CFII Before CFI ?

[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?

 

[UndauntedFlyer]

Proposed Changes to Part 61/141

http://www.nata.aero/about/Parts6191and141Revisions.jsp

 

[Amish RakeFight]

Proposed Changes to Part 61/141

http://www.nata.aero/about/Parts6191and141Revisions.jsp

Thanks.

I'm looking at some of the proposals. How likely are the various proposed changes to be implemented. I've never reviewed an NPRM before so I'm unfamiliar with the process. I see some items of interest but are curious to know how likely these proposals are.

 

[AC560]

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.

Yes but part of the issue is that you haven't put up anything to substantiate why this is the case. It is akin to I say it is so and thus you should believe me. A large part of instruction is when people come with a question particularly a regulation related one you provide not only the answer but the reference. I notice a general trend in your posts here that while well thought out and often correct lack any support in terms of where one could verify the information. Nobody is disputing that CFI-IA give instruction with no additional ratings what wasn't clear is the regulation or interpretation that allows for it.

Midelifeflyer's post gives the answer and the source, which is all anyone was looking for.

 

[UndauntedFlyer]

Yes but part of the issue is that you haven't put up anything to substantiate why this is the case. It is akin to I say it is so and thus you should believe me. A large part of instruction is when people come with a question particularly a regulation related one you provide not only the answer but the reference. I notice a general trend in your posts here that while well thought out and often correct lack any support in terms of where one could verify the information. Nobody is disputing that CFI-IA give instruction with no additional ratings what wasn't clear is the regulation or interpretation that allows for it.

Midelifeflyer's post gives the answer and the source, which is all anyone was looking for.

AC560: I am in complete agreement with your concept for teaching, and I use that myself when I tell new instructors to teach by fact rather than rumor. Anyone can say I heard this, I know an examiner that says that, or my instructor told me so and so. That easy.

Well you are right in your ideas on this completely, and when I say I have seen much evidence on this I guess I am also guilty of teaching by rumor to a degree; however some of the questions on this board require more research than I have time to do. So when I have said I saw evidence I may have been referring to the solid evidence that was presented here on FI by our most competent FI members, many of whom do a great job of digging these answers up, you included AC560.

So on this issue I think we have covered it to my satisfaction. We are all correct on this and it's just a case of much ado over not much. It works OK as is. Just live with it. We often have to do this with many rules where the FAA just avoids enforcement. As an example, Midway Airport (MDW) is 100% surrounded by buildings and is therefore a congested area. So if that is true then how can any pilot takeoff VFR with only a 1000 foot ceiling and stay 500 feet beneath the clouds and at the same time 1000 feet above the highest obstacle. Clearly it can not be done yet the FAA never goes after those that takeoff on such days when the ceiling is 1000 or even less with a SVFR.

So you see you are very right on this discussion about whether a person needs an airplane rating on his/her CFI certificate to teach as a CFI-IA, and so is Nosehair as well as Midlifecrisis and me too. We are all right and it seems the FAA doesn't want to really give a darn on this. It's just not worth it until somebody has a serious accident such as giving Instrument Airplane instruction in a twin doing single engine ILS's with a one-engine go around.

Remember the rotating beacon came after the midair, not before. For the most part, our society is reactive, not proactive. And if you try to be proactive there are those that will say this is not necessary. So you can not win, and on this issue I'm personally pleased to see so much interest and understanding by so many on this point, but it's just not worth worrying about since clearly the FAA isn’t making this an issue anywhere.

 

[midlifeflyer]

Thanks.

I'm looking at some of the proposals. How likely are the various proposed changes to be implemented. I've never reviewed an NPRM before so I'm unfamiliar with the process. I see some items of interest but are curious to know how likely these proposals are.

It's hard to tell. The general process for federal agencies (this isn't just an FAA thing) is Proposed Rule - comment period - Final Rule. You can start with the assumption that the FAA did some research into this before publishing the NPRM and has a general bias in favor of the proposals (although a "flagpole" proposal is not unheard of). Nevertheless comments, especially from recognized organizations (AOPA, GAMA, etc) tend to be taken seriously and you can expect some modification of proposals that generate a lot of negative comment. That may not mean complete withdrawal of a proposal (although that does happen) but just tweaking of the language to make it clearer or less onerous.

 

[AC560]

Words

One of the few productive threads on these forums. Every so often somethings comes up which we can all learn from which is why even after a lot of years I still find flying fun.

 

[DC8 Express]

Any recommendations on a flight school in Central Florida that can tailor make an initial CFI-I. I do not have a CFI nor do I want one however I have an ATP with over 10,000 hours and the instrument instructor written in hand. Not interested in 141 school. MEI-I is also a consideration if the price is right.

Would like to have a back up if things at present job go south.

Thanks