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BFR and Part 135

Gatordev

Well-Known Member
pilot
Site Admin
Contributor
I've been doing some Googling and haven't been able to find an answer that people agree on.

Part 61.56 states:

"(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."

It then goes on to state:

"(d) A person who has, within the period specified in paragraph (c) of this section, passed any of the following need not accomplish the flight review required by this section:
(1) A pilot proficiency check or practical test conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege."

So my question is, after completing a 135.293 and/or .297 check ride:

a) is a separate logbook entry required (in the checkee's logbook) notating the completion of a BFR in order to fly privately?
2) if a logbook entry is required, does the person giving the .293/.297 check have to be a CFI? (answer seems to be no, but asking for completeness)

I understand that a BFR isn't required because of paragraph (d), but it doesn't say it explicitly excludes the requirement of (c),(1).

I never worried about this before because I had my NATOPS check notated in a logbook, but I don't have that now after a .293 check since it's just paperwork.
 

HAL Pilot

Well-Known Member
None
Contributor
The person giving the instruction or check under part 135 or 121 does not have to be a CFI. They have to be designated by the company and approved by the FAA POI. These two things are what makes them an approved pilot check airman.

I just make a comment in the note section of my electronic logbook. I write the type of check and the check airman's name. (i.e. HAL line check, CKP: D. Jablowme). No signature from the check airman or anything. You are not required to (and never should) carry your logbook when you fly. If a FAA inspector ever demands proof of a BFR, you don't have to provide it on the spot. There is plenty of time to get a copy of the check from your company training jacket, fold it up, and stick it in the back of your logbook before you visit the FAA inspector later on with your logbook.

Just a point not asked....part 121/135 currency does not equal part 61 currency. As long as I make 3 landings in 90 days I am current for all part 121 flying including being PIC IFR. Part 61 requires 6 approaches in 6 months, yada, yada, yada. If I am current part 121, I can fly Cat III approaches in complex large aircraft but not fly any type of instruments in a general aviation aircraft. unless I have those 6 approaches, etc. Same with 121/135 landing currency. 121 doesn't care if the landings are day or night, 3 landings period and you're current. But this doesn't transfer to part 61 which not only requires 3 day and 3 night but also cares about SE versus ME.

I understand the easiness of 121/135 currency is because the FAA assumes a 121/135 pilot is more proficient than the average general aviation but it kind of sucks that I can fly 300 pax at night in the shittiest weather imaginable but I can't take my daughter out in a C172 without jumping through landing, day/night and instrument currency hoops.
 

wink

War Hoover NFO.
None
Super Moderator
Contributor
And don't forget, if you are going to fly without the training wheel up front, you have to get your 3 landings separately in the tail wheel aircraft.
 

Gatordev

Well-Known Member
pilot
Site Admin
Contributor
@HAL Pilot all good stuff, and it all makes sense. The argument (that I'm not saying I agree with) is that paragraph (c) doesn't remove the exception of (c) (2). I'd argue that it does, because the way it's written, the exception applies to both (1) and (2).

Additionally, there's no requirement to have a logbook except to show recency or currency, which the training jacket does, so what you say makes sense.

Interestingly, I've been told that the 6 in 6 does apply to us under 135, but it's not an issue because we get a .297 every 6 months, so it resets itself all the time. We also have to maintain the 3 night landings, but there's a difference between logging "night landings" and HNVGOs, which is why I think they make the distinction.

Small thing but the term “BFR” is now defunct in favor of “Flight Review”

Yeah. That happened 10-15 years ago. But everyone I know still calls it a BFR.

Yeah, since my first flight was 30 years ago, old habits can be hard to break.
 

HAL Pilot

Well-Known Member
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Contributor
@Gatordev Where do the FARs define “logbook”? I’d argue it can be anything want as long as it can show currency. A file folder with a bunch of 135 grade sheets can be a logbook.

I might be wrong about the 6 in 6 for 135. It doesn’t apply to 121. Especially 121 under AQP. 1 sim check a year and a line observation.
 

ChuckMK23

FERS and TSP contributor!
pilot
All the FAA cares about is logging of recent experience sufficient to show compliance with your FOM and 135 Certificate. Our program's dispatch Software contained fieds in addition to flight time and takeoffs for instrument time, approaches, (pilot edited), day and night (automatically calculated for you). I printed out each months report, signed, and put a copy in my personal file...Made it very simple.

@Gatordev we also had a dispatch sheet for each leg flown - I remember computing the weight and balance and loading before every takeoff on a small handheld computer on a carbon form in a small metal clipboard. Logged hobbs prior to each takeoff, seat positions occupied, fuel load, gross weight and CG calc. It was busy. Probably the the single most difficult thing to learn - as you know the flying itself is pretty straightforward.

I'm assuming you do all that on an ipad or some other tablet now. If you wanted to log your own detailed logbook, ForeFlight would be an excellent solution here.
 

wink

War Hoover NFO.
None
Super Moderator
Contributor
The reg says "reliable record", as I recall. That's why it can be company records, electronic logbook or a bound paper log, among other options. Doesn't have to be all in one place
 

Jim123

DD-214 in hand and I'm gonna party like it's 1998
pilot
Someone should give Gator’s check airman a heads-up.
 

Gatordev

Well-Known Member
pilot
Site Admin
Contributor
@Gatordev Where do the FARs define “logbook”? I’d argue it can be anything want as long as it can show currency. A file folder with a bunch of 135 grade sheets can be a logbook.

I'm with you and tracking. That said...

All the FAA cares about is logging of recent experience sufficient to show compliance with your FOM and 135 Certificate.

The other thing I'm thinking ahead to is not just what the FAA cares about (that's fairly easy), but also what a FBO/CFI cares about. I foresee both getting my MEL and having the potential to inherit a plane, both some time in the near to mid-future, so just making sure everything is lined up (which it appears to be).

Someone should give Gator’s check airman a heads-up.

If you only knew the guy... he's very "particular..." and Army.

Did my IFR progress check yesterday in the sim (only one ding) and will do my flights and .297 in another week or two. Since I already have two .293 rides in the last 6 months, I'll call it good on the BFR.
 
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