CFII Before CFI ?

[Amish RakeFight]

There would have been an AC or something for such an important change in training tradition. Current CFI's would have been mailed literature on the change in guidence. If the local FSDO and DPE's aren't making issue of it, then it must be okay. No one seems to have any stories of CFII-only's being violated either.

 

[AC560]

There is nothing that restricts a CFII to teaching instrument rating students only. It only limits him to teaching instrument flight training.

So what things in 61.107 can a CFI-I sign for and what things does a CFI-A need to sign for?

61.193 says A person who holds a flight instructor certificate is authorized within the limitations of that person's flight instructor certificate and ratings to give training and endorsements

61.195(c) says flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided.

The only limitation seems to be if you want to teach IFR training you need to be a CFI-I. There doesn't though seem to be any restriction to a CFI-I saying you can't teach things other then XYZ.

I am sure I am just missing something but I never really thought about it much until this thread came up. Because they way I read through it is if you accept the fact that CFI-I can instruct in a plane they can do everything.

 

[Amish RakeFight]

A CFI can teach you whatever they want to cover. However, if the training is to lead to a private certificate, then these hours must be flown with a CFI-A. If the objective is to train for an instrument rating, then the training time logged has to be spent with a CFI-I.

 

[UndauntedFlyer]

I talked to the FAA in DCA on this subject today and they said nothing has changed on this, a CFI-IA (only) can still teach and recommend a pilot for the IRA ticket. Nothing has changed and there was never any intention to change this. We did not discuss the 3 hours required for the PA.

 

[UndauntedFlyer]

I've never seen anything that says you can or cannot use a CFII who does not also have a CFI.

Daytonaflyer: I keep telling you but you will not listen. There is no such thing as a CFI (only). A CFI-I is also a CFI and so are all 7 CFI certificates. Your post makes no sense unless you identify what you mean by a CFI. If you mean a CFI-A(SE) then say so. Or do you mean a CFI-A(ME), or maybe you mean a CFI-G, or CFI-RH, or maybe a CFI-IH. Nobody knows for sure when you say CFI. I thought we went all through this. Don't you believe me or what?

 

[AC560]

However, if the training is to lead to a private certificate, then these hours must be flown with a CFI-A. If the objective is to train for an instrument rating, then the training time logged has to be spent with a CFI-I.

Where this is in the FAR's though, because all that I see is if you want to teach for the instrument rating your need a CFI-I. I don't see anything else.

a CFI-IA (only) can still teach and recommend a pilot for the IRA ticket.

Where is this limitation in the FAR's.

 

[UndauntedFlyer]

Where this is in the FAR's though, because all that I see is if you want to teach for the instrument rating your need a CFI-I. I don't see anything else.

Where is this limitation in the FAR's.

I'm really not sure what you are asking because there are no limitations specifically mentioned for a CFI-IA that I can think of, except for the limitations that apply to all CFI’s. But as I and many others have mentioned a CFI-IA can train and recommend instrument airplane students for their instrument rating airplane test. It is done all the time and I have personally tested such instrument applicants. Plus, as I have already mentioned, IACRA looks at the qualification of the recommending instructor and IACRA has been programmed by the FAA certification branch to allow a CFI-IA to recommend an IRA student for his/her practical test. Furthermore, just 2-days ago I happened to be talking to the FAA IACRA guru in DCA on just this subject. He says there are no plans to change this and my question was the first he had heard that there was any controversy on this subject. He thought that the privileges of a CFI-IA were clearly understood to be training and recommending IRA students.

Now as far as providing the 3 hours instrument time to a Private Airplane student, I don’t really have nor does anyone need an opinion on this because it is a rather ridiculous question and concern. Clearly a private pilot will be receiving all of his/her training from a CFI-A, and certainly that instructor will be the one providing the 3-hours of instrument time. It’s the CFI-A instructor that will be doing the recommending and that instructor will be the one to verify the proficiency of the student on the instrument tasks.

 

[AC560]

I'm really not sure what you are asking because there are no limitations specifically mentioned for a CFI-IA that I can think of, except for the limitations that apply to all CFI’s.

Which means that a CFI-I has no restriction on any instruction in an airplane nor endorsement. The limitation on a CFI in the FAR's is that to instruct for the instrument you need the CFI-I. I see no restriction that says a CFI-I cannot give instruction for ratings or certificates other then the instrument.

 

[nosehair]

just 2-days ago I happened to be talking to the FAA IACRA guru in DCA on just this subject. He says there are no plans to change this and my question was the first he had heard that there was any controversy on this subject. He thought that the privileges of a CFI-IA were clearly understood to be training and recommending IRA students.

Too bad you didn't have your FAR's handy to show him FAR 61.195(b)"A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
(1) A pilot certificate and flight instructor certificate with ( I say again) with applicable class and category ratings."

And then look at FAR 61.1, which defines flight training as: "...means that training, other than ground training, recieved from an authorized instructor in flight in an aircraft."

Doesn't say "other than instrument training"; it says "any flight training in an aircraft".

I believe if you could have shown him those two regulations, he might have had a different opinion as to the state of confusion which exists from the wording of it (them).

 

[AC560]

Just checking to see if UndauntedFlyer has posed NoseHairs questions to his contacts in Washinton.

 

[UndauntedFlyer]

No....I think we have been around and around on this one. No more comment on this from me.

 

[AC560]

FAA Order 8700.1, Vol 2, Chap 11,Section 1, Para 8
==============================
flight instructors who hold an “INSTRUMENT—AIRPLANE” rating only on their flight instructor certificate are authorized to give instrument flight instruction in single- and/or multiengine airplanes for instrument certification, provided they hold single- and/or multiengine ratings on their pilot certificate.
==============================

Not my research but it would appear to give the necessary allowance to allow CFI-IA only to give instrument training in an airplane.

 

[nosehair]

FAA Order 8700.1, Vol 2, Chap 11,Section 1, Para 8
==============================
flight instructors who hold an “INSTRUMENT—AIRPLANE” rating only on their flight instructor certificate are authorized to give instrument flight instruction in single- and/or multiengine airplanes for instrument certification, provided they hold single- and/or multiengine ratings on their pilot certificate.
==============================

Not my research but it would appear to give the necessary allowance to allow CFI-IA only to give instrument training in an airplane.

That would be a reasonable asumption based on your quote of the FAA Order 8700.1...but,..what's the date on that, and do you know it's current?...and has it been 'updated' to reflect the current FAR.
I know for a fact that the 8700.1 sometimes lags behind in getting changed to reflect FAR changes, particularly Part 61 Certification rules. They are the lowest on the totem pole of 'FAA things to do' list.

That Order would reflect the old rule, when the verbage was not the same as 61.195(b)(1) reads now.

And any FAA Inspector will tell you that FAR's supercede FAA Order 8700.1. It's a workbook designed to detail the execution of FAR's, not implement them, or be used as case evidence.
It's like OpSpecs which haven't been updated to reflect regulatory changes. And the Inspector is supposed to be aware and not use it - or make the appropriate change - which, of course, leads to individual interpretations.

 

[UndauntedFlyer]

Nosehair:

I have seen much evidence that goes against your view on the authority of the CFI-IA yet you insist it is all wrong because the FAR has been changed. Yet it has been proven that the FAR has been the same for many years. So I don't understand why you are so strongly in support of the postion that a CFI-IA must have an Airplane rating on his CFI certificate to teach instruments in an airplane.

So anyway, my question to you it this: Do you know of any FSDO that would not renew a CFI-IA (only) that presented a record of 5 recommendations with 5 passes for the IRA flight test. And if any of those files came through that office from the FSDO's examiners would that FSDO reject them by saying the CFI-IA wasn't qualified. And if all that is true of that office, wouldn't the Office have an obligaton to come after the CFI-IA for giving unauthorized CFI instruction when not qualified. So can you name such a FSDO who would do all of this in support of your postion?

On the other hand, I do know that the DPA FSDO has promptly renewed such a CFI based on this activity and that was the end of it. I would guess that all FSDO's would do the same because that is the current direction from Washington based on my latest calls to them on this subject.

 

[nosehair]

Nosehair:

I have seen much evidence that goes against your view on the authority of the CFI-IA yet you insist it is all wrong because the FAR has been changed. Yet it has been proven that the FAR has been the same for many years. So I don't understand why you are so strongly in support of the postion that a CFI-IA must have an Airplane rating on his CFI certificate to teach instruments in an airplane.

So anyway, my question to you it this: Do you know of any FSDO that would not renew a CFI-IA (only) that presented a record of 5 recommendations with 5 passes for the IRA flight test. And if any of those files came through that office from the FSDO's examiners would that FSDO reject them by saying the CFI-IA wasn't qualified. And if all that is true of that office, wouldn't the Office have an obligaton to come after the CFI-IA for giving unauthorized CFI instruction when not qualified. So can you name such a FSDO who would do all of this in support of your postion?

On the other hand, I do know that the DPA FSDO has promptly renewed such a CFI based on this activity and that was the end of it. I would guess that all FSDO's would do the same because that is the current direction from Washington based on my latest calls to them on this subject.

I'm not supporting the position, merely speculating on the obvious wording of FAR 61.195(b)(1). I am looking for supporting evidence of this authorization.

As far as FSDO's treatment of the rating, it is in confusion, and it is a legal rating that you can work with - in a simulator. IR applicants can get 25 hours hood in an airplane with a safety pilot, then do the 15 hours with a CFII in a sim - and that CFII can recommend, so there you go.

 

[Amish RakeFight]

Nosehair, I don't think anyone else shares your interpretation of this reg. It just doesn't make logical sense and makes the CFII very restrictive.

 

[nosehair]

Nosehair, I don't think anyone else shares your interpretation of this reg. It just doesn't make logical sense and makes the CFII very restrictive.

It isn't an "interpretation", it is black-and-white. Just because the FSDO says it's ok doesn't make it true.

As far as "logical", don't you really think it is "logical" for an airplane instructor to have "airplane instructor" on his instructor certificate? Doesn't matter if he's only teaching instruments - he's instructing in the air in an airplane. Show me one street person who thinks that is "logical" and safe.

You, we, the pilot population may screw it around to make it "logical" because it makes the training / rating ladder easier to climb. That's the kind of skewed logic you're using.

 

[midlifeflyer]

That would be a reasonable asumption based on your quote of the FAA Order 8700.1...but,..what's the date on that, and do you know it's current?...and has it been 'updated' to reflect the current FAR.
I know for a fact that the 8700.1 sometimes lags behind in getting changed to reflect FAR changes, particularly Part 61 Certification rules. They are the lowest on the totem pole of 'FAA things to do' list.

Good question. First of all, I'll say that I personally agree with your reading of the reg on both a legal and "sense" level (teaching a single engine instrument approach in a twin doesn't require an CFI-AME? And, there is a bit of history, including, as I recall, a Eastern Regional FAA legal opinion, that supports your reading.

But...

The version of 8700.1 that blurb comes from includes the revisions through 11-15-05, so it is current. Or, at least as current as it can be - Order 8700.1 was (recently) canceled and replaced by 8900.1 (http://fsims.faa.gov/). The quoted language has been reproduced without change at para 5-503.


I don't know what the prior 61.195 language was (or even if it was in the same place), but the current 61.195 language goes back to the August 1997 Part 61 revision.

Although it is not mentioned in the part dealing with this, there are in fact revisions to 8700.1 that deal with the the fact that "On August 4, 1997, a complete rewrite of part 61 became effective." (the quote is from a part of 8700.1 that talks about night flying restrictions).

FWIW group, the 8700.1 interpretation is identical to John Lynch's in the officially-disowned Part 61 FAQ which was written specifically to deal with the 1997 revisions.

Even if it's a low-priority item for the 8700.1/8900.1, 10 years is a bit long to let a glaring error sit around uncorrected.

One anecdotal piece -I am aware of one enforcement action that was initiated against an instructor for a violation of 61.195 for giving instrument instruction in a multi with a CFI-ASE and CFI-IA but not CFI-AME (but with an AMEL on the commercial certificate). The information I have (I was not directly involved) is that after the FAA Inspector conferred with Lynch, the action was dropped.

 

[nosehair]

the action was dropped.

Yep, I know. This isn't worth them worrying over. Or me either. Or anybody else, here. It goes on quite nicely,.. but be aware.

Has anybody heard any news about the upcoming part 61 'rewrite'..?

 

[Amish RakeFight]

Has anybody heard any news about the upcoming part 61 'rewrite'..?

No, but it sounds like you might have. What's in store?