Currency for CFI

[lawfly]

Some further comments: One could distinguish between CFI firend who is just sitting in right seat of his friend's new airplane and friend (or relative) is fully current, fully rated, and sole manipulator. And maybe they switch seats on next leg. Really just flying for flying's sake. But that goes more to whether CFI is "acting" as an authorized instructor rather than whether he is authorized by FAA for the operation in question. Here's another hypo: Same facts as original post, with clarification that the CFI is not a CFII. And the flight is a BFR. The instrument-rated private pilot is current for all of his privileges. All goes well, except it's a coastal airport and some localized low stratus has crept in. IFR approach back into airport. Actual IMC during descent. You can modify the hypo some more if you want, but idea is there's actual on the return. Can the CFI who is not a CFII but who is conducting BFR log the actual instrument time as his own actual instrument PIC? My thinking is in general the CFI needs to be a CFII to log actual instrument PIC while acting as authorized flight instructor. But this CFI is authorized to conduct a BFR of this private pilot. With focus on whether this CFI can log the actual instrument PIC, your thoughts?

 

[midlifeflyer]

Ah. The old, "Can a CFI-One-I teach instruments".

I've never seen an official interpretation that a CFI must have the second "I" in order to give instruction in IMC and to log PIC if he does. As far as I've been able to tell from looking at a bunch of rules and official opinions, a one-I can provide instruction in IMC and the student can log training received.

The only limitation is that instrument instruction by a one-I doesn't count toward the "instrument training" requirements of any certificate or rating. (The 3 hours for the PPL isn't "instrument training", it's "instruction in flight solely by reference to instruments". Sounds similar but is treated differently)

If this was a problem, the FAA has had plenty of chances to correct it. There are more than a few flight schools in which CFI-One-Is are used to provide backup instruction to the IIs, giving the student the benefit of a sort of "safety pilot plus" and the CFI practical training toward the II.

The multi make and model experience you refer to

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A flight instructor may not give training required for the issuance of a certificate or rating in a multiengine airplane, a helicopter, or a powered-lift unless that flight instructor has at least 5 flight hours of pilot-in-command time in the specific make and model of multiengine airplane, helicopter, or powered-lift, as appropriate.
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is much more specific.

 

[lawfly]

cart's original question related to whether a "CFI" could log for currency purposes the approaches performed by the presumably current Pvt-Instrument in the left seat. No further info was given as to whether the CFI was "acting as an authorized instructor" as would be required for the logging of PIC time by the instructor, but I think we reasonably assumed he was aboard in some instructor capacity. The responses applied "PIC" definitions to determine if the "CFI" could log Private's actual IMC approaches for his own currency. Interestingly, although there may interpretive decisions/opinions on the subject(?), the IFR currency requirements set forth in 61.57(c)(1) do not speak of "PIC". Rather, in terms of 61.57(c)(1) currency, the requirement is that the pilot seeking to extablish his currency have "performed" the approaches "for the purpose of obtaining instrument experience in an airraft". 61.57(c)(1). Query: meaning of "performed" for purposes of IFR currency? And in relation to CFI logging thereof for IFR currency on the facts of cart's hypo and generally?
Also: I still find the use of the term "authorized instructor" worthy of note in its various contexts. For example, 61. 195(c) requires the instructor who provides flight training for the issuance of an instrument rating (not cart's hypo where Pvt. already rated) to be CFII, but 61.195(d)(6) does not expressly require the instructor giving an instrument proficiency check to be CFII and 61.57(d)(2)(iv) simply requires IPC endorser to be "an authorized instructor."
The multi make and model requirement 61.195(f) is, as midlifeflyer states, very specific. However, 61.63(c)(1) for multi rating simply requires "an authorized instructor". My point is that the term "authorized" has import. As for CFI single I's teaching in instrument course, I believe in 141-142 schools the courses in each instructor may teach are specified in the school records, etc. I guess the main question this time around is "performed" and "for the purpose of obtaining instrument experience" in 61.57 (c) (1) especially as to cart's hypo. And meaning of "authorized flight instructor" in different contexts.

 

[lawfly]

My final(?) comment: "An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions." 61.51(g)(2)

There's that word "authorized" again. What does it mean in this context? I suggested in an earlier post that it means CFII. However, it has been suggested in response that "authorized" in this context means ANY flight instructor. (We are not talking about the Private-Instrument's log, or whether he is pursuing rating, etc., only about the CFI's logging as to: 1.) PIC 2.) Instrument 3.)Approach/IFR currency)

Additionally, 61.57(c) (2) (IFR currency) requires that a pilot seeking to act as "pilot in command" under IFR have "performed" six approaches, holding procedures, etc. within the preceding 6 calendar months. What does "performed" mean here?

I suggest that these quoted FAR provisions are central to cart's original inquiry (see start of thread).

Does "authorized instructor" for an IPC, 61.57(d)(2)(iv), mean CFII, or does it mean any instructor? To the "any instructor" advocates: Does this all mean that a CFI "single I" can give an IPC in actual IMC and log all the approaches as his own for IFR currency? Is he an "authorized instructor" for IPC purposes? For PIC purposes? For instrument purposes? Did he "perform" the approaches, for currency purposes?

 

[lawfly]

61.193, 61.193(g) shed some light. Would seem to require CFII for IPC. I worked at a 141 place years ago where for a while I was the only available double ii, and I did exclusively instrument instruction. But cart got me looking at the regs. I believe my own practice was to log actual IMC approaches with instrument students for my own currency. But then, they didn't have instrument ratings. So, I was the only one on board who could legally fly IFR and I was a CFII. Usually when the regs want "sole manipulator" they'll say it. But still think the "performed" language is interesting, especially if sole manipulator is instrument rated and current and right seat not a double ii. If training for a type rating and fly in some actual (which I did last year) guess instructor can log everything as left seat driver isn't typed yet and therefore can't be PIC. Oh well...I'm done.

Fly Safe
I'm having a "thread" with myself!! Those who know me well would not be surprised...Hey midlife, I logged my first 2,000 hours while working for Connecticut operators at HVN, BDL, GON. Long tiome ago. Maybe we'll chat sometime. You can teach me how to really fly the mountains. We have some here in CA, too. Visited your website.

 

[lawfly]

As Columbo would say, "One more thing": Want to re-iterate that I don't think the logging of approaches for currency necessarily requires one to be a PIC, but does require one to "perform" the approach (whatever that means). For example, when I was a required SIC under scheduled 135, I flew every other leg as per company policy. However, I was not PIC because my 135 endorsement was for SIC. When weather was down, as it often was, it was not uncommon for each pilot to hand fly 3 actual approaches a day, not infrequently down to 200 and a half. Did I "perform" at least the approaches I flew? I sure thought so. Did I feel current to fly a general aviation airplane single pilot Part 91 in actual? Yes, although I don't think I did during that period. Maybe in a two pilot crew both pilots "perform" every approach. I don't know. We were both double ii's, but weren't acting as instructors. Acting as 2 pilot crew per 135 cert and ops specs. Where that leaves our CFI single i in the original hypothetical, I don't know, but I think he should go get his double ii!

 

[midlifeflyer]

I'm having a "thread" with myself!!

It's been fun watching.