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Providing flight review in airplane outside of CFIs qualifications?

Asked by: 1685 views FAA Regulations

Can a CFI provide flight reviews in aircraft they are not rated to fly? Can a CFI provide a flight review in a complex airplane with no complex endorsement if the pilot is rated and PIC current? How about a CFI with no multi engine rating providing a flight review in a Multiengine airplane if the pilot is rated and PIC current? Please leave references.

 

Does a CFI always have to log and act as PIC to give instruction? Can a CFI instruct without logging, acting as, or being PIC if the pilot they are flying with is capable and authorized of being PIC?

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4 Answers



  1. Mark Kolber on Apr 15, 2023

    A CFI cannot do a flight review in an airplane they are not rated for. So no, a CFI with only an ASE rating cannot do a flight review in a multi. The complex airplane is different. An endorsement is not a rating. There is nothing regulatory **directly** prohibiting a CFI with no complex or tailwheel endorsement from giving a flight review in a complex or tailwheel airplane. But there are indications that the FAA would frown upon it.

    No pilot has to log anything unless it’s needed for qualification or currency. But the answer to your second question comes down to this. A CFI doesn’t not formally have to be in command, but the FAA will treat a CFI giving instruction as though they were the pilot in command. Basically, when we are giving instruction we are, as the cases put it, “always deemed to be the pilot in command.” Whether we are or not PIC in the regulatory sense, whether we are capable or not of even acting as PIC (ie, no medical certificate at all), we have the same responsibilities as though we were PIC.

    Let’s return to your complex example. There’s a gear up during the flight review. Your logbook is reviewed during the investigation. The FAA discovers you have never even done the 1-2 flights to get the endorsement. They ask, “what made you think you were qualified to teach someone else in an airplane you were not qualified to fly yourself?”

    Your answer is…?

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  2. Jeff Baum on Apr 15, 2023

    Mark answered your questions quite well.

    You asked for references. Here you go…

    61.195 Flight instructor limitations and qualifications.
    A person who holds a flight instructor certificate is subject to the following limitations:

    (b) Aircraft ratings. Except as provided in paragraph (c) of this section, a flight instructor may not conduct flight training in any aircraft unless the flight instructor:

    (1) Holds a flight instructor certificate with the applicable category and class rating;

    (2) Holds a pilot certificate with the applicable category and class rating; and

    (3) Meets the requirements of paragraph (e) of this section, if applicable.

    And, yes, a Flight Review is providing training.

    Advisory Circular 61-98D “…guidance for Flight Reviews…”

    4.2.5 Instructor Qualifications. Instructors should also consider their own experience and qualifications in a given Make/Model aircraft prior to giving a review in that model.

    The flight instructor conducting a flight review must hold a category, class, and (if appropriate) type rating on his or her pilot certificate. Also, the instructor must have a category and class rating on his or her flight instructor certificate or a sport instructor privilege in his or her logbook appropriate to the aircraft in which he or she conducts the review.

    To conduct a flight review in a multiengine airplane, the instructor must hold an airplane multiengine rating on his or her pilot and flight instructor certificate.

    For aircraft in which the flight instructor is not current or with which he or she is not familiar, he or she should obtain recent flight experience or sufficient knowledge of aircraft limitations, characteristics, and performance before conducting the review.

    In the 45 years of teaching flying and my years acting as a DPE, I’ve only had one person with whom I worked involved in a fatal accident (a Flight Review which I gave almost a year prior to the accident). One of the first people the FAA wants to talk with after an accident is the last CFI. They asked about my qualifications, what training I provided, if I used a syllabus and did I notice any indications of future problems. Imagine if I had said that I provided instruction in an airplane which I was not qualified to fly as PIC. It would have quickly moved from a friendly information gathering conversation to something considerably less friendly.

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  3. KDS on Apr 18, 2023

    Mark, the answer to your question is a well-worn line that applies to many endeavors gone wrong

    “It seemed like a good idea at the time.”

    Bill Cosby

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  4. Mark Kolber on Apr 19, 2023

    KDS, and it will probably work just as well 😀

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