CFII training an IFR student in a Multi without MEI..

[JediNein]

Actually the regs are quite clear ...

That's what the Inspector thought, too. No, the regs are not quite clear. That's why there is a part 61 FAQ Document that's bigger than part 61. The part 61 FAQ is #7 on the list of FAA Regulations and Policies above Advisory Circulars and well below Public Law. Inspectors are supposed to know this. Instructors need to get familiar with it, too. Further, a FAQ exists for part 141.

One has to be really durn careful to not take away privileges of the Instrument Instructor nor add privileges to the Multiengine Instructor. An CFI-Multi can not conduct "instrument instruction" without the "Instrument Airplane" category rating. There was a proposed change in the regulation in 1997 that added multiengine instrument and single engine instrument ratings to the instructor certificate. It didn't happen.


An "Instrument Airplane" (only) Instructor can conduct training and endorsements for all of the tasks in the IFR PTS including IPCs to a non-certified pilot in any airplane category aircraft for which the instructor holds the appropriate pilot certificate. The instructor must have five hours of PIC time in make and model in the case of a multiengine airplane.


If you do get a call about your following policy, force the inspector to put the exact charges in writing, an LOI. If you correct the Inspector, there will be another charge, and the Inspector will not stop digging until he/she finds something that will stick. I wasted two months going 12 rounds with the fellow instead of forcing an LOI and taking it to Legal.


All of us are only one ticked Inspector away from being a ground-pounder.

Fly SAFE!
Jedi Nein

 

[Ralgha]

§ 61.195 Flight instructor limitations and qualifications.

(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.

(b) says "A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:". Pretty cut and dry to me.

(c) says "an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft". Pretty clear that you need the instrument rating that is appropriate to category and class on both certificates.

Before someone pulls out the argument that (b) is only referring to training for a rating, it's not. (b) is referring to aircraft ratings required to give instruction. (c) has specific verbage limiting its applicability to instruction for instrument ratings, (b) has no such verbage.

Typically the next argument is that the instrument rating on the CFI certificate is not category/class specific.

Here's an excerpt from a pilot certificate:

COMMERCIAL PILOT
AIRPLANE SINGLE & MULTIENGINE LAND; INSTRUMENT AIRPLANE

Here's one from a CFI certificate:

FLIGHT INSTRUCTOR
AIRPLANE SINGLE AND MULTIENGINE; INSTRUMENT AIRPLANE

The only difference between the two is that the CFI is not restricted to land. So, since the instrument rating is not specific to a category/class, if a CFI with single-engine and instrument ratings can give instrument instruction in a twin, it follows that if I hold a pilot certificate with single-engine and instrument ratings, I could fly a twin as long as I never looked out the windows.

 

[JediNein]

One more and I'm done.

I don't make the rules, I follow them. I comment on them when they become proposed rules. But, it's not my hand that publishes them in the Federal Register.

The current tide at the FAA sez what I put in my first post. That document has changed multiple times as the FAA's policy has changed.

Follow or not at your own peril.

Fly SAFE!
Jedi Nein

 

[nosehair]

If the instructor does not have "any kind of certificate", how is that person an instructor and not just a noisy passenger? You can't log instruction time for either the student or the instructor unless the instructor is instructor rated in category and class, right? After that, the only qualifier is if it is for "a certificate or rating", in which case you would need the 5 hour make and model for a multi-engine. Am I missing something?

No, Red, you're not "missing somthing". As I stated in my "off-the-wall" post, there would be no logging of time in this case. The example was someone who was only teaching the use of these new-fangled electronic displays, or some such training that was not required for a certificate ot rating or other, such as a flight review, or anything that has to be logged. Just training for furthur education and experience. Then it doesn't matter what you certificates say, the instructee is PIC, and yeah, you're just a noisy passenger.