Flight Review in a single-seat aircraft
Posted: Mon Oct 15, 2012 1:26 pm
This topic has been raised in other threads. It turns out I may have misspoken (or maybe misinterpreted the FARs). Here's the issue in summary:
There used to be a commonly accepted procedure in place for satisfying a Flight Review (previously called a BFR) in a single-seat aircraft. This involved the supervising instructor watching the pilot fly, talking to him or her on the radio, and the pilot demonstrating requested maneuvers. At the time, the BFR requirement was open-ended, not specifying any minimum flight time, or ground training time, or particular maneuvers. This was all left to the discretion of the CFI.
A few years ago, the FAA changed the Flight Review rules. They deleted the term "biennial" (probably because some folks couldn't distinguish between twice a year and once every two years), replacing it with the language "flight review within the previous 24 calendar months". They also did away with CFI discretion, to the extent that a flight review now must include a minimum of one hour of ground training, and one hour of flight training.
Here's where the single-seat flight review came under scrutiny. AOPA (and others) interpreted the one hour of flight training as requiring dual controls -- impossible, of course, in a single seat airplane. In a previous post, I cited two relevant FARs, 61.56(a) which calls for "a minimum of 1 hour of flight training and 1 hour of ground training," and 91.109(a), that says "no person may operate a civil aircraft... that is being used for flight instruction unless that aircraft has fully functioning dual controls." My conclusion was that single-seat flight reviews were out.
I'm now ready to retract that interpretation. Bear in mind that I'm not an attorney, but this is my layman's interpretation: FAR 61.56(a) requires "flight training." FAR 91.109(a) requires dual controls for "flight instruction." Instruction and training are not the same thing! Furthermore, neither term is explicitly defined in FAR 1.1, General Definitions.
To those of you who are about to request a Letter of Interpretation from FAA Legal, I would caution that such a request can easily backfire on you. It's sometimes better to leave things ambiguous than to request a clarification that we're not going to like. But that's fodder for a completely different thread.
There used to be a commonly accepted procedure in place for satisfying a Flight Review (previously called a BFR) in a single-seat aircraft. This involved the supervising instructor watching the pilot fly, talking to him or her on the radio, and the pilot demonstrating requested maneuvers. At the time, the BFR requirement was open-ended, not specifying any minimum flight time, or ground training time, or particular maneuvers. This was all left to the discretion of the CFI.
A few years ago, the FAA changed the Flight Review rules. They deleted the term "biennial" (probably because some folks couldn't distinguish between twice a year and once every two years), replacing it with the language "flight review within the previous 24 calendar months". They also did away with CFI discretion, to the extent that a flight review now must include a minimum of one hour of ground training, and one hour of flight training.
Here's where the single-seat flight review came under scrutiny. AOPA (and others) interpreted the one hour of flight training as requiring dual controls -- impossible, of course, in a single seat airplane. In a previous post, I cited two relevant FARs, 61.56(a) which calls for "a minimum of 1 hour of flight training and 1 hour of ground training," and 91.109(a), that says "no person may operate a civil aircraft... that is being used for flight instruction unless that aircraft has fully functioning dual controls." My conclusion was that single-seat flight reviews were out.
I'm now ready to retract that interpretation. Bear in mind that I'm not an attorney, but this is my layman's interpretation: FAR 61.56(a) requires "flight training." FAR 91.109(a) requires dual controls for "flight instruction." Instruction and training are not the same thing! Furthermore, neither term is explicitly defined in FAR 1.1, General Definitions.
To those of you who are about to request a Letter of Interpretation from FAA Legal, I would caution that such a request can easily backfire on you. It's sometimes better to leave things ambiguous than to request a clarification that we're not going to like. But that's fodder for a completely different thread.