CFII Before CFI ?

[UndauntedFlyer]

Many of you may find this strange and it is uncommon, but I know several CFI-IA's that are only CFI-IA's. And they get more than their share of instrument students because they hold themselves out as instrument only specialists and people buy it. Yes I know this is rediculous because those with the ASE in addition to the CFI-IA are just that much more qualified but for whatever reason the CFI-IA's are doing OK, plus they can call themselves CFI's for their ego if they wish. Plus since they really don't like to sign off BFR's for their friends (liability concerns) who can not fly very well, they have the best excuse in the world, "Sorry I'm only a CFI-IA, I can not do BFR's, only instrument instruction, I'm a specialist." Those that are just CFI-IA's that I know like their special distinction that they think they have.

 

[UndauntedFlyer]

Nosehair: Again, I mean no disrespect of your valuable opinions but it seems that the FAQ's on this subject do not agree with the interpetation that you have posted on this subject: A CFI-IA can give instrument training in an airplane as long as his/her pilot certificate have the appropriate catagory and class rating. According the the FAQ on this, the class rating is not required on a CFI certificate. And besides, there are no class ratings ever on a CFI certificate, Example: CFI-ASE is not a class, CFI-AME is not a class, CFI-G is not a class. So how could it be necessary to have an appropriate catagory and class rating on a CFI certificate when there is no such thing? Your comments please.

QUESTION 3a: Can a Flight Instructor with only an Instrument-Airplane rating on his CFI certificate (but no Airplane Single-Engine rating on his CFI, but does have the Airplane Single Engine Land rating on his pilot certificate) give the flight training required by §61.107(b)(1)(ix) and §61.109(a)(3) for the Private Pilot Certificate and the Airplane Single Engine Land rating?

ANSWER 3a: Ref. §61.195(c); The answer is yes, provided the flight instructor holds “. . . 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 answer is addressed in §61.195(c), which states:

(c) Instrument Rating. A 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.

Read the words “. . . 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” VERY CAREFULLY. Yes, that is what it means.

So in the example in your question, the flight instructor would have to hold instrument privileges for the Airplane Single Engine Land rating on his pilot certificate AND ALSO instrument instructing privileges for the single engine airplane on his Flight Instructor Certificate. Yes, that is what §61.195(c) means! In the past, I have heard of an unwritten rumor going around that supposedly said a flight instructor who only held a Flight Instructor Certificate-Instrument Airplane and Commercial Pilot Certificate with an ASEL rating and Instrument-Airplane rating could provide instrument training to an applicant in a multiengine airplane. THAT PRACTICE IS NOT PERMITTED ANY LONGER, if it was ever permitted in the first place!

As an example, a flight instructor, who only holds a CFII-A rating is giving instrument training to an Instrument-Airplane applicant in an single engine land airplane. That flight instructor must hold the following:

Flight Instructor Certificate Commercial Pilot Certificate or ATP
Instrument-Airplane Airplane Single Engine Land
Instrument-Airplane

Another example. A flight instructor, who only holds a CFII-A rating is giving instrument training to an Instrument-Airplane applicant in an multengine land airplane. That flight instructor must hold the following:

Flight Instructor Certificate Commercial Pilot Certificate or ATP
Instrument-Airplane Airplane Multiengine Land
Instrument-Airplane

However this example is a “NO-NO” and a violation of §61.195(c). A flight instructor, who only holds the following and wishes to give instrument training to an Instrument-Airplane applicant in an multengine land airplane shall not do so.

Flight Instructor Certificate Commercial Pilot Certificate or ATP
Instrument-Airplane Airplane Single Engine Land
Instrument-Airplane

As per §61.195(c), which states in pertinent part: “. . . 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.”

 

[Amish RakeFight]

.................

 

[UndauntedFlyer]

Who get's the CFI-IA only anyway?

For all the reason I have mentioned already many people get the CFI-IA first. One reason is that it is a much easier test than the CFI-ASE.

 

[Amish RakeFight]

For all the reason I have mentioned already many people get the CFI-IA first. One reason is that it is a much easier test than the CFI-ASE.

Right, but I meant who gets the CFI-IA only - as in not getting the CFI-ASE ever.

 

[UndauntedFlyer]

Right, but I meant who gets the CFI-IA only - as in not getting the CFI-ASE ever.

As I mentioned in Post #31, there are some who choose this for the reasons I've listed.

 

[nosehair]

it seems that the FAQ's on this subject do not agree with the interpetation that you have posted on this

The FAQ's are dead. And the FAQ on this subject seems to be referencing the old way the reg used to read. Yes, it was possible to be an Instrument - Airplane instructor, and teach airplane instruments in a (1) ASEL if that was on your comercial certificate, and a (2) AMEL if that was on your commercial certificate. But, as you see, that is not the wording of the regulation anymore. The category and class must be on your CFI certificate to instruct in any airplane.

See how hard it is for you to accept, even though it is pretty straight forward in the instructor limitations regulation.

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

And besides, there are no class ratings ever on a CFI certificate, Example: CFI-ASE is not a class,

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

 

[nosehair]

Right, but I meant who gets the CFI-IA only - as in not getting the CFI-ASE ever.

There used to be lots of people. Not the standard pivate-to-commercial-to-cfi in single-engine airplanes, but military/airline/corporate pilots would get their double eye only, when it was legal, because they were only going to instruct multi-engine instruments anyway. Type ratings and all that.

 

[Daytonaflyer]

Nosehair,
I have to agree with UndauntedFlyer. The reason is that an instrument instructor is not providing instruction in flight maneuvers; he is providing instruction in instrument procedures. The student is already certified in flight maneuvers.

These clips were taken directly from the FAA's website on the FAR's.

Here is the section of the FAR's that was current from 1978 to 2004.
(b) Aircraft ratings. 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 the applicable category and class rating; and
(2) If appropriate, a type rating.
(c) Instrument Rating. A 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.
http://www1.airweb.faa.gov/Regulato...D0B3873B38226C0386256959004C26C3?OpenDocument

Here is the exact same section of the FAR's that is current from 2004 to Present.
As you can see, there were no changes to this particular section of the regulations. I don't know which changes you keep referring to, Nosehair.

(b) Aircraft ratings. 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 the applicable category and class rating; and
(2) If appropriate, a type rating.
(c) Instrument Rating. A 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.
http://www.airweb.faa.gov/Regulator...73198B2CFC80168786256EE100640CCF?OpenDocument

Nosehair, you are correct, an instrument instructor may not provide flight training in an airplane, however, he may provide instrument flight training in an airplane as long as both he and the student are rated in the airplane on their pilot certificates.

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.

 

[flyinghunter]

I don't pretend to be all knowing, but back to the original question, I did my ratings at ATP and granted it was start to fiinish in 11 days I dind't apply/try to do any flight instructing after my first rating. But I did my CFI-ME, CFI-IA, CFI-SE in that order.

 

[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.