Flight Review
Votes
Joined 01/06/2020 - 15 Posts
Answered By AOPA
I’m adding a helicopter rating to my Private Pilot certificate. My flight review is going to run out soon. Can I just get a flight review in the helicopter since I’m training in it currently?
9 Replies
Votes
Joined 01/30/2020 - 67 Posts
AOPA Staff Answer
Unfortunately, no. A flight review needs to be completed in an aircraft you’re rated in (FAR 61.56) https://www.ecfr.gov/cgi-bin/text-idx?SID=35bbff993cfabd2aa106478410a6c32d&mc=true&node=se14.2.61_156&rgn=div8 . Since you aren’t currently rated in helicopters you cannot accomplish a flight review in one.
Votes
Joined 01/05/2018 - 37 Posts
Not completely correct.  By obtaining a new rating, you have also accomplished the requirements for a flight review.  See 61.56 (d)(2).

You can continue as the helicopter student without a current flight review.  However, if you wish to keep flying f/w, you would have to get f/w flight review.  Best to just finish your add-on and good to go for two years in either category.
Votes
Joined 06/11/2017 - 789 Posts
Richard Campbell:
Not completely correct.  By obtaining a new rating, you have also accomplished the requirements for a flight review.  See 61.56 (d)(2).

You can continue as the helicopter student without a current flight review.  However, if you wish to keep flying f/w, you would have to get f/w flight review.  Best to just finish your add-on and good to go for two years in either category.

If her FR runs out before she takes the helo practical test, she would not be able to act as PIC.  That would prevent her from flying solo in the helicopter.  Since Sherry is not a Student Pilot, any solo she is doing in a helo would be under a 61.31(d)(2) endorsement, not 61.87, so she would not be be able to take advantage take of the exception in 61.56(g).  Also, this would create a problem for the helo practical test unless the examiner agrees to act as PIC during the test.  Unless she's going to take the helo practical test before her current flight review runs out, it's probably best if she gets a flight review in something in which she is rated before that happens.

Votes
Joined 01/30/2020 - 67 Posts
Thanks Ron, you're absolutely correct.
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Joined 01/05/2018 - 37 Posts
Well, then my Part 141 school got it wrong when I did my add-on, because I had not had a flight review in many years.  61.56(g) says "student pilot" in a generic sense it seems to me.  So not being rotorcraft rated, I would be a student in that Category, and could solo under 61.87 with the endorsement.  The DPE never questioned it either.
Votes
Joined 06/11/2017 - 789 Posts
Richard Campbell:
Well, then my Part 141 school got it wrong when I did my add-on, because I had not had a flight review in many years.  61.56(g) says "student pilot" in a generic sense it seems to me.  So not being rotorcraft rated, I would be a student in that Category, and could solo under 61.87 with the endorsement.

Yes, your school got it wrong, and NO, you CANNOT use a 61.87 endorsement for someone whose pilot certificate doesn't say "STUDENT PILOT".  A sharp-eyed DPE would have kicked you back to the school if you showed up for that helo test with the wrong solo endorsement and no current flight review.  61.56(g) specifically says "student pilot" (the lack of capitalization isn't relevant -- they do that everywhere in Part 61) and references 61.87, which is under the Student Pilot Subpart C of Part 61.  See 61.81 Applicability in Subpart C. If you held anything else at the time (Rec, Sport, Private, etc), you are not the holder of a student pilot certificate, and Subpart C doesn't apply.  They should have given you a 61.31(d)(2) logbook endorsement for solo in that helo, and in that case, you'd need a current flight review to be legal for solo and to be PIC on the practical test.

And let me reiterate -- there's no such thing as being " a student in that Category".  It's what's written on the front of your pilot certificate that determines whether you're a Student, Recreational, Sport, Private, Commercial, or Airplane Transport pilot.  Everything else regarding category/class/type privileges is governed by the ratings/limitations on the back of the certificate and endorsements in your logbook.  Someone with a commercial certificate and ASMEL ratings who gets an ATP certificate in a twin will have AIRLINE TRANSPORT PILOT on the front, and the back will say:

AIRPLANE MULTIENGINE LAND
COMMERCIAL PRIVILEGES AIRPLANE SINGLE ENGINE LAND

That person is an ATP no matter what they're flying, but they can only exercise commercial privileges in singles.

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Joined 01/05/2018 - 37 Posts
Interesting.  Although I haven't had any contact with my flight school in a few years, I'll pass this along to the Chief Pilot.
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Joined 06/11/2017 - 789 Posts
Richard Campbell:
Interesting.  Although I haven't had any contact with my flight school in a few years, I'll pass this along to the Chief Pilot.

There are lots of little "gotchas" buried in the FAR's, and this is one of them.  But if that school does a lot of add-ons rather than initial pilot training in helos, they should know better, especially if they're a 141 school under the extra scrutiny the FSDO gives such schools.

Votes
Joined 01/30/2020 - 67 Posts
Here's a letter of interpretation that talks about this flight review requirement for already certificated pilots exercising solo privileges under 61.31(d); https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2015/Beard%20-%20(2015)%20Legal%20Interpretation.pdf  . The whole letter is good, but this specific information starts at the last paragraph on the first page.