Biennial flight review requirement coming to Canada from 2024

[Big Pistons Forever]

I think this is an area where Better is the Enemy of Good Enough. Any one size fits all policy won't be perfect but the reality is a that is the only way regulations can work. My personal feeling is that there is problem with a lack of foundation flying skills in recreational aviation.

I agree that a one size policy won’t be perfect, but we have a duty to try to make it about as good as a one-size policy can be, based on real evidence (which, when it is gathered, I accept may validate personal feelings.) It should certainly be backed by evidence from flights made by Canadian-trained and licensed pilots, and not American ones, if the goal is to plug holes in the Canadian flight training system.

I found this from TSB

From 2007 to 2016, of the 1166 aeroplane accidents with landing phase events, 21% involved collision with object, 21% involved missing or going off the runway, 21% involved landing gear collapse or retraction, and 19% involved a nosedown or overturning event. Of the 477 aeroplane accidents with take-off phase events, 28% involved collision with terrain, 28% involved collision with object, 26% involved loss of control, and 26% involved power loss.

Landings and takeoffs have historically been the flight phase with the highest accident rate. It appears to me that the kinds of accidents recorded are likely indication of skill degradation in the pilots especially the the 58% that in the collision with an object, nose down or overturning, missing or going of the end of the runway categories.

Just watching GA landings at my home airport I see many examples of poor technique.
Again my personal experience as a class 1 instructor for 30 years is that poor landing technique is always associated with poor fundamental flying skills, and hence drove my earlier comment regarding my perception of where the problem is.

Photo: Do you support a practical component to the 24 month requirement, and if so what do you think it should comprise ?

[Big Pistons Forever]

With respect to the Piper Malibu example I think this is a red herring. There is only about 20 Piston Malibu's in Canada. There are hundreds of C 172s so It would seem logical to concentrate on a system that will generate the most bang for the buck. In addition the insurance companies are driving training requirements for complex airplanes that are both significantly higher than any proposed regulation and type specific.

Right.

So if I do, for argument’s sake, my annual first class (and expensive) flight training at FlightSafety on my own Malibu, Meridian, Baron, TBM, 414, Cirrus, or any of dozens of other advanced types, with thousands of hours, you’re saying I can Still lose my pilot privileges cause some class 4 with 200 hours doesn’t like the way I fly a 172?

Do these rule changes apply to ATPL holders as well flying A320’s?

Haven’t read it in detail, seems unclear to me.

Exactly the devils in the details. It would be stupid that insurance required proficiency training on a complex aircraft would not meet the regulatory requirements for recurrent training. Unfortunately there is very little detail as to how this is going to work. Contrary to popular belief comments from industry and pilots do get looked at, but unfortunately many of these TC initiatives often don’t get many comments from individual GA pilots.

I would strongly suggest that you email what you want for this regulatory change. Better to be the windscreen than the bug…..

[digits_]

Landing is also the item that is the most airplane specific to train or check. Going up in an ftu c172 landing on a long runway isn't going to give one a good impression how that pilot would handle a Mooney on a short field or landing a Lancair without stalling.

Who is this regulation going to help?

The best remedy against all this stuff is for pilots to fly more and often. Extra regulations only make that harder to achieve.

[photofly]

Contrary to popular belief comments from industry and pilots do get looked at,

They certainly looked at the comments we all made about the shitshow that was the last set of proposals. This is already waaay better.

The best remedy against all this stuff is for pilots to fly more and often. Extra regulations only make that harder to achieve.

What if the regulation said that an alternative to the flight review was simply to have flown 10, or 20, or 50 hours in the last year?

[digits_]

What if the regulation said that an alternative to the flight review was simply to have flown 10, or 20, or 50 hours in the last year?

At first glance that would be nice. But you'd have to be careful for ill intended side effects.

I used to fly in a flying club that required at least one flight every 3 months per airplane type to stay current or you'd have to go up with an instructor. Which meant that after 80 days people were getting under a bit of pressure to fly, and would be very tempted to fly in weather conditions they would otherwise not attempt to fly in. Especially on the PPL level the question on 'when' to fly is more crucial than 'how' to fly. Too many restrictions that would pressure on a low time PPL pilot (or even experienced ATPL holders in small VFR only aircraft) on 'when' to fly would have a lot of negative effects IMO.

I'm not sure a biennial flight review is required, but if the regulator would go that route, perhaps you could link it to total experience? Eg < 100 hours: yearly follow up, < 500: biennial, < 1000: 5 yearly. It would be nice to have access to the source data on what they base this suggestion on. I can't really think of any accident that would be prevented by an extra check. But granted, it's hard to predict what the effect would be.

[photofly]

I think the paper recency requirements are dumb (I think everyone does) and I think ICAO requires some form of recurrent training, so Transport Canada can't get away with "just fly more", so now that a bunch of people here have discussed it, why don't we each give it our best shot at writing the new clause?

Here's the rubric you have to match, from the proposal:

\CAR 421.05 – Delete obsolete requirements in paragraphs 421.05(2)(b), (c), (d) & (g) and
add new currency requirements that consists of ....

Word your response in a way that fits into the framework of CAR Standard 421.05 as the new paragraph (h). Or more than one paragraph, if you want, (h), (i) etc, which after the changes will read as follows:

(2) In order to comply with the requirements of 401.05(2)(a), any of the following are considered acceptable as recurrent training programs:

(a) 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;
(b) - deleted -
(c) - deleted -
(d) - deleted -
(e) completion of a training program or Pilot Proficiency Check as required by Parts IV, VI or VII of the Canadian Aviation Regulations;
(f) completion of the skill requirements for issue or renewal of a pilot permit, licence or rating, including night rating, VFR over-the-top rating, instrument rating, multi-engine class rating, flight instructor rating, landplane or seaplane rating; or
(amended 2000/09/01)
(g) - deleted -
(h)......

[digits_]

and I think ICAO requires some form of recurrent training

Probably only when flying in IMC or VMC, and if we don't do that anymore (IFC, VFC), we can pretty much do whatever we want

[Big Pistons Forever]

a) 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;
-

I think you have to be careful for what you ask for. The PPL navigation exercises are a complete waste of time for a licensed pilot. Pilots use GPS to navigate in the real world so a navigation exercise should reflect how pilots actually fly. Similarly the thumb and a map diversion exercise is another low value added exercise. I tell all my students if you need to divert for real use the nearest airport function on the GPS.

I don’t think people are crashing because they didn’t put drift lines on the map.

TSB has lots of actual accident data. The exercises on the recurrent training should be evidence based and address the known areas where pilots get into trouble.

My submission to TC is going to emphasize using an evidence based approach to determining the what and the how for directions on how to meet the new practical training program and emphasize a train to proficiency model.

[photofly]

a) 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;
-

I think you have to be careful for what you ask for. The PPL navigation exercises are a complete waste of time for a licensed pilot. Pilots use GPS to navigate in the real world so a navigation exercise should reflect how pilots actually fly. Similarly the thumb and a map diversion exercise is another low value added exercise. I tell all my students if you need to divert for real use the nearest airport function on the GPS.

I don’t think people are crashing because they didn’t put drift lines on the map.

Those are the existing provisions; I didn’t ask for them nor do I need to approve of them, because they’re already there. I was merely quoting them for your convenience to see how the whole thing will look once this change goes through.

The new proposal doesn’t disturb the existing paragraphs (a) (e) or (f), which will remain as valid methods to meet the 24 month recency requirement. I am however inviting you to word your own new paragraph (h) for submission to TC, because the institution of a new paragraph (h) is their present proposal.

I haven’t offered my suggestion for (h) yet.

[Big Pistons Forever]

Photo

I asked you first. So tell us what you think para h should say

[photofly]

(h) one hour of ground instruction and two hours of dual flight instruction provided by the holder of a flight instructor rating for the same category focusing on the improvement of basic flying skills

(i) 5 hours of dual flight instruction towards a permit, licence or rating not held, provided by a person qualified to do so by standard 425.21 of these regulations; or

(j) (i)having recommended 3 students for their flight test for issue of a permit or licence, all of whom demonstrated the required standard of skill and knowledge; and (ii) having conducted 50% or more of the last 10 hours of the dual flight instruction for the students recommended in (i) above.

[sportingrifle]

Not trying to be argumentative here but honestly trying to understand how this is going to work. I get that the majority of recreational pilots fly relatively common aircraft but a large number don’t.
Recreationally I fly a DH Beaver on both wheels and floats, a Harvard, and a Stearman. I also do a fair amount of type training on all 3 types.
Other than perhaps “Big Pistons”, I do not know of a single flight instructor in my area qualified to teach on these aircraft. Am I expected to find a Class 3 or 4 instructor to ride along and sign me off? That is just a total waste of fuel, although the instructor will enjoy it and probably learn something.
More frustrating, would I be permitted to sign off somebody as competent to fly these types? The insurance companies are already happy for me to do so. In fact they often send people to me. Will this new rule force owners of less common aircraft to seek instruction from less than qualified instructors instead of people with the required “tribal knowledge” to operate the aircraft safely?
If TC want to successfully move this forward, I think they are going to have to think outside of their box a little more.

[photofly]

Recreationally I fly a DH Beaver on both wheels and floats, a Harvard, and a Stearman. I also do a fair amount of type training on all 3 types.
Other than perhaps “Big Pistons”, I do not know of a single flight instructor in my area qualified to teach on these aircraft.
.
.
.
If TC want to successfully move this forward, I think they are going to have to think outside of their box a little more.

One is all you need. If BPF isn’t available for a couple hours in any two year period (I know he’s very busy) will it kill you to go fly a 172 at an FTU? If you’re quite sure it’s impossible for you to learn anything of value perhaps you could think of it as a worthwhile sacrifice the universal practice of which will benefit many many other Canadian pilots.

Do write to the address in the document listed and explain your concerns, but if you want out of the box thinking from government you are much more likely to get it by thinking the thinking you want them to think yourself, writing it down, and hoping they’ll just sign it. It’s guaranteed they are going to move this forward with or without your approval, and now is your chance to influence it.

Putting it another way, the TC inspector who eventually will make the decision on this isn’t nearly as invested as you are - it’s a just a 9-5 job to them - so try writing the regulation you want to see yourself. Go on.

[Big Pistons Forever]

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. TC has significant personnel shortages so input into this instructor guide would be welcomed. If the initial version is problematic it can be amended directly by TC without going through the incredibly cumbersome rule making process

So my vote for para h would be

h) recurrent training is a flight review as per CAR 405.11 (c) and shall be conducted in accordance with CAR 405.14 Instructor Guide for 24 month recurrent training

CAR 101 flight training means a training program of ground instruction and airborne training that is conducted in accordance with the flight instructor guide and flight training manual applicable to the aircraft used;

Flight Training Program Requirements
405.14 Flight training that is conducted using an aeroplane or helicopter shall be conducted in accordance with the applicable flight instructor guide and flight training manual or equivalent document and the applicable training manual on human factors.

Division II — Flight Training Program
Flight Training Program
405.11 No person shall conduct flight training unless the flight training program is in accordance with the requirements of Subpart 1 in respect of

(a) the initial issuance of a permit, licence or rating;

(b) the renewal of a rating; and

(c) a flight review.

[PilotDAR]

So my vote for para h would be

h) recurrent training is a flight review as per CAR 405.11 (c) and shall be conducted in accordance with CAR 405.14 Instructor Guide for 24 month recurrent training

'Sounds good, if the "in accordance with..." does not actually require the check pilot to be an instructor, having alternately some kind of "let", as a CPL with some experience can "instruct" for a float or multi engine rating. I agree that there could be a scarcity of flight instructors with experience of value on types common to some recreational pilots.

[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.