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?