here.

I'm thinking it means something like a catagory rated (helicopter) pilot gets signed off for solo in an airplane, he now has privileges in that airplane and can log PIC when he is the sole manipulator when dual.

Okay forget I said privelage at all. Lets just focus on the rating part. I know I can't log PIC, but I do have a type rating in the CL-65, and the checkride for the type rating should count toward the BFR. Actually, the only reason I cannot act as PIC is because I have a limitation "CL-65 SIC privelages only", and because under part 121 I'd need an ATP to act as PIC which I do not have.