Guy
Well-Known Member
Okay, I see where you are confused. You missed reading the part where I wrote:
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Single Engine Add-on
- Thread starter Fly_Unity
- Start date
Okay, I see where you are confused. You missed reading the part where I wrote:
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tgrayson
New Member
You're inventing something that doesn't exist: "Rated student pilot" is an oxymoron. No rated pilot is a student pilot or operates with student pilot privileges. When the regulations refer to "student pilot", they're referring to a pilot with a student pilot certificate.
61.56(g) does not pertain to any other pilot certificate other than student pilot certificate.
CoffeeIcePapers
Well-Hung Member
I would do the following:
Train him on the required maneuvers for the Commercial Single dd on, per the PTS.
Sign him off for a flight review.
Schedule a Commercial Single add on Checkride.
Train him on the required maneuvers for the Commercial Single dd on, per the PTS.
Sign him off for a flight review.
Schedule a Commercial Single add on Checkride.
Blackhawk
Well-Known Member
One thing that was brushed over that should be emphasized. You are not giving him a solo endorsement, you are giving him an endorsement to be a PIC while solo in SEL. There is no student pilot certificate involved. Also be advised that the endorsement to be PIC in SEL does not expire unless you put an expiration in the endorsement.
Guy
Well-Known Member
As they say in the old StarKist commercials, "Sorry, Charlie", but you're wrong. However, since it is obvious there isn't anything I can write that will convince you of that, here is what I suggest. Call the Memphis FSDO on Monday morning. It is a local call for you 322-8600. Ask to speak with a GA Operations Inspector. If he or she agrees with your belief that an airman who holds a certificate in one class of aircraft has to have a current flight review in that class of aircraft before they can solo or take a practical test in another class of aircraft, post that inspector's name.
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tgrayson
New Member
Only because you have no evidence and I have gobs of evidence. I have no interest in what MEM FSDO thinks. Here's an old FAQ regarding the student pilot thing, relevant parts in red:
QUESTION: If a person holds a Private Pilot Certificate or higher with an Airplane – Single Engine Land rating, may that person log PIC while undergoing training for an Airplane – Multiengine Land rating at the private pilot certification level?
The rule [i.e., § 61.51(e)(4)(ii) and (iii)] now provides that a student pilot may log PIC if that pilot has a solo endorsement and is undergoing training for a different certificate or rating. Is a person who holds a Private Pilot Certificate with an Airplane – Single Engine Land rating considered a student pilot when seeking an Airplane – Single Engine Sea rating? If so, then would a person who holds an Airplane – Single Engine Land rating and is undergoing training for an Airplane – Multiengine Land rating or an Airplane – Single Engine Sea rating be considered a student pilot?
Also does “undergoing training” in this context of my question mean dual instruction?
ANSWER: Ref. § 61.51(e)(1)(ii) and § 61.31(d)(3); § 61.51(e)(4) to which you refer only applies to persons holding a student pilot certificate. You asked “Is a person who holds a Private Pilot Certificate with an Airplane –Single Engine Land rating considered a student pilot when undergoing training for an Airplane – Multiengine Land rating or an Airplane – Single Engine Sea rating?” No, that person is a certificated pilot at a level above “student pilot” and § 61.51(e)(4) does not apply. He is not a student pilot nor considered a student pilot.
Guy
Well-Known Member
"Sorry, Charlie", but your "gobs of evidence" is not evidence at all nor does it relate to the question of a required flight review.
If you're afraid to call the MEM FSDO, write another letter. You know the address.
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Blackhawk
Well-Known Member
T is correct on this and I've seen it before. The pilot in question is not a student pilot and therefore must have a current flight review to be PIC in an aircraft. The good news is that there is no aeronautical experience requirement for the additional class rating, so if you can find a DE who will agree to be PIC during the check ride you can do all the training dual, then have the pilot take the check ride with the DE acting as PIC.
Blackhawk
Well-Known Member
Actually, I stand corrected. If we are going to use the FAQs, we need to use all of them:
the required endorsements for solo flight in that aircraft.
QUESTION:
The scenario is a rated pilot who is training for a new rating and is flying as
a solo ”PIC" with appropriate endorsements. In accordance with § 61.56(g), would this rated
pilot still be required a current flight review, even to solo the glider while under instruction?
a solo ”PIC" with appropriate endorsements. In accordance with § 61.56(g), would this rated
pilot still be required a current flight review, even to solo the glider while under instruction?
ANSWER:
Ref. §61.31(d)(3); No, the pilot would not need to have a current Flight
Review to solo as PIC a glider while undergoing training for that rating in a glider, provided that pilot has received the appropriate training and has a current solo endorsement in a glider, as per §61.31(d)(3). Section 61.31(d)(3) was specifically written to address this situation. Section 61.31(d)(3), states, in pertinent part:
(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the
pilot in command. To serve as the pilot in command of an aircraft, a person must—
* * * * *
(3) Have received training required by this part that is appropriate to the aircraft category,
class, and type rating (if a class or type rating is required) for the aircraft to be flown, and
have received the required endorsements from an instructor who is authorized to provide
Review to solo as PIC a glider while undergoing training for that rating in a glider, provided that pilot has received the appropriate training and has a current solo endorsement in a glider, as per §61.31(d)(3). Section 61.31(d)(3) was specifically written to address this situation. Section 61.31(d)(3), states, in pertinent part:
(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the
pilot in command. To serve as the pilot in command of an aircraft, a person must—
* * * * *
(3) Have received training required by this part that is appropriate to the aircraft category,
class, and type rating (if a class or type rating is required) for the aircraft to be flown, and
have received the required endorsements from an instructor who is authorized to provide
the required endorsements for solo flight in that aircraft.
tgrayson
New Member
This mechanism for avoiding the FR requirement is at least plausible, unlike Guy's assertion that the pilot is a student pilot. However, I raise this objection to the FAQ interpretation:
Can we assume that the regulation that the pilot have a current medical is also waived by 61.31(d)(3)? I suspect you'd say no and I agree. I would argue that 61(d)(3) provides only a necessary requirement for solo flight, and not sufficient. Unless a regulation explicitly references a condition for its own exception, then no exception exists.
Blackhawk
Well-Known Member
Wait... so you're saying the FAQs only applies when you like the answer?
tgrayson
New Member
As I pointed out previously, FAQs give insight, but have no authority on their own. This one seems incompatible with the regulations, as are a number others. The one I quoted is supported by the underlying regulations.
Blackhawk
Well-Known Member
Incompatible in your opinion. Let's see... FAA Certification Branch or some dude on a website. I'll go with door "A".
Blackhawk
Well-Known Member
This entire argument is a non sequitur. Medicals are different from currency and John in no way says someone can fly without a medical. Why don't you mention the price of tea in China as well? The way the regulation was exactly worded did not express the intent of the FAA as clarified by the chief of the FAA Certification branch. Let's take a case that I see on a regular basis:
1. Two people come to me wanting FW training. One has no experience, the other is a military RW pilot. The latter pilot has been in a staff position for several years, so his last flight was over two years ago. This pilot (pilot "B"), has no intention of ever flying a helicopter again.
2. According to your logic pilot "A" with no experience would be fine for solo (as long as he met the other requirements).
3. Pilot "B", however, would need to take a flight review in a helicopter first. He would need to travel 300 miles (the distance to the nearest flight school with helicopters), spend money on a hotel, then fly in a helicopter for a flight review- total expense well over $500 for something that will do nothing to enhance his safety as a fixed wing pilot and would actually discourage him from flying. He would be better off turning in his pilot certificate and starting from scratch.
Again, as John Lynch pointed out this makes absolutely no sense and was not the intent of the way 61.31 was written.
Mike H
Well-Known Member
You don't even need to make it that complicated. With Multi add-ons the applicant logs the time as PIC anyway. No reason it should be any different for a SE add-on. Since you'll probably be doing more than an hour of flight and an hour of ground in preparation for the checkride, there's nothing that says you can't include a flight review in that time.
tgrayson
New Member
You are arbitarily asserting that some regulations still apply and others do not, with no legal justification, other than your preference. The regulation states that a flight review is necessary to act as pilot in command, unless you're a student pilot. I see no regulation that grants exception to that. Does that make sense in this instance? No, but it doesn't make sense that a CFI ride doesn't count as a flight review, so making sense isn't really a criterion for being the law.
I'm puzzled that you would grant so much authority to the reputed state of mind of the people who wrote the regulation, given that so many of their interpretations have been overturned by the General Counsel's Office, which tries to focus on the law as written.
I also note that you agreed with me a couple of posts back, so your passion now seems a bit incongruous.
Cannon
New Member
What if the person were taking instruction for the addition of an airplane single engine sea to an existing airplane single engine land. Would you have them log PIC time before they were rated in seaplanes?
What if the person were taking instruction for the addition of rotorcraft helicopter to an existing airplane single engine land. Would you have them log PIC time before they were rated in helicopters?
tgrayson
New Member
Only if they were the sole occupant of the aircraft. And 61.51(e) doesn't provide any grounds for logging your checkride as PIC, in spite of the fact that it's commonly done.