And on the other question whether flight reviews may be conducted only by a Part 141 certificate holder…
Part 61 defines “flight review”:
flight review means an assessment of the competency of a flight crew member to perform:
(a) for the holder of a pilot licence or flight engineer licence—an activity authorised by a flight crew rating that the crew member holds; or
(b) for the holder of a glider pilot licence—an activity authorised by the licence.
CASR 61.400 says:
61.400 Limitations on exercise of privileges of pilot licences—flight review
(1) For this Part, successful completion of a flight review for a rating on a pilot licence requires demonstration, to a person mentioned in subregulation (2), that the holder of the rating is competent in each unit of competency mentioned in the Part 61 Manual of Standards for the rating.
(2) For subregulation (1), the persons are as follows:
(a) CASA;
(b) the holder of an approval under regulation 61.040 for this regulation;
(c) a pilot instructor who is authorised to conduct a flight review for the rating.
So far as I can tell, my AFR is a "flight review" of my SEA "rating".
I note that, in principle, anyone can be approved under reg 61.040 for the purposes of 61.400(2)(b). Further, Part 141 doesn’t rate a mention.
CASR 61.1230 says:
61.1230 Obligations of pilot instructors—records of activities conducted independently of Part 141 or 142 operator
(1) A pilot instructor commits an offence if:
(a) the instructor conducts a flight review or a session of flight training for a flight crew endorsement, other than an endorsement on an operational rating; and
(b) the training is not conducted on behalf of a Part 141 or 142 operator; and
(c) a record of the training is not made within 7 days after the session.
I note that 61.1230 expressly contemplates activities - including "flight reviews" - conducted independently of a Part 141 or 142 operator (provided the pilot instructor makes a record of the activities and is otherwise qualified).
Is the term “flight review” in that reg limited by “for a flight crew endorsement”? i.e the independent flight review can only be “for a flight crew endorsement”? If that’s what's intended, I reckon it’s poor drafting and inconsistent with the definition of “flight review”.
A “flight review” is “an assessment of the competency of a flight crew member to perform … - for the holder of a pilot licence -… an activity authorised by a flight crew rating that the crew member holds”. There’s nothing about endorsements in the definition of “flight review”.
However, over the last 12 months or so CASA has produced some of the more bizarre interpretations of legislation I have encountered, so who knows how CASA interprets regs like 61.1230.