Biennial flight review requirement coming to Canada from 2024

[photofly]

This is part of the proposals for shaking up VFR rules at night, but its applicability is to all pilots:

CAR 421.05 – Delete obsolete requirements in paragraphs 421.05(2)(b), (c), (d) & (g) and
add new currency requirements that consists of a recurrent training program with a minimum
of 1 hour of flight training and 1 hour of ground training.

From https://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/ ... x?id=12471

TC wants to introduce the US requirement of a biennial flight review, and change the rules so that doing any of the the following will no longer meet recency requirements:

(b) attendance at a safety seminar conducted by Transport Canada Aviation;

(c) successful completion of a recurrent training program designed to update pilot knowledge, which could include subject areas such as human factors, meteorology, flight planning and navigation, and aviation regulations, rules and procedures that has been approved by the Minister as being satisfactory for those purposes;

(d) completion of the self-paced study program produced annually in the Transport Canada Aviation Safety Newsletter, which is designed to update pilot knowledge in the subjects specified in (c) above

(g) completion of the written examination(s) for a permit, licence or rating.

Also note the change to "currency" from "recency", which is either careless writing or a deliberate move towards the US.

If you want to comment to TC, you have only until 5 June.

EDIT: something to think about is the timing. If this is brought into force in (say) October 2024, then unless you have had such a recurrent training programme in the two years prior (i.e. since last October) you will be immediately grounded.

[Big Pistons Forever]

EDIT: something to think about is the timing. If this is brought into force in (say) October 2024, then unless you have had such a recurrent training programme in the two years prior (i.e. since last October) you will be immediately grounded.

The coming into force date will start the clock. The only ones who would be affected would be someone who’s recency under the previous rules would have run out on or shortly after the coming into force date. The obvious solution is to renew your recency under the old rules just before the new rules come into force.

Personally I support a US style biennial revue based on some of the scary lack of basic flying competencies I see demonstrated every sunny weekend. I think however it should be performance based not prescriptive. Instead of 1 hour of training it should be train to proficiency in all the maneuvers we know consistently figure in accident reports.

I can think of pilots that could demonstrate a high level of skill in all the basic maneuvers in 30 minutes and others that would need 15 to 20 hours of training to be even close to that level.

[photofly]

The coming into force date will start the clock.

How would that be written into the regulations?

Instead of 1 hour of training it should be train to proficiency in all the maneuvers we know consistently figure in accident reports.

There aren’t enough flight instructors in the world to achieve this. You might as well pull down the shutters and we can all go home.

On the positive side, insurance rates might go down, and there would be a lot planes for sale all of a sudden.

[Big Pistons Forever]

The coming into force date will start the clock.

How would that be written into the regulations?

It will be in the Gazette 2 notes under applicablility

[photofly]

The coming into force date will start the clock.

How would that be written into the regulations?

It will be in the Gazette 2 notes under applicablility

So… it will be gazetted in 2024 for coining into force in 2026?

[PilotDAR]

I support the spirit of what I understand from this. In my opinion, receiving "training" or exposure to piloting, is not a substitute for actually demonstrating the skills. I think that a proud pilot should not have any hesitancy to demonstrate their proficiency to another pilot.

That said, I also agree that the industry would run short of properly experienced instructors to do these flight reviews. I think that the regulation change should require the demonstration to proficiency to a suitably another pilot suitably experienced on that class of aircraft. It i kind of pointless for a pilot who regularly flies their Malibu to have to rent a 172 to demonstrate proficiency to an instructor who has no knowledge of flying the Malibu! Have the requiring pilot elect another class experienced pilot peer, with a minimum of total, and class experience - A la an insurance checkride...

[Squaretail]

There aren’t enough flight instructors in the world to achieve this. You might as well pull down the shutters and we can all go home.

Transport's usual "nobody moves, nobody gets hurt" theory of safety. Is the safety rate in the U.S. demonstrably better because of their flight review requirements?

[Big Pistons Forever]

How would that be written into the regulations?

Instead of 1 hour of training it should be train to proficiency in all the maneuvers we know consistently figure in accident reports.

There aren’t enough flight instructors in the world to achieve this. You might as well pull down the shutters and we can all go home.

The majority of accidents are a result of a lack of pretty basic flying skills. So what you are basically saying is demanding that pilots can demonstrate PPL flight test standards of flying competence for slow flight/stall recognition and recovery, maintaining control after a loss of engine power, making safe landings near the specified touch down point in the proper landing attitude, manage fuel, and have a basic understanding of how aircraft systems work so that they can deal with failures; represents such a high bar it would end GA.

That is pretty bleak indictment of recreational pilot skills…..

FWIW the glider club I belong to decided that at the start of every flying seasons every pilot would do all the glider pilot license flight test maneuvers, on a train to proficiency basis. The motivation for this policy is that the club does not want anyone flying a club glider that could not demonstrate the skills required to gain an initial glider pilot license.

In practice this means that most pilots meet the standard with a 25 minute upper air work flight and a 3 minute low altitude rope break (250 ft AGL) exercise. However some pilots have needed 1 or 2 more flights to regain flight proficiency in some maneuvers. My experience is that pilots who need some extra practice to regain proficiency in a particular maneuver appreciate and understand the training they are getting.

[photofly]

How would that be written into the regulations?

Instead of 1 hour of training it should be train to proficiency in all the maneuvers we know consistently figure in accident reports.

There aren’t enough flight instructors in the world to achieve this. You might as well pull down the shutters and we can all go home.

The majority of accidents are a result of a lack of pretty basic flying skills. So what you are basically saying is demanding that pilots can demonstrate PPL flight test standards of flying competence for slow flight/stall recognition and recovery, maintaining control after a loss of engine power, making safe landings near the specified touch down point in the proper landing attitude, manage fuel, and have a basic understanding of how aircraft systems work so that they can deal with failures; represents such a high bar it would end GA.

That is pretty bleak indictment of recreational pilot skills…..

I may have been exaggerating a leeeetle bit... but I think it was you yourself (cough) who wrote:

Personally I support a US style biennial revue based on some of the scary lack of basic flying competencies I see demonstrated every sunny weekend. I think however it should be performance based not prescriptive. Instead of 1 hour of training it should be train to proficiency in all the maneuvers we know consistently figure in accident reports.

I can think of pilots that could demonstrate a high level of skill in all the basic maneuvers in 30 minutes and others that would need 15 to 20 hours of training to be even close to that level.

If there's indicting going on, it clearly isn't just me doing it.

In any case, I wouldn't like to be the flight instructor who ol'Joe picks for this new proficiency-based recency requirement that has to tell ol'Joe that the way he's been flying his 172 for the last umpteen years won't cut it, any more.

The majority of accidents are a result of a lack of pretty basic flying skills.

Can we have some statistical evidence of which accidents, and which skills, please? I'm not saying you're wrong, but I'd like to see some hard numbers. This discussion arises out of intended action to improve night flying skills, and some TSB recommendations. There are some real accidents that happened to night VFR flights cited, at least.

It i kind of pointless for a pilot who regularly flies their Malibu to have to rent a 172 to demonstrate proficiency to an instructor who has no knowledge of flying the Malibu!

Are you confident that the kind of pilot that would benefit from having to demonstrate their proficiency in a Malibu can manage a 172 properly? if not, that would be a better place to start.

[digits_]

The flight review would mainly affect airplane owners. Renters usually have to follow more restrictive rebtal requirements anyway.

For the price of one hour dual and an hour ground instruction, the average airplane owner can likely fly more than 4 hours (variable cost only) in their own airplane. Would aviation safety be served more by having owners fly 4 hours in their own airplane, or an hour in an FTU 172?

The average instructor nowadays likely has less experience than the average airplane owner. How valuable will instruction like that be?

What if after that hour of training the FI thinks you are absolutely incompetent?

How many accidents are caused by a lack of skill vs bad judgement? It's almost impossible to train judgement in a mandatory 1 hour course.

[PilotDAR]

PilotDAR wrote: ↑Sat May 27, 2023 4:56 pm
It i kind of pointless for a pilot who regularly flies their Malibu to have to rent a 172 to demonstrate proficiency to an instructor who has no knowledge of flying the Malibu!

Are you confident that the kind of pilot that would benefit from having to demonstrate their proficiency in a Malibu can manage a 172 properly? if not, that would be a better place to start.

More, I'm concerned that some instructors might not be experienced enough to observe a check flight in a Malibu to beneficial value, and, if they took the Malibu owner pilot in a 172 for the check ride, some aspects of handing [or not so much] the advanced airplane type might not come to light during the check flight. I have flown check flights with owners of advanced types, who obviously could handle a 172 adequately, but became task saturated with the more advanced type, and the basic flying then suffered.

[l_reason]

I think the solution to this is not having (only) instructors doing the check rides. Along with the requirement for pilots to have check rides should be a short course for CPL/ATPL pilots to become qualified checkers. You don’t need to be an instructor to judge if a pilot can operate an aircraft safely. There are very few instructors that can go up in a classic tailwheel plane and offer meaningful advice and guidance that may improve on that pilot’s abilities. I’m not sure if there would be any instructors for guys with small flying boats, but I’m sure PilotDAR would be a fine judge of their ability. Sorry PilotDAR I don’t even know if you hold an instructor ticket or not, clearly it shouldn’t matter.

Most check pilots handing out type ratings in Canadian airlines are not qualified flight instructors.

[photofly]

The average instructor nowadays likely has less experience than the average airplane owner. How valuable will instruction like that be?

What if after that hour of training the FI thinks you are absolutely incompetent?

Those are two good questions, relevant in different circumstances. If the new recency requirement is a competency test (it isn’t) then it doesn’t matter how experienced the instructor is as she is riding along as a mini PE. The pilot can work on his own to fix his flying or employ an instructor - the same or different - or have a mentor pilot to help. But yes, as I said earlier, what if noob instructor Sheila thinks that pilot Daphne who’s got 10,000 hours in Cessna singles doesn’t meet the PPL (or CPL) standards any more?

On the other question of what the 250 hour instructor can teach the 8000 hour Cessna pilot- which is relevant to the new requirement reportedly for an hour of “instruction” in the air and an hour in the ground, I’m with Ben Zoma who said (paraphrasing) “Who is a good pilot? The one who can learn from anybody.”

The new requirement under 421.05(2) is going to have to be substantially less comprehensive than the present “flight review with an instructor” process, because as it currently stands, that has to be the “completion of a flight review conducted by the holder of a flight instructor rating in the same category, shall include all items normally covered during the flight test for the issue of that permit or licence;”

That means the instructor MUST review everything, including cross country navigation, precautionary approaches, short and soft field landings, and (for every holder of a CPL) a spin recovery demonstration. A CPL-holding Malibu owner presently can’t lawfully complete a flight review for recency in her own plane because it’s not certified for intentional spins. As sensible as she would be to undertake that review periodically, she still needs to fill in the quiz in the ASL to fly legally.

[PilotDAR]

.......shall include all items normally covered during the flight test for the issue of that permit or licence;”

That means the instructor MUST review everything,.......

It's going to have to be a [trained] judgement thing. If the check pilot has concerns about the candidate's skills, dig deeper. If the candidate is demonstrating consistent skills, and leaving no doubt, perhaps it should be a light touch on peripheral topics. My previous medical examiner would you the "headset and tones" hearing test ever time. My present examiner whispers with hand covering mouth, and asks me to read back. I asked if that was a valid "hearing" test. "No, it's a "screening" test. If I had any doubt about your hearing, I'd require a full test". Judgement - I agree!

The spirit of the upcoming requirement is good - to assure the continued competency in actually flying - actually fly! To what standard, and observed by whom, may require some refinement.

[photofly]

Just to be clear - neither the present nor the (reportedly) intended future requirements actually involve a test of the pilot's skill against any standard by anyone.

The present flight review method of compliance with 24 month recency requirements is specifically a review of all flight test items. No opinion need be formed nor judgement given. (This contrasts with the 5-year recency recovery procedure which does require the instructor to certify the pilot as meeting the flight test standard.)

The (reportedly) future requirement will be an hour of ground instruction and an hour of flight instruction. It remains to be seen whether any further detail is given as to of what those two hours should comprise; it may be that an hour of ground and an hour of in-flight aerobatics instruction suffices. Or instruction in some other skill or towards a different licence or rating (albeit in the same category of aircraft.) The pilot is likely to be equally unskilled at landing after that process as they were before it.

[fish4life]

I think the solution to this is not having (only) instructors doing the check rides. Along with the requirement for pilots to have check rides should be a short course for CPL/ATPL pilots to become qualified checkers. You don’t need to be an instructor to judge if a pilot can operate an aircraft safely. There are very few instructors that can go up in a classic tailwheel plane and offer meaningful advice and guidance that may improve on that pilot’s abilities. I’m not sure if there would be any instructors for guys with small flying boats, but I’m sure PilotDAR would be a fine judge of their ability. Sorry PilotDAR I don’t even know if you hold an instructor ticket or not, clearly it shouldn’t matter.

Most check pilots handing out type ratings in Canadian airlines are not qualified flight instructors.

I agree if someone can be qualified to do line in doc or check someone out on a 705 machine they should be able to check people out on a piston single provided they have currency on that class of aircraft. It’s like how you don’t need an instructor rating to teach multi IFR as long as you have 500 hours if I remember correctly.

[photofly]

I agree if someone can be qualified to do line in doc or check someone out on a 705 machine they should be able to check people out on a piston single provided they have currency on that class of aircraft. It’s like how you don’t need an instructor rating to teach multi IFR as long as you have 500 hours if I remember correctly.

A person who conducts a PPC or line indoc is qualified to conduct those procedures. But the qualification of the person is not sufficient. For any pass/fail assessment the procedure itself needs qualification. The contents of the PPC or the line indoc are prescribed - it's not left up to the feelings of the check pilot on the day. And the check pilot is familiar with the contents and vetted as being familiar with the contents.

Similarly the pass/fail 5 year recency retrieval procedure (421.05(1)) has both a qualfied person (an instructor) and a procedure ("the skill requirement for the (permit or licence)") with which the instructor is familiar and has been vetted as familiar, since learning to grade against flight test standards is a significant part of flight instructor training.

If TC is going to introduce any kind of testing to the new 24 month procedure (again, for clarity, at present, it is not) it will need to say to what standard that test has to be conducted, and be specific about who is qualified to administer it. While experienced multi-IFR pilots are qualified to teach that skill (and recommend a candidate for the flight test) they aren't considered by TC as competent to assess any other flying skill. People who have undertaken and passed instructor rating training are considered in wider circumstances as not just competent to teach but to assess, also.

[digits_]

I think the solution to this is not having (only) instructors doing the check rides. Along with the requirement for pilots to have check rides should be a short course for CPL/ATPL pilots to become qualified checkers. You don’t need to be an instructor to judge if a pilot can operate an aircraft safely. There are very few instructors that can go up in a classic tailwheel plane and offer meaningful advice and guidance that may improve on that pilot’s abilities. I’m not sure if there would be any instructors for guys with small flying boats, but I’m sure PilotDAR would be a fine judge of their ability. Sorry PilotDAR I don’t even know if you hold an instructor ticket or not, clearly it shouldn’t matter.

Most check pilots handing out type ratings in Canadian airlines are not qualified flight instructors.

I agree if someone can be qualified to do line in doc or check someone out on a 705 machine they should be able to check people out on a piston single provided they have currency on that class of aircraft. It’s like how you don’t need an instructor rating to teach multi IFR as long as you have 500 hours if I remember correctly.

Perhaps. But by the time you make it to a 704/705 line check or line indoc, there's very little doubt you know how to fly the aircraft. Multiple people have deemed you ready and competent. Note that training at that level is usually more about procedures than actual flying skills.

This new review flight is to deal with possibly incompetent pilots. It would likely be significantly more important that you have at least a basic knowledge of the aircraft the pilot wants to fly in. Which in reality will translate to 'fly the ftu airplane'. Which won't help much.

[Big Pistons Forever]

The majority of accidents are a result of a lack of pretty basic flying skills.

Can we have some statistical evidence of which accidents, and which skills, please? I'm not saying you're wrong, but I'd like to see some hard numbers. This discussion arises out of intended action to improve night flying skills, and some TSB recommendations. There are some real accidents that happened to night VFR flights cited, at least.

Aviation Consumer magazine does a report on a used airplane every month. The March issue, which I happened to have handy has a report on the Piper Arrow. Every report has an accident analysis where the magazine reviews the 100 most recent accident reports. Of those 100; accidents that support failures of basic flying skills are as follows


- Hard landing 10
- Stall/VFR LOC 8
- landed short 6
- Runway loss of control 5
- Hit obstacle on take off 4


For 20 accidents no cause was identified and for 20 more the primary cause was engine failure, mostly due to to a lack of maintenance or flying with known faults.

So of the 60 accidents left the 5 on the list above which total 33, seem to be clearly due to flying skill deficits. I think this airplane is a good example to pick because unlike say the C 172 almost all flying hours will be recreational flying rather than flight training or commercial operations.

Bottom line is that there seems to be lots of room for improvement with respect to the maintenance of basic flying skills in the GA community.

[photofly]

Is that in Canada, or the USA?

That data would support a recurrent training programme in those elements for owners and pilots of Piper Arrows. Possibly, in the USA. But a similar table for a different model of aircraft might have different causes of accidents. Hypothetically, for the C182, in Canada:

- CFIT 20
- loss of control following inadvertent entry in to IMC 12
- fuel exhaustion 7

That data suggests a very different recurrent training programme would benefit Canadian pilots of 182s. If C182 flights are more common than Piper Arrow flights then a training programme based on the needs of Arrow pilots will miss the mark (pun intended).

I suspect you’ll think I’m just being difficult, but it’s very easy to mislead oneself with partially-relevant statistics. And the country is relevant, considering different training and recency/currency regimes.

If you want to sort out recreational flights vs commercial, then the data should be sorted by type of flight, or at least by type of licence held by the pilot (CPL vs PPL).