Can a pilot use WINGS program if their flight review is expired?
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Open
A few instructors have differing opinions.
61.56c covers flight reviews

(c) Except as provided in paragraphs (d), (e), and (g) of this section, no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command, that person has -

(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor and

(2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review.


61.56e
(e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily accomplished one or more phases of an FAA-sponsored pilot proficiency award program need not accomplish the flight review required by this section.

AC 61-91J - in section 5b really just quote 61.56e and doesn't seem to offer much/any clarity.

So the question is with regards to the statement "within the period specified in paragraph (c) of this section"  statement.  

Does this mean, that the phase of WINGS needs to all be completed before a flight review runs out?  If so, they would need a flight review?

Example 1 - Pilot has a flight review on 9/15/2018.  He conducts three flight activities on 9/15/2019.  He also does two knowledge courses.  Then on 10/1/2020 he realizes his flight review ran out.  So on 10/5/2020 he takes the one missing knowledge course and prints his WINGS card and puts it in his logbook.

Example 2. Same pilot but does not do any flights or online courses.  On 10/1/2020 he takes three different online courses, then on 10/5/2020 he flies three flight profiles with an instructor.  The instructor validates the 3 flight profiles.  The pilot prints out his WINGS card and puts it in his logbook.

Both examples seem to be against what 6156e is suggesting.  Both examples provides a valid WINGS card from the FAA site.  Is he/she legal to fly?
7 Replies
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1013 Posts
Lonzo Mc Laughlin:

I'm taking it that if a pilot  has a WINGS completion certificate, we can take that at face value and we don't have responsibility to dig deeper.

I think that's the bottom line -- if the WINGS certificate shows a completion date within the 24 calendar months preceding the flight you intend to make, your flight review square is filled.

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Thanks everyone this has been helpful.   This has presented some clarity.

There were some folks suggesting 61.56c time period is controlling when/if WINGS can be used.  It was helpful to additionally look at 61.56d.  The same argument would suggest that if an applicant took a check ride with a DPE without a current flight review (DPE acting as PIC) that in this case 61.56d wouldn't allow the new rating to count as a flight review.  I think folks would quickly realize this doesn't make sense.  61.56 is simply saying when it is legal to fly and as the original response said, it has exceptions such as d and e.

I wasn't attempting to get into the WINGS program itself.  I think I conclude 61.56 does not nor is it intended to govern the WINGS program.  I'm taking it that if a pilot  has a WINGS completion certificate, we can take that at face value and we don't have responsibility to dig deeper.
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1013 Posts
Good catch, Hoss -- I'd forgotten the 12-month limit for WINGS phase completion.
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Hi Lonzo,

I agree with Ron in almost every aspect of his answers, but there's one point that we need to look at on scenario #1

In scenario #1 you mention that the pilot's flight review is expired on 10/01/2020, which is true. You also said that the pilot completes 3 flight activities on 09/15/2019 and two knowledge courses (I'm assuming completed the same day).  Then you state that on 10/05/2020 he takes the one remaining knowledge credit to complete a WINGs phase and as a result gets the WINGs card. WINGs phases need to be completed within a period of 12 months to count for a phase, and the 5 prior activities (3 flight and 2 knowledge) would have expired on 09/30/2020 (just like the flight review), and could not be used moving forward from that date. This scenario would not have resulted in the WINGs phase completion card being awarded.

So at this point the pilot in scenario #1 would need to complete 2 more knowledge tasks and 3 flight activities to be able to use the WINGs program to regain flight review currency. The reference for this is AC 61-91J:

"c. Training Requirements. Pilots earn a phase of WINGS by successfully accomplishing a specified number of knowledge and flight tasks. The requirements of these tasks, as found in the current PTS, correspond to leading accident causal factors, as described in paragraph 4 above. Each time the pilot successfully completes the specified set of tasks, he or she earns another phase of WINGS.

(1) Pilots must complete all of the required set of tasks for a phase of WINGS, three knowledge and flight activities, within a 12-month period to count toward that phase of WINGS. When pilots complete the set of tasks for a phase of WINGS, that phase of WINGS is valid for 12 months. Current requirements of the WINGS Program are available at www.FAASafety.gov. "


Flight tasks that you complete in the WINGs program are to be demonstrated to proficiency (PTS/ACS). The same is true of the maneuvers demonstrated during a flight review. You could always talk with your CFI and get a flight review sign off at the same time that you complete a flight activity towards WINGs. This is assuming that you complete the hour of ground as well, or whatever equivalent the CFI is willing to accept.
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1013 Posts
Lonzo Mc Laughlin:
This is helpful, thank you.  From what I'm understanding, the focus of 51.56c is about defining when a pilot can legally fly. It's not trying to put boundaries during which period the WINGS program can be utilized. 

Correct.
Lonzo Mc Laughlin:
I'm seeing many CFIs having varying opinions on how this is intended.  Are there any FAA interpretation out there that you are aware of?  The consequence of being wrong on this topic is not small so it would be ideal if we could get the language cleaned up a bit or have an interpretation made.
I haven't looked for one, but the plain language is pretty clear. To act as PIC, you must have completed a flight review within the six calendar months preceding the flight unless you did one of the substitutes (such as a WINGS stage) within that same period.

The key to understanding this and all the other recent experience rules is that it's all about looking back to find the necessary item within the specified period. Here are some interpretations which discuss this concept regarding other issues:

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2008/Wynne%20-%20(2008)%20Legal%20Interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2006/Winton%20-%20(2006)%20Legal%20Interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Kane-AFS-250%20-%20(2011)%20Legal%20Interpretation.pdf
 
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This is helpful, thank you.  From what I'm understanding, the focus of 51.56c is about defining when a pilot can legally fly. It's not trying to put boundaries during which period the WINGS program can be utilized. 

I'm seeing many CFIs having varying opinions on how this is intended.  Are there any FAA interpretation out there that you are aware of?  The consequence of being wrong on this topic is not small so it would be ideal if we could get the language cleaned up a bit or have an interpretation made.