Flight Instructor Airplane Limitations in a Sim/Training Device

[JediNein]

Unlike apparently most of the respondents on the thread though I can accept and give the answer I don't know and leave it at that. I had hoped somebody knew something I didn't and could point me the correct way.

For the sake of your certificate(s) and from some of the incorrect information given in this thread, I'd suggest writing a letter requesting an interpretation of "authorized instructor" for instrument training, instrument knowledge endorsement, and IPC endorsements, and getting the FAA's response back before attempting to do any of those three with a CFI-Airplane certificate.

The letter from FAA National Legal Counsel will stand up in the courts that count.

 

[avbug]

Given December 18 of this year (2008), as an FAA Chief Legal Counsel interpretation:

[FONT=&quot]Mr. Michael Griffith[/FONT]
[FONT=&quot]1434 Windridge Dr.[/FONT]
[FONT=&quot]EI Cajon, CA 92020[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Dear Mr. Griffith,[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]This responds to your letter dated August 14, 2008, requesting an interpretation of Title 14,[/FONT]
[FONT=&quot]Code of Federal Regulations, as it pertains to logbook endorsements for meeting recent[/FONT]
[FONT=&quot]flight experience requirements under § 61.57 when a pilot fulfills such requirements by[/FONT]
[FONT=&quot]using an approved flight training device (FTD). You specifically ask what logbook endorsements can be given when an approved FTD is used, and who may endorse a pilot's logbook for passing the instrument proficiency check if the training takes place in an approved FTD.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Set forth below are pertinent parts of the regulations:[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]§ 61.57(c) Instrument experience. Except as provided in paragraph (e) of this section, no person may act as pilot in command ... unless within the preceding 6 calendar months, that person has: (l) ... performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or a flight training device that is representative of the aircraft category for the instrument privilege sought-[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]§ 61.57( d) Instrument Proficiency check. ...[/FONT]
[FONT=&quot](1) The instrument proficiency check must be-[/FONT]
[FONT=&quot](ii) For other than a glider, in a flight simulator or a flight training device that is representative of the aircraft category; ...[/FONT]
[FONT=&quot](2) The instrument proficiency check must be given by:[/FONT]
[FONT=&quot](i) An examiner;[/FONT]
[FONT=&quot](ii) A person authorized by the U.S. Armed Forces to conduct instrument[/FONT]
[FONT=&quot]flight tests, provided the person being tested is a member of the U.S.[/FONT]
[FONT=&quot]Armed Forces;[/FONT]
[FONT=&quot](iii) A company check pilot who is authorized to conduct instrument flight[/FONT]
[FONT=&quot]tests under part 121, 125, or 135 of this chapter or subpart K of part 91 of[/FONT]
[FONT=&quot]this chapter ... ;[/FONT]
[FONT=&quot](iv) An authorized instructor; or[/FONT]
[FONT=&quot](v) A person approved by the Administrator to conduct instrument practical tests.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]To answer your first question about what logbook endorsements can be given when an[/FONT]
[FONT=&quot]approved FTD is used, both §§ 61.57(c)(1) and 61.57(d)(1)(ii) explicitly state that approved FTDs may be used to meet the recent flight experience requirements, as long as a given FTD is approved for such training and proficiency check. Generally, all appropriate endorsements for passing the instrument proficiency check, which would be otherwise given if the check were passed in an aircraft, can also be given when one passes the check by using an FTD, as long as the FTD represents the appropriate aircraft category for the instrument privileges[/FONT]
[FONT=&quot]sought. You can find more information about approved training devices in the FAA's[/FONT]
[FONT=&quot]Advisory Circular 61-136, published on 07/14/08.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]With regards to your second question of who can endorse a pilot's logbook for passing a[/FONT]
[FONT=&quot]proficiency check, § 61.57(d)(2)(iv) requires the endorsement from an "authorized instructor", Although the category of "authorized instructor" identified in § 61.57(d)(2) includes various instructors, such as a part 142 training center instructor, an Instrument Ground Instructor (IGI) is not an "authorized instructor" who can endorse for the instrument proficiency check required by § 61.57( d). The flight proficiency check contains a flight[/FONT]
[FONT=&quot]portion and hence requires an authorized flight instructor.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Moreover, § 61. 193(a) states that a CFI is authorized to give appropriate endorsements that "relate to" an instrument rating only "within the limitations of that person's flight instructor certificate". Therefore, only a certified instrument flight instructor (CFII), who holds an instrument rating on his or her flight instructor certificate, which is appropriate to the category and class of the aircraft for which the instrument proficiency check is being conducted in, is authorized to endorse for passing that instrument proficiency check.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]This response was prepared by Adrianne Wojcik, an Attorney in the Regulations Division of the Office of the Chief Counsel, and has been coordinated with the Office of Flight[/FONT]
[FONT=&quot]Standards. If you have additional questions regarding the matter, please contact us at your[/FONT]
[FONT=&quot]convenience at (202)267-7776.[/FONT]
[FONT=&quot]Sincerely,[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Rebecca B. MacPherson[/FONT]
[FONT=&quot]Assistant Chief Counsel for Regulations, AGC-200[/FONT][FONT=&quot][/FONT]

 

[brokeflyer]

Relevance to question is?



No and if I did I wouldn't have asked the question. It is apparent that nobody knows the specific answer to the question. I am reasonably certain that you need a instrument rating on your instructor certificate to give instrument instruction even though the writing of part 61 does not indicate that (as it also does not support a instrument instructor only giving any instrument instruction in an airplane, that power is granted by by 8900.1).

Unlike apparently most of the respondents on the thread though I can accept and give the answer I don't know and leave it at that. I had hoped somebody knew something I didn't and could point me the correct way.

No you don't need to be a CFII to give instrument instruction. You need to be a CFII to endorse the logbook of someone to either: A) take the written or B) go do the practical test.

You are required to have instrument instruction for your private I think its like 3 hours. That isnt always from a CFII either.

Anything that is logged to be used for the hourly requirement must be logged by a CFII.

 

[AC560]

For the sake of your certificate(s) and from some of the incorrect information given in this thread

Nowhere have I stated I wanted to do this nor would I have a need to. As I clearly stated several times I am of the belief one needs a II and the only reason for the question is it came up in conversation with a student and another CFI back in by the Sim one day.

I was merely looking for well thought out answers supported by regulations.

Given December 18 of this year (2008), as an FAA Chief Legal Counsel interpretation:

Thanks Avbug, not a very well written response but it adds some insight. Interesting that they state essentially that sim time is now flight time and that ground instructor and 142 instructors can't give any flight training endorsements.

 

[AC560]

No you don't need to be a CFII to give instrument instruction. You need to be a CFII to endorse the logbook of someone to either: A) take the written or B) go do the practical test.

You are required to have instrument instruction for your private I think its like 3 hours. That isnt always from a CFII either.

Anything that is logged to be used for the hourly requirement must be logged by a CFII.

Again all things I know and believe myself, however they aren't things which can be documented to a student.

 

[Amish RakeFight]

Relevance to question is?

Why would someone want an IGI to perform their instruction in an sim when a CFII is more qualified. The relevance is in the quality of instruction. You seem to be looking for some affirmation that an IGI-only may give sim instruction.

 

[FlyinFife]

Apparently, at least some portions of the IPC require an Airplane

Interesting that they state essentially that sim time is now flight time and that ground instructor and 142 instructors can't give any flight training endorsements.

I saw that quote in Avbug's post as well and was confused. I started digging into the Regs and PTS to figure out why. I was always under the impression that an IPC could be entirely conducted in an FTD or SIM, and therefore would allow an IGI to endorse an IPC.

According to the PTS, only Level B, C, and D Simulators are allowed to credit all Instrument PTS tasks. All other FTD/Sim categories have at least one task that is required to be conducted during an IPC that cannot be done in an FTD/Sim.

That being said, the quote in Avbug's post referred to doing an IPC in an FTD. So, it appears that an IGI may conduct an IPC in an FTD for those tasks that can be credited in the FTD, but the IGI cannot endorse the IPC because the remaining tasks must be conducted in an airplane by an appropriately rated flight instructor (i.e. CFI-I).

 

[avbug]

Thanks Avbug, not a very well written response but it adds some insight. Interesting that they state essentially that sim time is now flight time and that ground instructor and 142 instructors can't give any flight training endorsements.

I'll try to supply more detailed information and address this topic, but presently I'm extremely busy and have only limited time.

 

[AC560]

According to the PTS, only Level B, C, and D Simulators are allowed to credit all Instrument PTS tasks. All other FTD/Sim categories have at least one task that is required to be conducted during an IPC that cannot be done in an FTD/Sim.

The local FSDO though can issue a waiver on the circle to land portion of the IPC. I don't have one handy but I have seen them so you can do the entire procedure in the sim (again not suggesting that is a good thing just saying it is a possible thing). I would guess this becomes one of those opinions like the one on what is known icing that gets reworded or recanted as it appears to have several errors (but is still binding nonetheless).

I'll try to supply more detailed information and address this topic, but presently I'm extremely busy and have only limited time.

No problem appreciate the information you provided, only positive contribution on the whole thread.