Many new glider pilots come to our community from the powered-flight world. Powered aircraft pilots want to add a glider rating to their certificate for a whole number of reasons – the challenge of getting a new rating drives many pilots, or hopefully they want to pursue the sport of glider flying on a more serious basis. Oftentimes, powered pilots become ineligible for a third class medical certificate and see glider flying as a way to continue to pursue their passion. Regardless of the motivation, there are some regulatory nuances that affect already certificated pilots who want to solo a glider in pursuit of their rating. This article will discuss those nuances and how they affect the flight training process.
PILOT IN COMMAND
First, in order to act as pilot in command of any aircraft, an airman needs to hold an appropriate pilot certificate. That certificate can be a student pilot certificate all the way up to an airline transport pilot certificate. Second, to act as PIC, the airman needs to meet the currency and other requirements of that certificate the airman holds. That could be things like three take off and landings to carry passengers, a current flight review, and meeting instrument currency requirements, depending on the operations conducted.
For student pilots flying a glider, the requirements are codified in 14 CFR Part 61, Subpart C, Student Pilots. In order to solo (ie act as PIC), a student pilot needs a student pilot certificate per 61.83, a pre-solo written test, reviewed with the CFI per 61.87, documented flight training on the areas of operation per 61.87 (c), and (i), and have endorsements from an instructor for the make and model to be soloed (every 90 days), for the method of launch (aero, winch, etc), and have the instructor sign off the student pilot certificate authorizing solo flight. It is very important to note that a pilot already certificated with a rating in a different category and class (e.g. a private pilot with an airplane single engine land rating), is NOT a student pilot. As such, a certificated pilot seeking to add the glider category to their Pilot Certificate does not concern him/herself with Part 61 Subpart C. In this case, the relevant regulation is 14 CFR Part 61.63 (b). which outlines the requirements for an additional aircraft category rating.
For a certificated pilot to solo a glider before they are rated, the relevant regulation is Part 61.31(d)(2), which states that in order to act as pilot in command of an aircraft a person must either (1) hold a category/class rating for the aircraft being flown, or (2) Have received training required by this part that is appropriate to the pilot certification level aircraft category (and) class for the aircraft to the flown and have received an endorsement for solo flight in that aircraft from an authorized instructor. In other words, you are flying as a certificated pilot with a solo endorsement for the glider category/class from your CFIG.
There is one more wicket to pass through in order to act as pilot in command. You need to meet the Part 61 requirements for any pilot to act as PIC. More specifically, 61.56(c) requires that “no person may act as pilot in command of an aircraft unless, since the beginning of the 24th 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….”
Page 7 Note that 61.56(g) specifically exempts student pilots from the flight review requirement by substituting the endorsement provided in Part 61.87.
Now that we have peeled the layers of part 61 back so far, those of you who have stuck with me now get to see the meat of the issue here….
Let’s say you got your private certificate 20 years ago and stopped flying shortly thereafter for some reason. Now, you have come to CSA, pulled gliders up to the flight line, logged flights, cleaned the golf carts, and took glider lessons from a terrific CFIG. In order to meet the aeronautical experience requirements of Part 61, need a specific number of solo flights. You are getting ready to solo – and its going to be any day now.
But not so fast…. Since you are a powered pilot from many years ago, the FAA still sees you as a certificated airman – NOT a student pilot. Therefore, part 61.83 doesn’t apply, Part 61.31(d)(2) does. But, so does 61.56. That means you need a current flight review to act as PIC in a glider – and that Flight Review has to be in a Category and Class in which you are already rated. You haven’t flown a powered aircraft in 20 years, and don’t see any need or benefit to spend the money for a flight review in a powered aircraft since you have no intention of every flying one. Further, you are concerned an instructor will require a flight review be flown to proficiency in the airplane since theoretically once signed off you are legal to fly an airplane again even through you have no intention of doing so… The FAA has reinforced this interpretation of the regulations though at least two Legal Interpretations (Beard, 2015) and (Bennett, 2016).
So, what are your options if you are an out-of-currency powered pilot who is ready to solo in the glider? You have two options: get a flight review in a category/class aircraft that you are rated in, like a 172 or Warrior, which may add time and expense to your glider pursuit, or the second option of which CSA’s Stephen Williams took advantage this past summer to get his glider certificate without having to resort to a flight review in something he will never fly….
Sport Pilot Option
Several years ago, the FAA created the sport pilot certificate as a way to enable pilots who wanted to fly simpler aircraft to get their license without a lot of the burden that private pilots have to go through. Consequently, there are more restrictions on sport pilots and the aircraft they can fly.
Sport Pilots are covered by Subpart J of Part 61.For pilots who are already certificated at a higher level (i.e.; Private, Commercial), the aeronautical experience is listed the table in Part 61.303 and 61.321. So Stephen, for example, has a commercial certificate with airplane single and multi engine land ratings.To get a sport pilot certificate with a glider category, we start at Part 61.303 – and look at the section for those who hold at least a private pilot certificate but not a rating for the category and class of light sport you wish to operate (i.e. glider):
What the FAA does here is to give you credit for being a certificated pilot already at a level higher than Sport Pilot.The implication of that is that by meeting the requirements of Part 61.321 for category and class endorsements at the sport pilot level, a transitioning pilot can meet the aeronautical experience requirements necessary for exercising sport pilot privileges without a solo flight requirement.
The Unifying Legal Interpretation
So you have your private pilot certificate with an airplane rating. You have met the requirements of Part 61.303 and Part 61.321. Next you have met the requirements ofParts 61.309 and 61.311 by receiving and logging training in the aeronautical knowledge and areas of operation in Part 61.309 and 61.311. The final step, in order to exercise Sport Pilot privileges for the Glider category, is to obtain a sign-off by an authorized instructor, and pass a proficiency check from a second authorized instructor (note: not necessarily a DPE), following the sport pilot PTS.
Now, recall that in order to act as PIC you need to have a Flight Review per 61.56.Steve actually requested an interpretation from the FAA about this and their response was that the sign off of the sport pilot proficiency check meets the flight review requirement of Part 61.56 !
We went through a lot of minutia in the regulations to determine that a transitioning pilot needs a 61.56 flight review in order to act as PIC of a glider (i.e.; to fly solo), and that since transitioning pilots require solo flights to meet the aeronautical experience provisions to add the glider category and class for private pilot and higher certificates, the Flight Review represents a potential barrier to transitioning pilots.
The Sport Pilot route allows already-certificated pilots with a certificate at the Private or higher level, to gain a glider category and class privileges at the Sport Pilot level on their existing pilot certificate without requiring solo flights for aeronautical experience to qualify for the flight check.Therefore a pilot can earn a glider rating at the Sport Pilot level without having to meet 61.56, but once the pilot has the proficiency check signature of 61.321, that check also meets the requirement of 61.56!
As always it is up to the instructor to ensure that they are comfortable with the level of proficiency for the pilot in whose logbook they are placing their signature. Whether its for first solo or Sport Pilot privileges, instructors are encouraged to follow the syllabus, PTS, and their own experience to ensure proficiency of their students.
There is a similar route for flight instructors who have an airplane CFI already. A certificated CFI can add a glider (Sport Pilot) CFI to their existing certificate with an endorsement. However, these instructors can ONLY instruct sport pilot students, not private and commercial candidates. For those interested, see Part 61.419.