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Can/Do Sport Pilot and Sport Pilot CFI additional rating proficiency checks conducted by a CFI count towards flight review and CFI renewal (non-expired)?

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FAA Regulations, Flight Instructor, General Aviation, Light Sport Aircraft

Can/Do Sport Pilot and Sport Pilot CFI additional rating proficiency checks conducted by a CFI count towards flight review and CFI renewal (non-expired)?

I have researched countless pages and cannot find a clear answer. Maybe the answer is valid by exclusion of certain verbiage, but I still need the opinion of another. 

I am a commercial pilot and (subpart H) CFI.  I recently added sport (subpart J) pilot Rotorcraft Gyroplane to my pilot certificate as well as sport pilot CFI (subpart K) Rotorcraft Gyroplane to my CFI privileges.

 

I completed these additional category/class ratings through the proficiency checks required by 61.321 and 61.419. Both regs basically require the following:

1. Train to proficiency on the areas of operations with CFI #1 and get an endorsement to take the proficiency check.

2. Get with CFI #2 and take the proficiency check per the regs.

3. Fill out paperwork and mail it to the FAA.

4. Have CFI #2 sign your logbook with the endorsement of passing the proficiency check for that additional LSA category/class rating. 

I did this for both sport pilot and sport CFI. 

Now let’s look at the regs for flight review and CFI renewal:

 

Flight review: 61.56(d) 

d) A person who has, within the period specified in paragraph (c) of this section, passed any of
the following need not accomplish the flight review required by this section:
(1) A pilot proficiency check or practical test conducted by an examiner, an approved pilot check
airman, or a U.S. Armed Force, for a pilot certificate, rating, or.
(2) A practical test conducted by an examiner for the issuance of a flight instructor certificate,
an additional rating on a flight instructor certificate, renewal of a flight instructor certificate, or
reinstatement of a flight instructor certificate.

 

To renew any CFI in subpart H or K, you follow the subpart H requirements in 61.197:

a) A person who holds a flight instructor certificate that has not expired may renew that flight
instructor certificate by—
(1) Passing a practical test for—
(i) One of the ratings listed on the current flight instructor certificate; or
(ii) An additional flight instructor rating; or

The rest of that reg isn’t applicable…

 

QUESTION:

1. Does the proficiency check completed by a flight Instructor count for the flight review?

2. Is a flight instructor conducting the proficiency check considered an examiner?

3. Is the proficiency check considered a practical test?

4. Does passing the additional cat/class sport pilot CFI rating count as an additional rating for renewing my CFI?

 

I think the answer entirely depends on the definition of practical test, proficiency check, pilot proficiency check, and examiner.

 

what do you think?

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3 Answers



  1. LTCTerry on Jul 01, 2021

    1. I understand that a Sport Pilot privilege add on counts as a flight review. I’ve not found it myself, but a recent article in the Soaring Society’s magazine described it as giving 61.56 flight review credit.

    2. No. Examiners have something that designates them as examiners. CFIs giving proficiency checks are not examining, they are checking…

    3. No. Sport Pilots have privileges not ratings.

    4. No. Same as 3.

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  2. Max Trescott, Aviation News Talk podcast host on Jul 01, 2021

    To answer your questions:
    1. No. The proficiency check referred to is the annual recurrent training required of pilots rated in a turbojet or other aircraft requiring a type rating.
    2. No. A flight instructor cannot conduct a pilot proficiency check. It can only be conducted by a PPE, or Pilot Proficiency Examiner.
    3. No. A pilot proficiency check is very similar to a checkride, but it’s not identical to the practical test a pilot needs to pass to get a type rating.
    4. I don’t know, but I doubt it. Typically the only two additional CFI ratings that would count toward renewal would be the CFII and MEI checkrides.

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  3. Mark Kolber on Jul 02, 2021

    Does it? As in automatically? No. The FAR 321(b) “second CFI” proficiency check is not the proficiency check described in 61.56(d).

    Can it? Of course. If based on the flight and ground tasks covered (and the required Part 91 review), the CFI is satisfied you, in the words if the reg, “demonstrate the safe exercise of the privileges of the pilot certificate,” he or she can endorse the flight review.

    On the sport CFI question, it’s a little less clear, but I’ll go with the same answer, in part because sport pilots and sport CFIs don’t have category and class ratings.

    What it comes down to is the difference between a privilege “endorsement” and a “rating.”

    “Ratings” are placed on pilot certificates in the section entitled “ratings.” If you look at your sport CFI certificate, you’ll see that the rating is, “sport pilot.” That’s your only “rating” as a CFI.

    “Endorsements,” whether tailwheel, high performance, complex, or sport pilot additional category/class/cross country/are not “ratings.”

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