That's is just the requirements for formal 'Flight Training', which requires formal qualifications to conduct. That is anytime a candidate is seeking a licence, rating, endorsement or special design feature you have to apply those rules. You can conduct other training, such as recurrent training, general improvement or finesse, how to drop a flour bomb, and other things that don't fit into the 'Flight Training Requirements' sections, without the need to hold an instructor rating. And you won't be able to log most of it as training as it's not formal flight training as such. Again that's what happens during airline line training. Basically if you are conducting 'dual training' then you have to apply that section of the rules. Anything else is just 'training' in general.

I would consider training during an AFR as training for the validation of a licence, therefore related to the issue of a licence. The same as if you fall out of recency for IFR flight, you can undertake dual instruction in the areas required to regain currency for that rating, so it is training related to that rating.

I think the tenuous link is in the list of 'Part 141 flight training' in CASR 141.015(1): "(f)training, other than training conducted as a multi‑crew operation, that is given as part of a flight review". It's an attempt to turn something that does not fall within the definition of "flight training" into "flight training".

Whether that works? Only a court can decide.

If it works, "Part 141 flight training" could include training someone to whistle Dixie in an aircraft, by just adding that training to the list in 141.015(1), even though training someone to whistle Dixie does not fall within the definition of "flight training".

If I had received this reply from CASA I would ask for a regulatory reference.

Pretty sure the first line used to read "for the issue of" or "training towards the issue of". Now it reads as any training associated with those items, whether you hold the licence or not. So if you conduct training in sequences related to those items you are conducting formal flight training for those items.

I love all this going around in circles. At the end of the day someone has to sign a licence (or fill out online form) saying that person x still meets the the competencies of the licence as set out in the M.O.S. That’s person name will be attached to having judged those competencies for the next 24 months or AFR. One thing they should be doing is promoting safety. The OP was not doing anything unsafe so I would say “sure do run ups if you want”. If something goes wrong later ATSB will pull the records of the pilot and who did their last AFR and ask lots of questions. Because I am assessing their ability and will have to take over if unsafe “I am PIC” and will make that quite clear in the briefing (same as when I’m wearing my FE hat on a test).

I think that 61.210 was mostly aimed at PICUS/ICUS programs that were created to meet the need for 500 hours multi engine PIC, especially in regards to airlines hiring low time pilots/cadets. There is now a legal statement that requires the airlines/operator to have a specific program outlined to allow it to happen. It does open up other things, akin to what universities/TAFE do these days and let the industry create it's own little development courses that are not necessarily required but may be nice to have, and then require them to have some sort of syllabus and assessment process.

I think you need to read the whole of 61.195. I posted it at #100.

Note that subreg (1) merely specifies what subreg (2) applies to. Subreg (2) is about applicants for the stuff in (1), and what those applicants have to do to get it.

Australia the land of making vintage GA aeroplanes complicated to operate!

No wonder GA hours are dropping!

Yup, they have left no wheel uninvented.

This conversation dulls the senses, this would test anybody on the 12 steps to sobriety.

On another note, has anybody now got an expired SE FR because CASA has yet again changed an interpretation of what renews FR's?

Doesn't "flight training" require the copious writing up of and signing of paperwork?

If so, perhaps that's the layman's distinction then??.. if there's no write-up on the specific action then it isn't "training" - it's one-on-one coaching in the care and handling of an aircraft by your very own rent-a-friend.

"flight training" in CASR is whatever CASR defines it to mean. The definition of "flight training" in CASR does not include training that is given as part of a "flight review".

My (perhaps quaint) view is that the term "Part 141 flight training" can only mean a subset of what CASR defines as "flight training", not go beyond it.

A "flight review" is defined to mean an assessment of competence. The concept of training as "part of" a flight review is a confusion of the concept.

Let's say a pilot presents for a flight review but does not meet standard. In USA I have the option of giving that applicant whatever training is required in the hope they can demonstrate they meet standard later If they agree I will provide the instruction required and ask them to schedule a new flight review attempt. That first session is signed off as instruction given not as a failed flight review.

If the applicant meets standard at the next attempt I will sign them off for a satisfactory flight review (in FAA parlance this is an endorsement). The applicant and I have the option of repeating this process as many times as we wish. However, if the flight review attempt requires training, then clearly the applicant did not meet flight review standard.

That approach is entirely consistent with the regulatory structure in Australia. But what's happened is that a "flight review" has morphed into something it's not supposed to be, fuelled by this kind of nonsense published by CASA:That’s not the purpose of flight reviews. I’m sure there are lots of people who want that to be the purpose of flight reviews, for a variety of reasons not confined to safety, but that’s not what the words in the definition say or mean.

The term “flight review” is defined in CASR to be:A flight review is an assessment of competence. I can’t see any words that say or mean: “The purpose of a flight review is to provide a pilot with the opportunity to receive training that refreshes their flying skills and operational knowledge.” A pilot can choose to take up that opportunity any time the pilot thinks it’s necessary or desirable. But the fact is: an assessment of competence is not flight training.

Whether a pilot wants to receive training in order to deal with any relevant unit of competency in which the pilot has been assessed by an instructor as “not competent”, and the circumstances in which that training, if any, will occur, are supposed to be – and technically still are – matters for the pilot and the instructor to decide.

The 'gap' I see in the definition of "flight training" is that it does not include training 'in the abstract' - i.e. training delivered to someone who is already the holder of the licence, rating/s and endorsement/s required to do whatever flying activities in which they're currently engaged.