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FAR § 61.56.(c).(1) states that every two years I must have

Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor.

The answer to my question hinges on the exact meaning of the word "rated". If I've been signed off to solo in a C-172, am I "rated" for that aircraft as far as this regulation is concerned?

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  • $\begingroup$ I believe that because you cannot use your Sport privileges to act as PIC in a non-sport aircraft, you cannot perform a BFR in one. $\endgroup$
    – egid
    Jul 26, 2015 at 21:48
  • $\begingroup$ @egid I believe you don't need to be PIC during a flight review, the CFI can be PIC. Otherwise it would be impossible to do one if your previous flight review had lapsed. $\endgroup$
    – Pondlife
    Jul 27, 2015 at 0:18
  • $\begingroup$ I'm looking it up. I'm fairly certain you need to be able to act as PIC ("an aircraft for which that pilot is rated") - otherwise one could get a flight review in a helicopter for their PPL SEL. $\endgroup$
    – egid
    Jul 27, 2015 at 0:20
  • $\begingroup$ And I specifically did say that he cannot act as PIC - but you're right, I should have said "in general" as it's not possible to be legal PIC (although one could be sole manipulator) for the completion of a flight review. $\endgroup$
    – egid
    Jul 27, 2015 at 0:22
  • $\begingroup$ @egid Apparently the FAA says that you only need one flight review: "For example, a pilot who holds a private pilot certificate with an ASEL rating and a commercial balloon certificate may take a flight review in either aircraft and will have met the requirements of the rule for both". That surprised me. $\endgroup$
    – Pondlife
    Jul 27, 2015 at 16:58

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Nope, sorry! If you need a flight review, use an LSA you have been endorsed for.

§61.56(c)(1) states that a flight review must be:

Accomplished [...] in an aircraft for which that pilot is rated

According to the AOPA (note: this article is specifically targeted at non-Sport pilots):

Rated is interpreted as category and class [emphasis mine]

And in another article, the AOPA continues:

Sport pilot certificates will be issued without category/class designation

...and just for the final nail in the coffin, here's the FAA itself (thanks, @Pondlife!), in AC 61-98B:

A pilot who holds only a sport pilot certificate may only take a flight review in a light sport aircraft for which he or she holds an operational privilege. For example, a sport pilot who holds airplane privileges could not take the flight review in a Cessna 172 since that airplane is not a light sport airplane and he or she does not hold operating privileges for that airplane.

Long story short, this all means that no, a Sport Pilot cannot perform a flight review in a non-LSA type. Because you require specific logbook endorsements in make/model for category/class/speed (an LSA like a Sting S3 vs Airplane Single-Engine Land), you are not rated to fly a Cessna 172, for example. Your solo endorsement isn't a rating, as it isn't part of a certificate - it's an endorsement.

Once you become a Private Pilot, you'll be able to do a flight review in almost any ASEL type, including all LSAs because you're suddenly rated for the Airplane category and Single Engine Land class, with no light-sport-only limitation.

As far as I can tell, your student pilot certificate is actually invalid. It's been superseded by your Sport Pilot certificate and you are now adding privileges to that certificate. As such, it doesn't really matter that you've been endorsed for solo in a 172; you aren't rated to fly one in the same way you are for an LSA.

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    $\begingroup$ I'm attempting to nail down if the FAA considers LSA it's own category. $\endgroup$
    – egid
    Jul 28, 2015 at 15:34
  • $\begingroup$ FWIW, my SPL says "AIRPLANE SINGLE-ENGINE LAND" on the back, and during training I was told that LSAs can have the same categories and classes as other aircraft (except where the LSA definition prohibits it, so there can be and are LSA rotorcraft, but there can't be an LSA twin), which corresponded with the correct answers on the written test. $\endgroup$
    – Throw Away Account
    Jul 28, 2015 at 23:49
  • $\begingroup$ Also, I don't see how a Third Class Medical And Student Pilot Certificate can be superseded by a certificate that doesn't confer the privileges of a student pilot certificate. It clearly doesn't add privileges to the SPL, since by definition an SPL limits you to flying day VFR below the clouds in an LSA, while allowing you to fly within those limitations without a medical. $\endgroup$
    – Throw Away Account
    Jul 28, 2015 at 23:52
  • $\begingroup$ I'm gonna have to call my FSDO and see what they say. $\endgroup$
    – Throw Away Account
    Jul 28, 2015 at 23:53
  • $\begingroup$ @ThrowawayAccount3Million: a certificated pilot doesn't need a student cert to add new categories or classes. Otherwise a PPL SEL would need a student cert to add rotorcraft, for example, and that's not the case. The same should hold true for sport. A Sport Pilot needs a medical but not a student cert when adding ratings. $\endgroup$
    – egid
    Jul 29, 2015 at 0:20
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As mentioned above, but hard to see - once you pass any check ride and you are a pilot (sport, recreation, private, commercial or airline transport) so no longer a Student Pilot. You are a Pilot; different rules apply for adding a new category/class to your Pilot Certificate.

A Flight Review (Hasn't been a "BFR" since 1997. The FAA's preferred term is "Flight Review," read the Advisory Circular!) must take place in an aircraft for which the pilot is rated. 61.56 provides useful alternatives. One of these is training via the FAA's Wings program.

In the OP's case, three dual flights in the 172, combined with some online training, could provide credit for the flight review. Just a little planning/coordination with the instructor is required.

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According to Flying Magazine January 2010, it sounds like, yes you can:

Q: I'm a private pilot flying at the Sport Pilot level. Can I take my flight review in the Cessna 172 that's available at my local FBO?

A: The requirements for a flight review are called out in 14 CFR 61.56. The regulation requires the flight review to be accomplished in an aircraft for which the pilot is rated. Since you are a private pilot you are rated to fly the Cessna 172 (assuming you have an Airplane Single Engine Land rating on your pilot certificate), so this would meet the requirement of the regulation. Since you don't hold an FAA medical certificate, you would not be authorized to act as pilot in command (PIC) during the flight portion of the review, but Sec. 61.56 does not contain a requirement for the pilot taking the flight review to hold a medical certificate or to act as PIC, so this is not a problem. The flight instructor performing the flight review will act as PIC during the flight.

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  • $\begingroup$ The OP is not a Private Pilot though, he is a Sport Pilot. "Since you are a private pilot you are rated to fly the Cessna 172..." The OP is not "rated" to fly it, the OP can fly LSA's, and has an endorsement to fly 172's solo. A solo flight is simply an instructional flight, under supervision of a flight instructor but on which the flight instructor is not present. He cannot fly a 172 for any other reason than an instructional flight. $\endgroup$
    – Ron Beyer
    Sep 13, 2017 at 19:14
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If you currently hold a Sport Pilot Certificate or other grade of Pilot Certificate, your Student Pilot Certificate is no longer valid in the eyes of the FAA and the law. Therefore §61.56(c)(1) governs this and the flight review must be conducted aboard an aircraft which the pilot is appropriately rated to serve as PIC aboard.

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