A friend of mine is working towards his initial CFI. I'm helping him work through regulatory, weather, and other knowledge stuff when time permits. During our most recent ground session he asked me a question that I had never been asked. Here's the setup...

A CFI with a freshly minted MEI (airplane, land) is asked to conduct a flight review for a customer in the customer's own Cessna 421C, a pressurized piston twin certified to >30,000'. This CFI has only flown one type of twin (pick a common training twin, doesn't really matter). He has no time at all in a 421 of any sort or any other twin aside from the trainer in which he trained for his commercial-multi and MEI. Our MEI is otherwise current in all categories and classes for which he is certified, holds a complex endorsement gained during his commercial training, and holds a First Class with no limitations.

The customer is current in all categories and classes for which he is certified, is within the 24mo flight review window, and has a First Class. In short, the customer is fully qualified to be PIC for the flight portion of the flight review.

What's obvious:

  • The five hour rule does not apply since a flight review is not instruction given for a certificate or rating.

  • Our MEI cannot act as PIC of the customer's 421C because the MEI is missing a high altitude endorsement and a high performance endorsement even though he is category and class certified for airplane multi land.

  • A CFI does not need to be PIC, or even hold a medical, in cases where the student/customer is able to act as PIC.

  • Edit: it's a really bad idea to do fly an aircraft type with which you are not familiar.

The question is this:
Can our fresh MEI give the customer a valid flight review in the customer's 421C?


4 Answers 4


The flight instructor is limited to give training in the category and class ratings of their pilot and instructor certificates, not by make and model.

Per §61.193 and §61.195 the flight instructor is authorized to train and issue endorsements for a flight review so long she or he holds a pilot certificate and flight instructor certificate with the applicable category and class rating.

Furthermore, per §61.51(e)(3), the flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

The instructor is advised according to Advisory Circular: AC 61-98C, Section 4-2 Paragraph e. Instructor Qualifications:

Instructors should also consider their own experience and qualifications in a given make and model aircraft prior to giving a review in that model... ...To conduct a flight review in a multiengine airplane, the instructor must hold an airplane multiengine rating on their pilot and flight instructor certificates. For aircraft in which the CFI is not current or with which he or she is not familiar, he or she must obtain recent flight experience or sufficient knowledge of aircraft limitations, characteristics, and performance before conducting the review. In any case, the CFI must observe the rating limitations of § 61.195.

So, yes. An appropriately rated flight instructor (whether or not they should) is authorized to conduct the flight review.

What's more, even if the instructor is not qualified to act as PIC (e.g. does not have a high-performance training endorsement), that instructor will still log pilot-in-command time as instructor because he or she is appropriately rated to do so.

  • $\begingroup$ I wouldn't necessarily write off the value of a freshly minted instructor giving a crusty old dog a flight review. There should be learning both ways. $\endgroup$
    – STWilson
    Commented Jun 19, 2017 at 16:09
  • 1
    $\begingroup$ Agree. Tech is the new thing. I wouldn't expect an older pilot flying a stwam 175 to know all about WAAS. Could be a good lesson for both. $\endgroup$
    – acpilot
    Commented Jun 19, 2017 at 16:15
  • $\begingroup$ I'm not sure I see how the instructor can log PIC. 61.51(e)(iii) applies to someone acting as PIC in an aircraft or operation that requires more than one pilot. But the instructor can't act as PIC and the operation doesn't require more than one pilot. Did I miss something? That doesn't change the rest of your answer, though. $\endgroup$
    – Pondlife
    Commented Jun 19, 2017 at 17:47
  • $\begingroup$ @Pondlife, you referred to AOPA in your answer. This is a quote from AOPA, "Flight instructors may log any flight time as PIC whenever they are providing flight instruction, whether or not they are acting as PIC (FAR 61.51)." $\endgroup$
    – STWilson
    Commented Jun 19, 2017 at 18:14
  • $\begingroup$ The instructor must only be rated for the category and class. §61.51(e)(3) says, A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft. $\endgroup$
    – STWilson
    Commented Jun 19, 2017 at 18:26

I may be oversimplifying, but it looks to me like the main question here is just "can an instructor give a flight review without acting as PIC?". You've given one specific example of why the instructor can't act as PIC, but there could be others.

The short answer is that as long as the pilot can legally act as PIC, the instructor doesn't have to. AOPA has a nice guide that gives this advice for instructors:

35. Who acts as pilot in command during a flight review?
This question should be resolved before the flight so that both you and the pilot have a clear understanding of PIC responsibilities. You should inspect the pilot’s logbook, pilot certificate, and medical certificate to ensure that he or she is qualified to act as pilot in command. If the pilot does not meet the pilot-in-command requirements, you must assume that role. While you are in the process of inspecting paperwork, don’t forget to check the status of the aircraft. Is it airworthy?

There's also a secondary question of whether it's a good idea for an instructor to give a flight review in an aircraft that he isn't familiar with. STWilson's answer covers that nicely.


Your "What's obvious" list pretty much sums up the issue. As long as it is clearly decided before the flight begins that the CFI is NOT going to act as PIC, there is nothing in the FARs that would preclude giving the customer the Flight Review.

As a CFI, I would insist that a written note attesting to the fact that the customer is accepting his/her role as PIC be signed and remain behind on the ground. This ensures that should a potential violation, incident, etc. occur during the flight, the customer is on record acknowledging PIC responsibility.

  • $\begingroup$ Could a mention of this note and its location also be made in the cockpit before commencing flight, in order to have it on the CVR if something goes badly enough wrong during the flight for that recording to be reviewed? $\endgroup$
    – user
    Commented Jun 19, 2017 at 14:51
  • $\begingroup$ The pilot in command status does change during multi-crewed flight and during instruction. I can tell you from experience, the FSDO inspector will make his or her own determination based on facts other than what is decided upon beforehand and attested to by the pilots. $\endgroup$
    – STWilson
    Commented Jun 19, 2017 at 16:04
  • $\begingroup$ Although, it's irrelevant to the question and answer above, the PIC status during a flight could change based on the circumstances. Not relevant here though. In the response to the question, I'm reinforcing the fact that the CFI would not (could not) be the PIC. As a general rule, when there may be a question regarding who is the FAR Part 1 (person responsible for the flight), clearly making this designation before the flight is a good idea. The FSDO inspector does not make this determination, the FARs do. $\endgroup$
    – user22445
    Commented Jun 19, 2017 at 16:59
  • $\begingroup$ EDIT to above: In this case, since the CFI is not rated in the C421 because of the missing high altitude endorsement, he/she could not log PIC time. With this endorsement however, both could log PIC, although only the customer would be FAR Part 1 PIC. $\endgroup$
    – user22445
    Commented Jun 19, 2017 at 17:04
  • 1
    $\begingroup$ Ok, I agree that, in spite of the exact wording of the applicable FARs as I mention in my comment above, under the circumstances described in the question the CFI could "log" pic time. However, the CFI, in accordance with the questioner's "What's Obvious" section, and my original answer, cannot "act" as PIC. $\endgroup$
    – user22445
    Commented Jun 19, 2017 at 20:41

In a flight review, the instructor is supposed to evaluate the pilot flying simulated IMC, which may also include unusual attitude recoveries. The point is that the pilot being evaluated is under the "hood" and the CFI would need to be capable of acting as PIC. This means a current medical as well as any aircraft requirements.

As near as I can determine the only loophole possibility is if the flight were conducted under IFR, in which case the CFI would not be needed as a crew member because of the flight rules.

So lack of medical (and the requirement to have one to act as PIC during hooded pilot operations), combined with high altitude endorsement, time in the C421, all work to make the administration of a flight review a no-go.

Tangentially, a safety pilot for IFR practice must also have a valid medical.


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