CFII Before CFI ?

[UndauntedFlyer]

The FAQ's are dead.

It does not read the way it used to. Get used to it.

You know better than that. Itis category and class; A is airplane; that is a category; SE is class, a single-engine.

Nosehair: Again, we all value your opinions and they are most important to this Board, but as Datonaflyer has pointed out, the regulation has really not changed on this point.

And while you are correct that the FAQ's are no longer available, they were the opinion of the FAA in Washington on this subject. I have not seen anything that says the opinions were wrong on anything in particular from the FAQ's. They were the opinions of the person who was responsible for Part 61 in Washington and nothing has changed since that opinion was written. It appears that the FAR on this has not been rewritten if DatonaFlyer has posted correctly.

Also, regarding the Category and Class: As you have correctly pointed out, category is Airplane, but class as per 61.5 as are placed on a pilot certificate are SINGLE ENGINE LAND, not AIRPLANE SINGLE ENGINE. There is no class called AIRPLANE SINGLE ENGINE for a pilot certificate. So as I have pointed out, no one is ever rated for a real Category and Class on their flight instructor certificate. If a person wants to teach in a sea plane they don't have the class "ASES" on their CFI certificate, they have it on their pilot certificate. So many people think that the same is true for a Flight Instructor with a rating of only INSTRUMENT AIRPLANE, if they want to teach in a single engine airplane or a multiengine airplane then they must have the respective CLASS on their PILOT certificate, just as the FAQ answer says.

Of course the confusion comes in as to what is a class. A class is ASEL or AMEL. But while ASE this is listed as a class for a CFI certificate it isn't really a class. That is the problem.

This was the same when the FAQ answer was written and nothing has changed as best as I can see.

Personally, I think that if the FAA wants to get rid of the problem with the FAQ's being in contradiction with the current opinions of the FAA, they will have to have a complete re-write of Part 61. Then the FAQ's are really dead. And I have heard that that may happen sometime soon.

And DaytonaFlyer has also pointed out the following that I believe is very true and a part of the confusion:

DaytonaFlyer:

"The difference is that the FAA refers to flight training and instrument flight training as two seperate types of training, both of which can be conducted in an airplane.

 

[AC560]

And while you are correct that the FAQ's are no longer available, they were the opinion of the FAA in Washington on this subject.

The above is incorrect.

They were the opinions of the person who was responsible for Part 61 in Washington

The above is correct.

John Lynch's opinions were just that and that is why the FAQ was removed.

 

[UndauntedFlyer]

John Lynch's opinions were just that (the opinion of the FAA person responsibe for Part 61) and that is why the FAQ was removed.

The FAQ's were written by an FAA inspector in his official capicity as a representative of the Administrator. Right? So that makes them the opinion of the Administator! Right? So now they are no longer available but they have not been officially cancelled. Right? So how are they any less valid as what was the opinion of the Administrator? And without an official recall or a re-write of Part 61, the FAQ's are still valid opinions of the Administrator. Or am I missing something here?

I agree that many of the things written in the FAQ's seem a little far out, especially with regard to crediting flight time, and I am sure the FAQ's stepped on some of the legal people's toes, and that's probably why they were taken down, but if they are no longer true, and were therefore incorrect, we should know this. Are they untrue, in all or part? What is the real story on the FAQs?

 

[AC560]

The FAQ's were written by an FAA inspector in his official capicity as a representative of the Administrator. Right? So that makes them the opinion of the Administator! Right? So now they are no longer available but they have not been officially cancelled. Right? So how are they any less valid as what was the opinion of the Administrator? And without an official recall or a re-write of Part 61, the FAQ's are still valid opinions of the Administrator. Or am I missing something here?

Taken from the FAQ itself

PART 61 FAQ's - With Change # 14-- QUESTION: Thank you for your letter dated April 20, 1999, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding the logging of pilot-in-command time. Specifically, whether a pilot needs to have the appropriate 14 CFR section 61.31 endorsements before he or she can properly log pilot-in-command time under 14 CFR section 61.51(e).


In your letter you state that you are “concerned with the answers given by John Lynch, AFS-840, through his Frequently Asked Questions 14 CFR, PARTS 61 & 141 website,” regarding the 14 CFR section 61.31 endorsements and the logging of pilot-in-command time under 14 CFR section 61.51(e). In this website, Mr. Lynch was given the following scenario: a person holds a private pilot certificate with a single-engine land rating. This pilot is obtaining training in a single-engine land airplane that is also a complex or high performance airplane. The question asked was whether this person could log the time he or she manipulated the controls as pilot-in-command time. Mr. Lynch stated that this person could not log pilot-in-command time under 14 CFR section 61.51(e) in a single-engine land airplane that is also a complex or high performance airplane, without having the appropriate endorsements required under 14 CFR section 61.31. This answer is incorrect.


ANSWER: Ref. §61.51(e)(1)(i); Before discussing this issue, please note that Mr. Lynch’s website is an informational website provided by the Flight Standards Service (AFS). It is not a legal site and the Office of the Chief Counsel does not review it. Accordingly, information provided on his website is not legally binding.

 

[siucavflight]

I have only my CFI IA, plenty of instrument sign offs, IPCs given. The DPA FSDO has renewed me every other year based on my pass rate. You can give instruction in an airplane, if not I think that they would have said something by now.

 

[nosehair]

I have only my CFI IA, plenty of instrument sign offs, IPCs given. The DPA FSDO has renewed me every other year based on my pass rate. You can give instruction in an airplane, if not I think that they would have said something by now.

As I said, it is being done all over. That doesn't make it legal according to the regulation. It is being 'accepted" by all the FSDO's and DE's as an "everybody knows" situation.

There is no seperate definition of 'flight training' as opposed to 'instrument flight training' in the regulations relating to instructor limitations.

61.195(b) says you have to have the cat and class on your CFI certificate to conduct flight training in an airplane.
61.195(c) adds the limitation that you must also have an instrument rating on your CFI certificate. It adds this requirement to (b), it does not stand alone in spite of (b). That's how you guys, and most other people read it, because that's how you want to see it.

I know it is being done, so more people saying that they do it doesn't make it legal.

I'll say it again: my only point was to show how regulations can take on a life of their own. If most of the population believes that the day begins at midnight, then that's how it is defined by that population - regardless of when the sun goes down.

I seem to remember some legal opinion on this once; and also that it may be cleared up in the new proposed part 61 rules that are cooking. Anybody hear any progress report on that?

 

[Amish RakeFight]

Nosehair,

A CFI-I may give instrument instruction in a SE or ME airplane even if he does not possess the CFI-A or MEI.

By reason of logic, the FAA would not permit the issuance of a CFI-I as the inital instructor certificate. Otherwise, there would have to be a provision which stated that a CFI-A would be required for CFI-I instrument training.

Your suggested reasoning that a CFI-I may only conduct training in a simulator is incorrect. If that were so, no one would be able to get an IFR ticket as only a portion of your training may be conducted in a simulator. The rest would have to take place in an airplane. That would negate your understanding that only a CFI/CFII may conduct training for an instrument rating, which is not the case. If it were, then there would be a stipulation requiring the CFI-I to be in possession of the CFI-A.

The pont here is that you are giving instrument flight training. Not flight training for ME procedures or SE procedures. Once certificated, it is understood that you have demonstrated competency in these operations.

It is only required that one have the SE and ME on their pilot certificate. A CFI rating is in place to train a pilot for a specific PTS, such as the instrument tasks.

Clear?

 

[AC560]

A CFI-I may give instrument instruction in a SE or ME airplane even if he does not possess the CFI-A or MEI.

Can a CFI-I with no other rating give the 3hrs of control and maneuvering of an airplane solely by reference to instruments... for the initial private certificate?

 

[nosehair]

By reason of logic,

I totally understand your logic. It is the very same logic we all applied until the regulation changed.

Now it says, in addition to having the rating on your pilot certificate, that it must be on your flight instructor certificate, also.

Didn't used to say that. I don't know when it changed, but I know this controversy has gone on some time.

When I first got a CFI in 1963, the CFI was category only; CFI - Airplane, CFI - Helicopter, etc.

You could CFI in whatever was on your Commercial.

You didn't have to have an instrument rating to have a commercial or CFI. If you got an instrument rating you could teach instruments - if you got a ME rating, you could teach ME.

Then in '74, I think, they (the FAA) changed the rule to require an instrument instructor rating and a ME instructor rating, seperately.

But, the double-eye was category only. You could still instruct instruments in a multi - even without a ME on your commercial.

But that's not how it reads today, but the mis-understanding throughout the training and certification still responds as though it were still the same as it used to be.

Again, I have not seen a current legal opinion that contradicts the current FAR.

 

[UndauntedFlyer]

One strange thing about the CFI-IA, while we say this is OK for teaching instrument only in whatever class of airplane that's on that person's pilot certificate, such an instructor must actually teach more than "instrument" instruction. They must also teach airplane flight instruction. I'm speaking of the circling approach to a landing and in the multiengine area, a CFI-IA does have to teach engine out procedures. That's because those tasks are on the IRA test for those applicants seeking their ratings in airplanes, the single engine work is required if the test is in a twin.

In any event, this is a gray area that apparently causes the FAA Flight Standards folks to look the other way and not ask too many questions. I guess everybody in aviation just likes it the way it is because it works OK.

There are really many things like this, for example: If you really read the certification requirements for the instrument rating (IRA), a person would have to have 43 hours of instrument time logged, 3 for the private pilot (PA) and 40 for the instrument. And for the commercial pilot (CA) who is instrument rated, he/she would need to have 53 hours of instrument time logged, 3 for PA, 40 for the IRA, and 10 more for the CA. The FAA in DCA looked at this one time because that is what the regulations now say, and were going to start enforcing this, but backed off when it appeared they were going to have to recall 1000's of currently issued certificates. It was too disruptive so they just said, let it go. That wasn't the intention in the rewrite of Part 61.

So you see, it is the same thing here, it says what it says, but at least for now, the FAA does not make an issue of this. I expect that in the upcoming new rewrite of Part 61, this will be clarified. I hope it stays the same just so we can continue to have the "Double I only" specialists. They are unique and somewhat of a carryover from the CFI-A days.