This question comes from Clayton:
I am a commercial pilot, single and multi engine ratings with instrument privilages. I am also a CFI single engine land.I recently received my CFI ticket and I’m confused on if the CFI ride counts as a biannual. Regs say that any additional rating qualifies as biannual but since the CFI is a different certificate will I still have to have a biannual?
To start let’s review the regulation that discusses flight reviews, 14 CFR 61.56. If you look at paragraph (d) it states that a “pilot who has passed a pilot proficiency check does not need to accomplish the flight review required by this section.” So does a CFI checkride count as a pilot proficiency check?
The answer is No. Why? Well, because the FAA specifically says so. Not in the regulation of course (that would be too easy) but in this recently released request for interpretation on 14 CFR 61.56(D) They specifically state that:
The answer is that a successful completion of a flight instructor practical test within the preceding 24 calendar months does not automatically relieve a pilot of the requirement to complete §61.56 flight review. A flight instructor practical test is not a pilot proficiency check for a pilot certificate, rating or an operating privilege, or any other acceptable substitute for a flight review specifically listed in § 61.56(d). A flight instructor practical test is not primarily focused on piloting skills but rather on one’s instructional skills. Thus, prima facie, it does not constitute a pilot proficiency check adequate to substitute for a flight review, as specified under § 61.56(d).
One way around this however (and the FAA ruling says so) is to request from your DE that your BFR and CFI checkride be done in conjunction. Acoording to the regs, a flight review requires one hour of ground and flight training. I don’t know about you, but my CFI checkride lasted A LOT longer than one hour on both the ground and flight portion of the practical test. Just be sure that your DE puts in an additional endorsement in your lookbook that attests to the fact that you have met the requirements of 61.56.
Congratulations on your CFI. Hopefully this helps you some.
Here is the link again to this FAA interpretation.
Fly Safe!
I’m not sure that yours is a fair interpretation of the letter you reference in your reply to the original poster. There is a reason that the FAA specifically used the phrase ‘prima facie’ is a latin phrase that means, ‘on first inspection’ or ‘at first appearance’.
If you talk to many CFI’s who have had their checkride done directly with the FAA you will likely find individuals who have had a ‘ride’ that lasted from five to six hours on just the oral alone. In the process one not only has to demonstrate the knowledge of a Commercial Pilot, but also must demonstrate the skill of flight instructor to TEACH the concept as well as just understand it. The same is true for the CFI ride (often 4 to 5 hours when done with the FAA directly). Not only does one have to demonstrate Commercial Pilot maneuvers to Commercial standards, one must ALSO be able to TEACH those maneuvers as well. The Commercial BFR’s I’ve had, pale in comparison to the one I did for my Flight Instructor certificate. IMHO, the CFI ‘ride meets the requirements to the Nth degree; easily meeting the prima facie standard that must be met in common law jurisdictions.
Hi Eddie,
Thanks for your input on the FAA letter.
I agree with you. My CFI checkride was by far the most grueling checkride of my flight career to date and that is including many type ratings, Part 135 and Part 121 checkrides as well. I don’t think any examiner or FAA administrator would say that I didn’t meet the requirements of 61.56 when I took my CFI checkride.
However…
I think the intended purpose of the FAA letter is to say that when it comes right down to it, the CFI checkride is technically not a BFR. If for some reason, there was a question about your recency or currency of experience and you pointed to the date of your CFI checkride as your last BFR, it wouldn’t cut it…technically. Now, your right, a CFI checkride can meet the requirements for a BFR but it is up to the discretion of the examiner to give you a separate logbook endorsement for that. If you get that BFR endorsement when you take your CFI checkride (which I think 99.9% of all examiners would do) than you would, of course, be fine.
I understand your point. But to answer the original poster’s question…you need a separate endorsement for the BFR. Not necessarily another ride or review, but a separate endorsement is required to meet the requirements of 61.56. (also IMHO)
Thanks again Eddie.
Hi To all,
I will need a BFR by the end of this month (July) but will start an excellerated training program for my Multi-Enginer Add On to my Commercial certificate.
Can I count the training time as PIC and then consider my check ride sufficient to meet the BFR requirements.
Thanks for the answer
John
John,
If you take your checkride by the end of the month, then you would fall under the exception to the flight review requirement. 61.56(D)
If you don’t take your checkride by the end of the month, then you could count the training time towards the BFR. Just make sure your instructor covers general and flight operating rules (p.91) during the required 1 hour ground training. You’ll also need to make sure that he endorses your logbook for the BFR.
Here is a link to 61.56: http://tinyurl.com/5qyxms
Good luck with your Multi-Engine. What are you training in?