midlifeflyer
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I'm not sure I see the reasoning. I don't findCitationLover said:it doesn't state it explicitly, thus it is a grey area (like a lot of reg's).
i got this confirmed from Larry Sturm of the Charlotte FSDO because we had a DE saying the spin endorsement HAD to be done within the 3 hrs prep time requirement from 61.39. we kinda beat the spin stuff around.
particularly vague. But grey or not, I wouldn't rely too much on the result of a jaw session. Although not really regulatory, there is a question in the Part 61 FAQ that asks whether non-24-month CFIs can be used for any of the initial CFI training. Lynch's answer is "no".Except for an instructor who meets the requirements of paragraph (h)(3)(ii) of this section, a flight instructor who provides training to an initial applicant for a flight instructor certificate must -
QUESTION: Our FSDO has come across a situation that seems to be a clear noncompliance issue with initial CFI training and we want to confirm our interpretation of the regulations.
§ 61.195(h) is the issue. Two local Part 61 training schools are taking the position that required training for the initial CFI can be given, in substantial part, by instructors that do not meet the two year/200 hour requirements of 61.195(h) ("senior instructors" in the local vernacular). As we read the regulation all instruction required for an initial CFI applicant has to be conducted by a CFI meeting the two year/200 hour requirement.
Can a "junior" instructor can be used in preparing an initial CFI applicant, and if so, what limitations on their use would apply?
ANSWER: Ref. § 61.195(h)(2); NO, a "junior" instructor cannot be used.
In accordance with § 61.195(h)(2), which states in pertinent part, ". . . who provides training to an initial applicant for a flight instructor certificate must- . . . . held a flight instructor certificate for at least 24 months . . . have given at least 200 hours of flight training . . ."
The rule requires that the training resulting in the required endorsements for an initial flight instructor applicant must be given by a CFI who meets the requirements of § 61.195(h)(2). Notice that this question does not involve the requirements for an instructor serving in an FAA-approved school under § 61.195(h)(3)(ii).