Biennial flight review requirement coming to Canada from 2024

[photofly]

One of the challenges for TC is the difficulty of actually changing a regulation. It is IMO much better if the regulation references another TC document. In this case it should be a flight instructor guide for the 24 month recurrent training. This guide would be Transport Canada publication (TP) and would controlled and amended by TC. The guide can provide the necessary granularity to make the recurrent training worthwhile and provide a means to allow alternate means of compliance, like the case of people flying unusual aircraft types. ...

This is great, and a huge step forward.

But in one sense, all we've done is kicked the can down the road a bit. The regulation says that 24 month recurrent training will be done IAW the "flight instructor guide for 24 month recurrent training" - but the job of changing the regulations - and having the flying public comment on it - can't be complete until you say, at least in outline, what's in this new Flight Instructor Guide for 24 Month Recurrent Training.

So... what's in it?

TC has significant personnel shortages so input into this instructor guide would be welcomed.

Fair point. Your turn to kick us off, then.

[Big Pistons Forever]

There are existing Instructor Guides for flight instruction for ratings that can be taught by an instructor that does not hold a flight instructor rating such as "Instructor Guide — Seaplane Rating - TP 12668"

There is no reason why an instructor guide for 24 month recurrent training could not specify situations where an instructor rating would not be required. I think the "what" is more important than the "who" if the goal is to make practical recurrent training actually useful and not just a box ticking exercise

[photofly]

What you would need is simply an extra clause in Standard 425.21 Qualifications of Flight Instructors:

(20) A person who conducts flight training toward a flight review conducted for the purpose of meeting the requirements of regulation yada yada yada shall have ....

or alternatively

(20) A person who conducts flight training toward a flight review conducted for the purpose of meeting the requirements of regulation yada yada yada shall have the qualifications specified in the Flight Instructor Guide for 24 Month Recurrent Training.

But again - in which document the details are written isn't as relevant as the details themselves. The what is more important than the where, so to say. What qualifications should such an instructor have? Specifics are important.

[Big Pistons Forever]

What you would need is simply an extra clause in Standard 425.21 Qualifications of Flight Instructors:

(20) A person who conducts flight training toward a flight review conducted for the purpose of meeting the requirements of regulation yada yada yada shall have ....

or alternatively

(20) A person who conducts flight training toward a flight review conducted for the purpose of meeting the requirements of regulation yada yada yada shall have the qualifications specified in the Flight Instructor Guide for 24 Month Recurrent Training.

But again - in which document the details are written isn't as relevant as the details themselves. The what is more important than the where, so to say. What qualifications should such an instructor have? Specifics are important.

I don't think it is necessary to amend 425.21 as this CAR speaks to instruction for the issuance of a rating, permit or license, which is not the case here. If there is a CAR enabling a Recurrent Instructor Guide than I think you have enough maneuvering room in it to address the qualification issue as part of the guide.

The Seaplane Guide has a fairly extensive preamble that discusses instructional techniques and so I envision something similar for the new guide.

[photofly]

Again, you're discussing the easy bit, and not the difficult and interesting bit: what should the qualifications for an instructor be?
Hours on type? Hours overall? Category of license? Combination of all three? Something else?

[Big Pistons Forever]

Again, you're discussing the easy bit, and not the difficult and interesting bit: what should the qualifications for an instructor be?
Hours on type? Hours overall? Category of license? Combination of all three? Something else?

Well if you want to be in a broad alignment with other parts of part 4 it could be instructor has 500 TT, 50 on type in the last 24 months, CPL/ATPL license for pilots doing recurrent training on Complex Aircraft, Multi Engine, Seaplane/ski plane, or conventional gear. All other airplanes require the instructor hold a flight instructor rating.

[photofly]

So.. a CPL with 1000 hours on a 172 but no instructor rating can't do recurrent training on a 172 because it's not complex, multi-engined, a seaplane, or conventional gear?

And a class 3 instructor with 400 hours, all on a taildragger, who can teach and recommend a PPL or CPL candidate in it, can't conduct recurrent training in the same airplane?

[Big Pistons Forever]

So.. a CPL with 1000 hours on a 172 but no instructor rating can't do recurrent training on a 172 because it's not complex, multi-engined, a seaplane, or conventional gear?

And a class 3 instructor with 400 hours, all on a taildragger, who can teach and recommend a PPL or CPL candidate in it, can't conduct recurrent training in the same airplane?

I think as a starting point it would be better to have someone who has a flight instructor rating do the flight training required for the required recurrent training. There are many, many pilots who hold a flight instructor rating and have lots of C 172 time who can do the training on buddies C 172. He should use one of those.

Regarding the tail dragger example my wording was careless. The intent is to provide an avenue for pilots who cannot easily access training from an appropriately experienced instructor who holds an instructor rating. Since in your example the instructor holds an instructor rating there would be no issue.

The intent was to have an alternative when we know the number of pilots who hold an instructor rating and have experience on the types listed is quite small, therefore general and specific total and type experience would be deemed sufficient, as is the case for example with the seaplane rating.

So here is a better wording

A holder of a valid instructor rating shall provide the flight training required for the 24 month recurrent training. However alternatively if the instructor has 500 TT, 50 on type in the last 24 months, and a CPL/ATPL they may conduct the required recurrent training on Complex Airplanes, Multi Engine airplanes , Seaplane/ski planes, or conventional gear airplanes.


So Photo how would you word the instructor requirements for thr 24 month practical ?

[7ECA]

Or, how about scrapping this entirely; as it is in essence just some box ticking exercise and will do little to nothing to enhance safety.

Aeroplanes are not falling out of the sky in Canada at an alarming rate, at least not at this very moment. So the idea that additional, and potentially prohibitively expensive recurrent training will somehow have a positive effect on accident rates (that are already low) seems like an utter fallacy.

How about Transport Canada focuses on things like, cleaning up the CARs and eliminating loopholes for 7XX operations, actually designing and implementing fatigue and duty regulations that have an actual clearly defined duty/flight time limit for the various subparts of commercial aviation, clearing up medical standards, etc...

But no, let's go after the low hanging fruit, recreational pilots and night flying. FFS.

[photofly]

\
So Photo how would you word the instructor requirements for thr 24 month practical ?

Given the goal is pilot training, and not pilot proficiency in any particular type, I don't see why owner-pilots of rarer types or classes should be permitted any lesser qualified instructor than pilots of Cessna 172s. To conduct your recency training in your own plane is a convenience only, and there's nothing to prevent you from finding a C172 to show off your skills to a local instructor instead. So if a particular level of hours or experience is adequate to conduct this training on a twin otter on floats, the same qualification should suffice for providing training for the same purpose in a 150.

That said, how about this:

425.21(20) An instructor providing dual insruction in an aircraft towards the requirement of Standard 421.05(h) shall meet the requirements specified in (1) through (19) above for the provision of dual instruction towards any licence or rating that is required to act as pilot in command of that aircraft.

That's on the basis that if a person is qualified to instruct towards a particular licence in that plane, they are doubtless qualified to conduct recency training in the same aircraft. It covers people who hold instructor ratings as well as people who qualify to provide seaplane ratings or multi-engine ratings by virtue of their experience.

[tsgarp]

The is another one of those ideas that looks good at first glance, but whose implementation has huge potential for cluster @#$!.

[Big Pistons Forever]

\
So Photo how would you word the instructor requirements for thr 24 month practical ?

Given the goal is pilot training, and not pilot proficiency in any particular type, I don't see why owner-pilots of rarer types or classes should be permitted any lesser qualified instructor than pilots of Cessna 172s. To conduct your recency training in your own plane is a convenience only, and there's nothing to prevent you from finding a C172 to show off your skills to a local instructor instead. So if a particular level of hours or experience is adequate to conduct this training on a twin otter on floats, the same qualification should suffice for providing training for the same purpose in a 150.

That said, how about this:

425.21(20) An instructor providing dual insruction in an aircraft towards the requirement of Standard 421.05(h) shall meet the requirements specified in (1) through (19) above for the provision of dual instruction towards any licence or rating that is required to act as pilot in command of that aircraft.

That's on the basis that if a person is qualified to instruct towards a particular licence in that plane, they are doubtless qualified to conduct recency training in the same aircraft. It covers people who hold instructor ratings as well as people who qualify to provide seaplane ratings or multi-engine ratings by virtue of their experience.

I am OK with that approach

[Big Pistons Forever]

The is another one of those ideas that looks good at first glance, but whose implementation has huge potential for cluster @#$!.

The train has left the station, so if you don’t like the destination send your issue to TC

[PilotDAR]

I've read the posts, and given them thought, so I'm thinking a step back: What is the purpose of the BFR? A check of competency? Or, Instruction? I believe that the purpose is a check. Thus, the term "instructor" for the role of the check pilot is parallel, and not required. Sure, if it works that an instructor do the check, that's fine. But, if no instructor with appropriate skills and experience is available, then another pilot who meets the experience and skill requirements of check pilot should suffice.

Now, define "check pilot" for this purpose: Must have some competency to assess the candidate skills. I think that airplane type and class considered, an instructor would. If an instructor is not available for the type and class of airplane, then a pilot with minimum experience on class and type (notice I'm not saying CPL/ATPL), who has also received basic instruction on the standards required for demonstration of pilot skills (which may be a new couple of hour "ground" course), probably in conjunction with an instructor's involvement.

I can think of a number of situations where the "best" mentor pilot available was only a PPL, just a really experienced on type PPL. Indeed, I recall that a group of police pilots were type endorsed by a PPL (I knew) - by special exemption, because there was no CPL with the required type endorsement, and experience to provide the training, and recommendation for type endorsement.

[photofly]

I don't think it's a check or assessment of any kind. I'd fight very very strongly against any proposal that had the possibility of anyone either failing, or not passing, or any other form or words that means that if you undertake the described process whatever it may be that it's possible your recency requirement isn't renewed.

If TC intends to implement any kind of pass/fail process (again, no matter how it's worded) that's a whole different question, and the pilot community needs test guides, and trained and assessed examiners to carry out the testing, and a programme to equalize standards nationwide, and an appeal process, and the whole works, just like there is for the initial issue of a licence or rating. In other words, it's a formal PPC. Otherwise we have the whole "Bob's a soft touch but don't fly with Alice, and I hear Phyllis will pass you if you donate to her son's charity" scenario, and it's all a disaster.

I'm 100% solid that this should be some amount (an hour, two hours, something like that) of instruction, and if the instructor doesn't think you fly nice enough, then that's his or her lookout, and your recency is renewed regardless.

[rookiepilot]

A 200 hour instructor on 172’s has absolutely zero business holding carte blanche authority for the licence qualifications for a 4000 hour PPL in their hands to renew or deny, when the instructor would have a hard time even starting the complex high performance aircraft the PPL flies.

This is stupid, and no other industry would do anything but laugh at an equivalent.

Lets instead discuss how instructors are allowed to teach IFR without one minute seeing the inside of a cloud.

[tsgarp]

The is another one of those ideas that looks good at first glance, but whose implementation has huge potential for cluster @#$!.

The train has left the station, so if you don’t like the destination send your issue to TC

I would if; 1.) I thought anyone was there to read it; and 2.) I thought they would listen.

[digits_]

The is another one of those ideas that looks good at first glance, but whose implementation has huge potential for cluster @#$!.

The train has left the station, so if you don’t like the destination send your issue to TC

I would if; 1.) I thought anyone was there to read it; and 2.) I thought they would listen.

They do read your reply and you will get a response.

[photofly]

You now have an extra month to send in comments - the consultation period has been extended to 6 July.

[Aviatard]

A 200 hour instructor on 172’s has absolutely zero business holding carte blanche authority for the licence qualifications for a 4000 hour PPL in their hands to renew or deny, when the instructor would have a hard time even starting the complex high performance aircraft the PPL flies.

What do you consider the minimum experience level to be for an instructor to be able to renew or deny a 4000 hour PPL? Is a Cirrus really that hard to start? I'm assuming you meant "high-performance" and not high performance. For the record I agree with you, I'm just wondering where you'd draw the line on experience.

I had an experience having to check out a new renter pilot on our aircraft. As we are chatting before the flight, I asked him what was the last aircraft he flew. His answer: T38. So I asked, you mean the USAF supersonic trainer? That T38? He said yup. So the I asked how he came to do that, and he answered: NASA.

I was checking out an actual 2-time Space Shuttle astronaut.