Pilot Counsel

The 'biennial' flight review

December 1, 2004

John S. Yodice is the secretary and general counsel for the AOPA board of trustees.

In our continuing review of the regulations for pilots starting out on a typical private (noncommercial) flight, last month we reviewed the "recent experience" requirements of FAR 61.57. In addition to recent experience, there are other similar kinds of requirements, ones that involve flight and ground training and logbook endorsements in order to act as pilot in command of a flight. This month we will review the requirement for a "biennial" flight review — that is, a flight review every two years. After that we will cover the requirements for training and endorsement in complex airplanes, high-performance airplanes, pressurized aircraft, and tailwheel airplanes. It is often rewarding, and sometimes surprising, for pilots to be reminded of the details of these regulations. Rewarding and sometimes surprising for me, too.

The flight review is more familiarly (but no longer accurately) known as the biennial flight review, or BFR for short. It is FAR 61.56 that imposes the requirement. It says that a pilot may not command ("act as pilot in command of") an aircraft unless the pilot has satisfactorily accomplished a flight review within the past two years. More precisely, we are given a little more than two years most of the time, because the rule says that the review must have taken place "since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command." That's a brainteaser. What it means is that the look-back period can actually be a little more than 24 months or two years, back to the beginning of the month in which a two-year period is calculated. So a flight review is good for two years from the last day of the month in which you took it. That's why it's no longer accurately called a biennial, which technically means two years to the day.

In addition to accomplishing the review, there is an associated logbook requirement. The pilot's logbook must be endorsed by the flight instructor (or other authorized person) who gave the review, and it must certify that the review was satisfactorily completed. The logbook endorsement is a separate legal requirement. So having actually accomplished the flight review is not enough. There is a subtle problem here. The problem is that you should expect, after the fact, that the FAA will be skeptical about an unlogged review. "After the fact" being an accident or an incident under investigation in which the FAA invariably asks to review the pilot's logbook. If the review is not logged, that's a problem. Trust me, I have seen enough of these situations.

The review must consist of at least one hour of ground training reviewing the current operating and flight rules of FAR Part 91, and at least one hour of flight training reviewing some maneuvers and procedures. The flight training part of the review is intended to be sufficient to demonstrate to the reviewer that the pilot is able to safely exercise the privileges of his or her certificate. For glider pilots, three instructional flights in a glider to traffic pattern altitude can take the place of one hour of flight training. Beyond these generalizations, the details of the review are left to the discretion of the reviewer. For example, the review does not necessarily have to relate to all of the ratings a pilot has. In the review, a pilot may use any aircraft for which the pilot and the instructor are rated, within the discretion of the reviewer. A review in one category and class aircraft may satisfy the reviewer regarding all of the categories and classes for which the pilot is rated.

There are also alternate methods of compliance with the flight review requirement. It can be met if within the preceding 24 calendar months the pilot passed and logged a flight test for a pilot certificate or an added rating. For example, if a pilot passed a flight check for an instrument rating or a multi-engine rating, the pilot would be legal for the next 24 calendar months. If a flight instructor has satisfactorily completed a renewal of his or her flight instructor certificate, that may count for the required one-hour ground training.

In addition, a pilot can meet the requirement by passing an FAA-required proficiency flight check, as, for example, a six-month check for air taxi operations or a pilot-examiner annual flight check. A proficiency flight check given by a U.S. armed forces check pilot also qualifies.

The FAA's Pilot Proficiency Award program, more commonly called the Wings program, also qualifies. If within the 24-calendar-month period a pilot has satisfactorily accomplished one or more phases of the program in an aircraft, the pilot need not accomplish a flight review.

A student pilot does not need a current flight review if he or she is undergoing training for a certificate and has a current solo flight endorsement.

One frequently asked question is whether an instrument proficiency check (IPC) qualifies as an alternative method of compliance for the flight review. The technical answer is no. However, an IPC may be done in combination with a flight review. That's specifically allowed in the regulations. But it is not automatic. It is up to the flight instructor doing the check. If he or she is willing to sign it off as a flight review as well as an instrument proficiency check, then it will qualify. Many flight instructors will do so because the maneuvers and procedures in the IPC are usually sufficient to demonstrate to the flight instructor whether the pilot is able to safely exercise the privileges of his or her certificate.

An often-asked question is whether the flight review may be accomplished in a flight simulator or flight training device. The answer is yes, but with important conditions. The most restrictive is that the flight simulator or flight training device must be used in accordance with an approved course conducted by an FAA-certificated training center. Another condition is that the simulator or device being used must represent an aircraft or set of aircraft for which the pilot is rated. If the flight simulator being used is not approved for landings, then the pilot must also meet the general and night "recent experience" requirements for takeoff and landing (see " Pilot Counsel: Recent-Experience Requirements," November Pilot).

One last thing. The requirement is for a flight review, not a flight check. There is not supposed to be a "pass or fail" aspect to it. The regulations say that the review must be "satisfactorily" accomplished, meaning that if the reviewer is not satisfied with your performance, he or she does not endorse your logbook with an unsatisfactory review (but the instructor may want to make an entry showing the instruction that was given). You can keep on trying, with a different instructor if you like, until your review is satisfactory. You must exercise judgment considering why the reviewer was not satisfied. Some additional flight training could well be indicated. But as long as your last satisfactory review is not older than the period we talked about, you are still in compliance with the flight review requirement to act as pilot in command. If it is older, you cannot fly as pilot in command, not even solo.

John S. Yodice