What constitutes a flight review for the purposes of eligibility for a remote pilot certificate under 14 CFR 107.61(d)(2)? An applicant for the Remote Pilot Certificate who already holds a pilot's license can forgo the knowledge test required by 14 CFR 107.61(d)(1) if they have a current flight review. The regulation states that an applicant must be able to demonstrate aeronautical knowledge by satisfying one of the following conditions:


  14 CFR 107.61(d)  
  
  (1) Pass an initial aeronautical knowledge test covering the areas of knowledge specified in §107.73(a); or  
  
  (2) If a person holds a pilot certificate (other than a student pilot certificate) issued under part 61 of this chapter and meets the flight review requirements specified in §61.56, complete an initial training course covering the areas of knowledge specified in §107.74(a) in a manner acceptable to the Administrator.


14 CFR 61.56 specifies that a flight review is: 


  (a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training.  
  
  [...]  
  
  (b) Glider pilots may substitute a minimum of three instructional flights in a glider, each of which includes a flight to traffic pattern altitude, in lieu of the 1 hour of flight training required in paragraph (a) of this section.  
  
  [...]   
  
  (f) A person who holds a flight instructor certificate and who has, within the period specified in paragraph (c) of this section, satisfactorily completed a renewal of a flight instructor certificate under the provisions in §61.197 need not accomplish the one hour of ground training specified in paragraph (a) of this section.


Are these definitions to be understood as the definition of a flight review, or might the following flight review exemptions also count for the purposes of §107.61(d)(2)?


  (d) A person who has, within the period specified in paragraph (c) of this section, passed any of the following need not accomplish the flight review required by this section:
  
  (1) A pilot proficiency check or practical test conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege.
  
  (2) A practical test conducted by an examiner for the issuance of a flight instructor certificate, an additional rating on a flight instructor certificate, renewal of a flight instructor certificate, or reinstatement of a flight instructor certificate.
  
  (e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily accomplished one or more phases of an FAA-sponsored pilot proficiency award program need not accomplish the flight review required by this section.


For the purpose of initial certification under §107(d)(2), is a flight review to be understood strictly as the training defined by 14 CFR 61.56 (a), (b), or (f), or do the exemptions to the requirement for a flight review—14 CFR 61.56 (d) or (e)—also count as a flight review?
You have to take into account the intent of the regulation.  I think the regulations intent is to ensure the pilot has been evaluated on his knowledge within the previous two years by either a CFI or examiner.

With that in mind, a flight review by a CFI or passing a practical test by an examiner satisfies the requirement for the remote operator to take the full initial knowledge test.



From the preamble to the Part 107 final rule.


  The FAA proposed that a certificated remote pilot must also pass a recurrent aeronautical knowledge test every 24 months. Like the flight review requirement specified in §61.56, the recurrent knowledge test provides the opportunity for a remote pilot’s aeronautical knowledge to be reevaluated on a periodic basis. The FAA adopts this provision as proposed, with one change. As discussed in III.F.2.i, the FAA exempts part 61 pilot certificate holders from the requirement to complete recurrent knowledge tests as long as they satisfy the flight review requirements of §61.56 and complete an online training course every 24 months


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  The FAA agrees with commenters who suggested that requiring part-61- certificated pilots who satisfy the flight- review requirements of §61.56 to take an initial or recurrent knowledge test is unduly burdensome. Through initial certification and subsequent flight reviews, a part-61-certificated airman is required to demonstrate knowledge of many of the topic areas tested on the UAS knowledge test. These areas include: Airspace classification and operating requirements, aviation weather sources, radio communication procedures, physiological effects of drugs and alcohol, aeronautical decision-making and judgment, and airport operations. Because a part 61 pilot certificate holder is evaluated on these areas of knowledge in the course of the part 61 certification and flight review process, reevaluating these areas of knowledge on the initial and recurrent knowledge tests conducted under part 107 would be needlessly duplicative. 


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