Can you get a flight review in a plane you're not rated in?

BrianNC

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For instance, I'm SEL. Could I actually do a flight review in a twin, then go on to complete that for a multi engine rating, but get the review done before getting the multi rating?

Or another scenario, go for the multi engine rating, and then when getting the rating, that was a flight review also? Or do I need that flight review in a single then go on for other ratings?

I am in need of a flight review, but going to start training for ME soon, so just wondering if I can basically kill two birds with one stone.
 
61.56(c)(1) suggests the flight review must be in an aircraft "for which that pilot is rated". So, while the practical test would work (61.56(d)(2)), the training itself wouldn't.
 
For instance, I'm SEL. Could I actually do a flight review in a twin, then go on to complete that for a multi engine rating, but get the review done before getting the multi rating?

Or another scenario, go for the multi engine rating, and then when getting the rating, that was a flight review also? Or do I need that flight review in a single then go on for other ratings?

I am in need of a flight review, but going to start training for ME soon, so just wondering if I can basically kill two birds with one stone.
By the time you got familiar enough to pass a FR in the twin you would be about ready for your ME ride.
 
61.56(c)(1) suggests the flight review must be in an aircraft "for which that pilot is rated". So, while the practical test would work (61.56(d)(2)), the training itself wouldn't.
By the time you got familiar enough to pass a FR in the twin you would be about ready for your ME ride.

So in other words, don't worry about the flightt review and just let the checkride suffice.
 
Lots of people add certificates and ratings in lieu of flight reviews. It's more expensive, of course, but it's good to learn new stuff and have your flying evaluated on a regular basis. Besides, you never know when you'll need that multiengine seaplane rating on your ATP certificate.
 
One other question related to this. Say I go for the multi, but combine it with initial commercial rating (I don't have a single commercial). I assume there is no advantage to getting a single engine flight review since none of my training in the multi will be PIC time anyway. Is there any advantage at all to getting a single flight review before I go for an initial commercial multi? I can't think of any off the top of my head. Just want to make sure I'm not missing something.
 
You could take the Commercial written test, do the multi training and complete a Commercial Pilot check ride in the multi. Your Certificate would then read "Commercial Pilot" on the front. On the back it would list Airplane Multiengine Land, Private privileges Airplane Single Engine Land.

You would have completed the Flight Review requirement by completing a check ride. You would be able to fly with Commercial privileges in multi engine, but only private privileges in single engine.

If you are instrument rated, be prepared to complete approaches and other maneuvers to include engine out operations under the hood and you will have instrument privileges in multi. Otherwise it would say VFR only.
 
Chief Counsel's office says you need the FR when training for a new rating because you're a certificated pilot. The only carve out in the regs is for Student Pilots flying on a solo endorsement. No carve out for an expired pilot training for a new category/class.

Chief Counsel also recognizes in the letter that this is a problem and told the regulatory folks to fix it. In April of 2016.

https://www.faa.gov/about/office_or...ing Academy - (2016) Legal Interpretation.pdf

It has not yet been fixed.

It's really common for a pilot who's out of currency to come back to the airport, grab a CFI, and start training for a new rating to both get new skills and also to get current again.

Regs technically don't allow it.

Here's the real problem with it. Let's say you're a lighter than air pilot in your twenties and then stop flying. Now you come back in your 40s to get an ASEL. Are you really going to go get a balloon FR so you can solo an airplane?

It's jacked.
 
So in other words, don't worry about the flightt review and just let the checkride suffice.

Can't if you're rated and the FR has expired. See above Chief Cousel letter.

Yup... that's what I would do.

See above.

Lots of people add certificates and ratings in lieu of flight reviews.

Can only do it if you have a current FR. If FR is expired you have to get it current.

You would have completed the Flight Review requirement by completing a check ride.

Can only do that if you have a current FR in - category/class you hold a rating in.

Just tagging folks who may not know because that 2016 letter isn't widely known.

Blame it on @midlifeflyer. He originally pointed it out to me. Hahaha.
 
P.S. In case it's not clear from my sarcasm in the post -- this FR thing for a pilot training for new rating is STUPID.

Let's toss another regulatory mess into this, since this is a *multi* rating...

During training, it's unlikely a non-student pilot seeking to add AMEL would ever be solo. The insurance companies won't allow it.

Thus the carve out in the multi engine prerequisite flight time regs (my emphasis surrounded by ***** below):

"10 hours of solo flight time in a multiengine airplane ***** or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor **** (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), "

So... you're never truly alone in the aircraft. During training. Or don't have to be. They carved this out because you can't get insurance to solo in a twin. Or maybe you can, but it'll cost more than your car. Probably. Whatever. Obviously a carve for insurance problems, either way.

And 61.47 says during an examination ...

"(c) Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter."

So...

Many would say that the multi candidate is never solo and never carrying passengers during training or on the checkride so... they're good.

As compared to say, a glider student adding a glider rating when they're an expired FR ASEL power pilot. They're hosed.

But...

I think the wording of the examination carve out is specifically intended to allow you not to call the examiner a passenger when you're not rated to carry passengers, and also vice-versa so the examiner doesn't have to be PIC to carry the candidate aloft as a passenger and not rated pilot.

But... It still doesn't let the rated pilot candidate off the hook for needing an FR to fly. Passengers or none.

Which... is the problem. And is just a total freaking mess.

I think you SHOULD be able to go, as an expired FR pilot, train with an instructor, add a rating, and have it count for the FR. But you see where the problem / hole in the regs is when you dig in and look.

You can't. And it's really really dumb.

Like @Kritchlow said about his checklist story of what the FAA had approved for his aircraft at a Part 135 which made no sense... this also makes no sense... and "You just can't make this stuff up."

LOL. Sorry man. Best plan: Get the FR done in a category and class you're rated in, and then add the multi.

Or find an instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation (as you can see above, the vast majority of pilots and instructors think a new rating resets the FR clock -- it does -- and you can train and fly the checkride in the multi without needing the FR -- maybe you can, maybe you can't, but only because it's a multi and you don't have to solo it... or maybe you need the FR anyway because you can't act as PIC of any aircraft without one.

LOL. Clear as mud, ain't it? :)
 
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For instance, I'm SEL. Could I actually do a flight review in a twin, then go on to complete that for a multi engine rating, but get the review done before getting the multi rating?

Or another scenario, go for the multi engine rating, and then when getting the rating, that was a flight review also? Or do I need that flight review in a single then go on for other ratings?

I am in need of a flight review, but going to start training for ME soon, so just wondering if I can basically kill two birds with one stone.

You might want to review the day/night currency requirements as well. You cannot combine MEL and SEL landings to meet the passenger carrying requirements.

61.57
(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and—

(i) The person acted as the sole manipulator of the flight controls; and

(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel.
 
Or find an instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation (as you can see above, the vast majority of pilots and instructors think a new rating resets the FR clock -- it does -- and you can train and fly the checkride in the multi without needing the FR -- maybe you can, maybe you can't, but only because it's a multi and you don't have to solo it... or maybe you need the FR anyway because you can't act as PIC of any aircraft without one.

LOL. Clear as mud, ain't it? :)

I was actually discussing this with the owner of the flight school who is is also a DPE where I was going to do this and it never came up, so apparently he hasn't read the April '16 interpretation because he never brought this up. He seemed to be ok with it. And he would be the one doing the check ride.

As far as maybe needing the FR anyway because I can't act as PIC, I had brought up earlier that in multi training you aren't the PIC anyway because you don't have that rating yet, so my theory was that didn't matter that you can't act as the PIC.

I guess the question is, since you mentioned "Or find and instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation" which I apparently have done, is it 'technically' ok? Would this ever be an issue or even be noticed or would anybody really care?
 
P.S. In case it's not clear from my sarcasm in the post -- this FR thing for a pilot training for new rating is STUPID.

Let's toss another regulatory mess into this, since this is a *multi* rating...

During training, it's unlikely a non-student pilot seeking to add AMEL would ever be solo. The insurance companies won't allow it.

Thus the carve out in the multi engine prerequisite flight time regs (my emphasis surrounded by ***** below):

"10 hours of solo flight time in a multiengine airplane ***** or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor **** (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), "

So... you're never truly alone in the aircraft. During training. Or don't have to be. They carved this out because you can't get insurance to solo in a twin. Or maybe you can, but it'll cost more than your car. Probably. Whatever. Obviously a carve for insurance problems, either way.

And 61.47 says during an examination ...

"(c) Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter."

So...

Many would say that the multi candidate is never solo and never carrying passengers during training or on the checkride so... they're good.

As compared to say, a glider student adding a glider rating when they're an expired FR ASEL power pilot. They're hosed.

But...

I think the wording of the examination carve out is specifically intended to allow you not to call the examiner a passenger when you're not rated to carry passengers, and also vice-versa so the examiner doesn't have to be PIC to carry the candidate aloft as a passenger and not rated pilot.

But... It still doesn't let the rated pilot candidate off the hook for needing an FR to fly. Passengers or none.

Which... is the problem. And is just a total freaking mess.

I think you SHOULD be able to go, as an expired FR pilot, train with an instructor, add a rating, and have it count for the FR. But you see where the problem / hole in the regs is when you dig in and look.

You can't. And it's really really dumb.

Like @Kritchlow said about his checklist story of what the FAA had approved for his aircraft at a Part 135 which made no sense... this also makes no sense... and "You just can't make this stuff up."

LOL. Sorry man. Best plan: Get the FR done in a category and class you're rated in, and then add the multi.

Or find an instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation (as you can see above, the vast majority of pilots and instructors think a new rating resets the FR clock -- it does -- and you can train and fly the checkride in the multi without needing the FR -- maybe you can, maybe you can't, but only because it's a multi and you don't have to solo it... or maybe you need the FR anyway because you can't act as PIC of any aircraft without one.

LOL. Clear as mud, ain't it? :)
Wow. I had no inkling of this problem. Well I'm neither a CFI nor a FAR expert, but my reading is the only way this would work is if the DPE agreed to be PIC for the checkride, since the candidate isn't otherwise PIC qualified (other than not having the multi rating). He could train and "solo" based on the carve-out you quoted ("performing the duties of PIC" with a CFI on board) but the checkride would still be a problem.
 
You would have completed the Flight Review requirement by completing a check ride.
Just to pick nits... ;)

61.56(d), (e), and (g) discuss pilots who "need not accomplish" a flight review. The flight review requirement isn't completed, the need for it is negated for the time being.
 
I was actually discussing this with the owner of the flight school who is is also a DPE where I was going to do this and it never came up, so apparently he hasn't read the April '16 interpretation because he never brought this up. He seemed to be ok with it. And he would be the one doing the check ride.

As far as maybe needing the FR anyway because I can't act as PIC, I had brought up earlier that in multi training you aren't the PIC anyway because you don't have that rating yet, so my theory was that didn't matter that you can't act as the PIC.

I guess the question is, since you mentioned "Or find and instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation" which I apparently have done, is it 'technically' ok? Would this ever be an issue or even be noticed or would anybody really care?
There have been situations in which a completed checkride has been reversed doe to a later-noticed lack of qualification, but it would be rare.

If you look at that interpretation, it does not say you need a FR to train for a new certificate or rating. It says you need to have an FR in order to exercise the solo endorsement for a new category or class. I'd say most folks, for example, do their multi add-on without ever soloing.

So the real question is, do you need a solo endorsement to take a checkride? If you don't, I'm not sure the 2016 Bennett Interpretation is relevant. (I think I once had an answer to that one but I can't recall it, so maybe someone else does)
 
Can't if you're rated and the FR has expired. See above Chief Cousel letter.



See above.



Can only do it if you have a current FR. If FR is expired you have to get it current.



Can only do that if you have a current FR in - category/class you hold a rating in.

Just tagging folks who may not know because that 2016 letter isn't widely known.

Blame it on @midlifeflyer. He originally pointed it out to me. Hahaha.
Would not any rating cover the flight review, or am I misinterpreptatting what you're saying?
 
Chief Counsel's office says you need the FR when training for a new rating because you're a certificated pilot. f

Wow, that's not at all what it says. You are twisting their words.

Many flight schools won't even let you solo a twin after your check ride let alone before.
 
I was actually discussing this with the owner of the flight school who is is also a DPE where I was going to do this and it never came up, so apparently he hasn't read the April '16 interpretation because he never brought this up. He seemed to be ok with it. And he would be the one doing the check ride.

As far as maybe needing the FR anyway because I can't act as PIC, I had brought up earlier that in multi training you aren't the PIC anyway because you don't have that rating yet, so my theory was that didn't matter that you can't act as the PIC.

I guess the question is, since you mentioned "Or find and instructor and examiner who aren't paying attention and haven't read the April 2016 interpretation" which I apparently have done, is it 'technically' ok? Would this ever be an issue or even be noticed or would anybody really care?

I wouldn't be asking on the internet. ;-)

Wow, that's not at all what it says. You are twisting their words.

Many flight schools won't even let you solo a twin after your check ride let alone before.

As @midlifeflyer said, the real question is if you need a solo *endorsement* to fly the checkride. You aren't qualified to be PIC yet, and the examiner also isn't PIC.

If you have a current FR it seems FAA looks the other way, if you don't, nobody knows.

The Chief Counsel clearly says it needs to be fixed via regulation change. They aren't budging from the letter of the law. And what's in the letter of the law isn't common practice.

I've never seen any MEI sign a solo endorsement ever for a checkride. They sign that the candidate is ready for the checkride.

An additional question is who knows what the insurance company would say a checkride is if a wreck happened. There's no PIC qualified under the insurance rules unless the policy says checkrides are ok. It's a mess.

Is it done all the time? Yes. Absolutely. Is it a disaster waiting to happen for someone's estate legally? Probably.

Get good twin training and don't break the airplane on the checkride. I guess.

It's be nice if the regulatory folks would fix what their own lawyers said is broken.

Where the regs really hurt, like I said, is in adding a glider rating to a pilot who's out of currency. They need to solo. So they have to go get an FR unless nobody pays any attention to the 2016 letter. Or my hypothetical balloonist turned airplane pilot later in life scenario.
 
I wouldn't be asking on the internet. ;-)

Get good twin training and don't break the airplane on the checkride. I guess.

Sounds like a plan.
whistle.gif
 
Can't if you're rated and the FR has expired. See above Chief Cousel letter.



See above.



Can only do it if you have a current FR. If FR is expired you have to get it current.



Can only do that if you have a current FR in - category/class you hold a rating in.

Just tagging folks who may not know because that 2016 letter isn't widely known.

Blame it on @midlifeflyer. He originally pointed it out to me. Hahaha.
On the presumption the current FR has not expired.

Yes that letter has grounded a few students at our soaring club.
Never never ever ask the FAA a question that you don't already know the outcome. You may not like what you are told.
 
On the presumption the current FR has not expired.

Yes that letter has grounded a few students at our soaring club.
Never never ever ask the FAA a question that you don't already know the outcome. You may not like what you are told.

Well one of the assumptions people also have is that if the answer is "this law was badly written" that someone will actually fix it in a timely manner.

But that's not usually what happens.

Certainly haven't seen an NPRM yet on this one...
 
I've got one if you'd like to see what one looks like.

Heh. Cool. Sounds like someone is reading all this stuff. ;)

Of course the question then becomes what the insurance company thinks of it in a multi... most probably say flat out, "No".

And I doubt too many owners have asked the insurer what they consider a checkride to be... the named insured isn't on board.

The candidate isn't PIC but is solo in a way, since they're not carrying a "passenger" at least in a legal sense... and the DPE usually isn't PIC either.

As a new multi instructor rated person, looking over the regs and how broken the mix of regs is plus the mess insurance is on them, I'm not particularly happy with the options for limiting my personal liability.

Real world, I have to believe I'll teach well enough nothing will happen. But in the legal world, it'd be nice if the DPE's or candidate's family couldn't take my house, over an accident during a checkride.

Be interesting to hear what a lawyer thinks of that. How would an aviation attorney suggest an MEI take reasonable precautions against legal action?

I'm guessing AOPA Legal Services ain't gonna help. LOL.
 
Would not any rating cover the flight review, or am I misinterpreptatting what you're saying?

I missed your question earlier. Sorry. Scrolled past it by accident.

It would, but you can't fly solo on the way to a rating if you're rated in another category/class and have an expired FR in that other category/class per the Beard letter.

And there's also the question of the checkride itself. You're not rated so you're either solo and without an FR unable to be PIC -- Chief Counsel says the regulatory folks need to fix that, since only Student Pilots can do that -- or you're PIC, and you can't be that without the FR in your old category/class.

So what are you on a checkride? I contend, no FR, no checkride.

But that's not the commonly held belief or completely common practice.

The glider CFIs have their attention level up in this regard because of the two letters both Beard and the 2016 letter but power CFIs haven't really picked up on this yet.

"Come on out and add a rating and that will reset your FR clock." Not necessarily possible because of the need to solo for some ratings and at least solo during the checkride for all unless the DPE agrees to be PIC.

If the DPE agrees to be PIC, that works. But they usually won't.

The Chief Counsel has said to glider folks: You can't sign off an expired FR power pilot to solo in gliders.

That interpretation has implications for other ratings then also.

Glider candidates have to renew their power FR before they can solo a glider. And they have to have two hours of glider solo to qualify for the rating. So they're stuck.

Must get an FR in whatever category and class they flew prior to gliders, before they can complete the solo requirement.

(Interesting loophole here. If they trained in the distant past, and had two hours of solo, think a DPE would accept that they had zero solo in prep for the checkride today but he required two hours twenty years ago? I doubt it. But technically legal. I think. Would any CFIG sign off ready for the ride with only solo time from twenty years ago? Almost zero chance, but again... could happen. I think.)

In multi ratings it gets weirder because FAA wrote a loophole into the solo time requirement. Can be done with an MEI on board as long as the candidate is "performing the duties of PIC".

(How different MEIs interpret that could be anything from sitting silently and saying nothing the entire flight (the least useful from a training perspective), to a full coordinated two person crew and candidate is making all flight decisions using on board resources including the MEI (the best option since that's what the candidate will need to do someday anyway), but there's certainly no FAA guidance that I've found on the matter. Obviously real world you're training someone to behave and act as a PIC throughout anyway, so... the reg carve out is obviously the FAA giving in to insurers. Insurers won't let ME candidates fly solo with standard insurance coverage anymore. Apparently they once did long ago, but that's way before my time. They got tired of paying for solo wrecks, I guess.)

And then there's the less common but possible jumps between other categories and classes. The balloonist-in-their-twenties who wants an ASEL in their forties.

They're still a rated pilot in lighter than air and need an FR in their original category and class if the rating they want to add has a solo requirement. That one really sucks.

(Ironically if they add an AMEL or AMES they can use the solo loophole to fly with the CFI, but the problem remains of "What are they during the checkride?")

I'm really tempted to ask a few DPEs what they think of this. None here that I know of ever accept PIC responsibility and are directed for the most part not to. I *think* they can make a special request of the FSDO and be PIC under special circumstances but not sure.

They ask to see your most current FR, and this is probably why. Expired FR... is a problem.

If an MEI *did* sign a solo endorsement specifically for the checkride, that's fine and allowed in the regs, but do they have an ethical responsibility to notify both the candidate and DPE that unless the DPE is PIC, the insurance company says there's no coverage?

The MEI has that option to sign a solo endorsement for the checkride. A CFI-G doesn't because of the oddball ME loophole.

I'll admit to not having a ME insurance policy here to look at, and definitely not a commercial training policy... if there's specific wording that checkrides are covered when the candidate is solo with an examiner, great. That portion is solved.

So... you can fly every hour needed for the ME add-on right up to the checkride with an expired FR and then you have to figure out if :

- The MEI signs off the candidate to solo for the checkride and possibly has zero insurance coverage because the candidate is solo. DPE remains a "non-passenger" per the checkride regs and not PIC.

- DPE accepts PIC responsibility for the flight either under the open pilot clause or some other clause in the insurance policy, or even as a named insured (unlikely).

Or...

- Just get an FR done. (Way simpler for an ASEL. Harder for different categories and classes.)

If a pilot certificate EXPIRED this would all be different. But since they don't, the FR becomes the controlling factor as to whether or not you can fly these things.

Fascinating mess, isn't it?
 
And there's also the question of the checkride itself. You're not rated so you're either solo and without an FR unable to be PIC -- Chief Counsel says the regulatory folks need to fix that, since only Student Pilots can do that -- or you're PIC, and you can't be that without the FR in your old category/class.
Yeah, that's the part that grabbed my attention. On the checkride the applicant is supposed to be PIC-qualified except for the rating itself - FR, medical (apparently can be BasicMed now) - and though the DPE can agree to be PIC, this is frowned on and most DPEs won't do it.

I also agree that this is yet another example of someone asking the Chief Counsel a question to which they (and we) couldn't stand the answer. Despite the way the reg was written, no one seemed to be worried about this before Beard... and now everyone going for ratings with an expired FR is screwed. (Well, not quite screwed, they just need to get an FR in a plane they're rated in first.)
 
I missed your question earlier. Sorry. Scrolled past it by accident.

It would, but you can't fly solo on the way to a rating if you're rated in another category/class and have an expired FR in that other category/class per the Beard letter.

And there's also the question of the checkride itself. You're not rated so you're either solo and without an FR unable to be PIC -- Chief Counsel says the regulatory folks need to fix that, since only Student Pilots can do that -- or you're PIC, and you can't be that without the FR in your old category/class.

So what are you on a checkride? I contend, no FR, no checkride.

But that's not the commonly held belief or completely common practice.

The glider CFIs have their attention level up in this regard because of the two letters both Beard and the 2016 letter but power CFIs haven't really picked up on this yet.

"Come on out and add a rating and that will reset your FR clock." Not necessarily possible because of the need to solo for some ratings and at least solo during the checkride for all unless the DPE agrees to be PIC.

If the DPE agrees to be PIC, that works. But they usually won't.

The Chief Counsel has said to glider folks: You can't sign off an expired FR power pilot to solo in gliders.

That interpretation has implications for other ratings then also.

Glider candidates have to renew their power FR before they can solo a glider. And they have to have two hours of glider solo to qualify for the rating. So they're stuck.

Must get an FR in whatever category and class they flew prior to gliders, before they can complete the solo requirement.

(Interesting loophole here. If they trained in the distant past, and had two hours of solo, think a DPE would accept that they had zero solo in prep for the checkride today but he required two hours twenty years ago? I doubt it. But technically legal. I think. Would any CFIG sign off ready for the ride with only solo time from twenty years ago? Almost zero chance, but again... could happen. I think.)

In multi ratings it gets weirder because FAA wrote a loophole into the solo time requirement. Can be done with an MEI on board as long as the candidate is "performing the duties of PIC".

(How different MEIs interpret that could be anything from sitting silently and saying nothing the entire flight (the least useful from a training perspective), to a full coordinated two person crew and candidate is making all flight decisions using on board resources including the MEI (the best option since that's what the candidate will need to do someday anyway), but there's certainly no FAA guidance that I've found on the matter. Obviously real world you're training someone to behave and act as a PIC throughout anyway, so... the reg carve out is obviously the FAA giving in to insurers. Insurers won't let ME candidates fly solo with standard insurance coverage anymore. Apparently they once did long ago, but that's way before my time. They got tired of paying for solo wrecks, I guess.)

And then there's the less common but possible jumps between other categories and classes. The balloonist-in-their-twenties who wants an ASEL in their forties.

They're still a rated pilot in lighter than air and need an FR in their original category and class if the rating they want to add has a solo requirement. That one really sucks.

(Ironically if they add an AMEL or AMES they can use the solo loophole to fly with the CFI, but the problem remains of "What are they during the checkride?")

I'm really tempted to ask a few DPEs what they think of this. None here that I know of ever accept PIC responsibility and are directed for the most part not to. I *think* they can make a special request of the FSDO and be PIC under special circumstances but not sure.

They ask to see your most current FR, and this is probably why. Expired FR... is a problem.

If an MEI *did* sign a solo endorsement specifically for the checkride, that's fine and allowed in the regs, but do they have an ethical responsibility to notify both the candidate and DPE that unless the DPE is PIC, the insurance company says there's no coverage?

The MEI has that option to sign a solo endorsement for the checkride. A CFI-G doesn't because of the oddball ME loophole.

I'll admit to not having a ME insurance policy here to look at, and definitely not a commercial training policy... if there's specific wording that checkrides are covered when the candidate is solo with an examiner, great. That portion is solved.

So... you can fly every hour needed for the ME add-on right up to the checkride with an expired FR and then you have to figure out if :

- The MEI signs off the candidate to solo for the checkride and possibly has zero insurance coverage because the candidate is solo. DPE remains a "non-passenger" per the checkride regs and not PIC.

- DPE accepts PIC responsibility for the flight either under the open pilot clause or some other clause in the insurance policy, or even as a named insured (unlikely).

Or...

- Just get an FR done. (Way simpler for an ASEL. Harder for different categories and classes.)

If a pilot certificate EXPIRED this would all be different. But since they don't, the FR becomes the controlling factor as to whether or not you can fly these things.

Fascinating mess, isn't it?

Uncle!!!








:D
 

LOL! That's what I said when I first started trying to figure it out!!!

The Chief Cousel letters are an enormous PITA because frankly, most pilots an many instructors don't read them, don't know about them, and will say (even in light of a letter printed out and handed to them), "That's not what the regs say!"
 
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