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Authorized Intructor

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May 27, 2002
Here's a good question that I could never figure out.

What constitutes an "Authorized Instructor", specifically who can give out High Altitude Endorsements?

Here's the situation, occasionally I fly a King Air under 91 and sometimes I take a line guy with a Multi along, and let him fly the dead legs, he wants to log the PIC time but doesn't have the high altitude.

My CFI is expired a long time ago, and I don't think I can endorse his log book on basis of an ATP. Other than renewing my CFI is there any way for me to endorse his log book?

Can any current CFI give him a high altitude, or does that CFI also need a high altitude?

Also, could he log Instruction given (he has an MEI),for the legs that I fly without having a High Altitude?

Authorized Instructor

An authorized instructor is one who holds a current CFI certificate, or is signed off as a instructor and is currently a PIC for a 135/121 certificate holder, and then only may give training in airline service for the certificate holder. The ATP certificate makes no difference in this case.

In answer to you question about if the CFI is required to have a high altitude sign-off; 61.31(g) requires both ground and flight training. Granted the literal wording of the reg. would allow the ground training without the HA endorsment, but the flight training portion specifically requires training in a pressurized aircraft with normal operations above 25,000 msl. If neither pilot had a sign-off such a flight would be illegal.

The answer to the ME instruction time is NO also. The reg. states the the instructor must be certificated in catergory, class & type (if applicable), and for multi-engine aircraft at least 5 hours PIC in make and model. 61.195
To elaborate a little further:

61.1(b)(2)(ii) defines an "authorized instructor" as "a person who holds a current flight instructor certificate issued under Part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate".

The FAA legal department has issued an opinion indicating an authorized instructor need not have a high altitude endorsement (or any of the other endorsements indicated in 61.31) to provide training in an aircraft requiring such to act as PIC, AS LONG AS the instruction is not related to the endorsement. (See below)

So, can your flight instructor/friend provide training for a high altitude endorsement without holding one himself? No. Can he provide other types of training? Yes, according to the legal opinion, so long as he holds the appropriate pilot certificates, flight instructor certificates, and type rating if required (see 61.195(b)).

Finally, with regard to logging PIC time, 61.51(e) governs logging of PIC time. If the instructor is otherwise rated for the plane (category, class, and type if required), then he can log PIC time under 61.51(1)(i) even though he cannot act as PIC without the high altitude endorsement. When discussing logging of PIC time, endorsements are not considered "ratings".

If you are not familiar with Doc's FAR Pages, it's an excellent source for this type information, and coincidentally (?) a very similar question appears there very recently.


Legal Opinion:

Eastern Region
Office of the Regional Counsel
1 Aviation Plaza
Room 561
Jamaica, NY 11434

RE: Request for interpretation of 14 C.F.R. 61.195(b)(1)

Dear Mr. Dennstaedt:

This is in response to your letter dated March 5, 2002, wherein you ask whether a certified flight instructor (CFI) is required to have obtained the ground and flight training and one-time endorsement required under 14 C.F.R. (Federal Aviation Regulation [FAR]) 61.31(f), in order to conduct training in a high performance aircraft. Similarly, you ask whether a CFI is required to have obtained the ground and flight training and one-time endorsement required under FAR 61.31(e) to conduct training in a complex airplane; required under FAR 61.31(g) to conduct training in a pressurized aircraft; and required under FAR 61.31(i) to conduct training in a tail wheel airplane. With respect to each of these questions, you are referring to a case where the individual receiving the training has himself also received the requisite ground and flight training and one-time endorsement and thus is fully qualified to act as pilot-in-command (PIC) of the aircraft. In an e-mail message to me dated March 20, 2002, you indicated several examples of the type of training you were referring to: training in crosswind landing procedures, training an airman to obtain his commercial pilot certificate, or training an airman for the Wings program or other pilot proficiency program.

Under FAR 61.31(f), no person may act as PIC of a high-performance airplane unless that person has (i) received and logged ground training from an authorized instructor in a high-performance airplane, or in a flight simulator or flight training device that is representative of a high performance airplane; and has been found proficient in the airplane and systems of the airplane; and (ii) received a one-time endorsement in the pilot’s logbook from an authorized instructor who certifies the person is proficient to operate a high performance airplane. Under FARs 61.31(e), 61.31(g), and 61.31(i), there are similar training and endorsement requirements to act as PIC, respectively, of the complex airplane, pressurized aircraft, and a tail wheel airplane. As you indicate in your letter, a flight instructor, like any other airman, is obviously subject to these requirements if he wishes to act a PIC of one of these types of aircraft.

The question remaining is whether a flight instructor who otherwise meets the requirements for giving flight instruction but is not qualified under FAR 61.31(e)(f)(g) or (i) to act as PIC, respectively, of a complex airplane, high-performance aircraft, pressurized aircraft, or tail wheel airplane, can legally give training in such a (sic) aircraft to a pilot who is qualified to act as PIC of such an aircraft. In our opinion, he can give instruction so long as that instruction does not relate to skills necessary for an endorsement that the CFI does not hold. See FAR 61.193.

We note, however, that the fact that the individual receiving the flight training is qualified to act as PIC of the aircraft and his instructor is not, does not necessarily mean that the former is acting as PIC, and the latter is not. A PIC is defined in FAR 1.1 as “the pilot responsible for the operation and safety of an aircraft during the flight time.” Under National Transportation Safety Board (NTSB) case law, determining who acted as PIC of a particular flight can depend on a variety of circumstances, including but not limited to who owned the aircraft; who sat in the left seat; who handled the controls and radio communications; who decided the details of the flight; who exercise (sic) decisional authority with respect to emergency situations; who logged the time as pilot-in-command time; and what the understanding between the parties was. Administrator v. D.J. Cooper, NTSB Order No. EA-4433 (February 22, 1996). While the fact that one individual was qualified to act as PIC and the other was not is relative, but no dispositive.

If you have additional inquiries, please contact Zachary M. Berman of this office at (718) 553-3258.


Loretta E. Alkalay
Interesting, so you are saying he can LOG all the time he is sole manipulator as PIC, even though he can not ACT as PIC, because he does not have a high altitude endorsement.

I guess that's really all he needs, I'm just trying to help him get some good experience, I really could care less what he puts in his logbook.

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