Flight Instructor Airplane Limitations in a Sim/Training Device

[AC560]

This is a cross post to something I put on the AOPA forums as I am really stumped for an answer and hope that somebody can help me out.

Somebody asked me a question which is one of those where I just always assumed the answer until they made a good argument and we actually read the reg's.

61.195 (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.

Can a CFI without an instrument instructor rating give instrument instruction in sim? My thought would be no but in reading the regulations says maybe, can somebody point what I am missing. Appreciate any comments providing supporting text, not just personal opinions.

 

[ALIMBO]

I believe they can give instrument instruction just not towards their instrument rating. Much like the instrument time needed to get your private.

 

[7574EVER]

I'm going to go with yes they can and it can be for the instrument rating. If I remember correctly only fifteen hours of instruction in the aircraft are required to be from a double I. So, if a student is training for his/her IFR rating and logs dual from a basic CFI during some of the training they are still within legal standards provided they have the required dual from the double I. Fourty hours of IFR time is required for the rating....only fifteen from an "authorized instructor". They don't specify or seem to care where the other twenty-five hours comes from.

 

[nosehair]

61.195 (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.

Can a CFI without an instrument instructor rating give instrument instruction in sim? My thought would be no but in reading the regulations says maybe, can somebody point what I am missing.

OK, let's walk through those words..."A (CFI) who provides,...instrument flight training,....must hold....an instrument rating....on his (CFI)...

what are you missing?...yes, it is directed towards the issuance of the IR, but the sim time allowed for the IR, or currency must be with an "approprately rated", ie, "double-eye", CFI.

 

[AC560]

OK, let's walk through those words..."A (CFI) who provides,...instrument flight training,....must hold....an instrument rating....on his (CFI)...

There is one word which causes a problem flight training. You must hold an instrument instructor rating only to give flight training as that reads.

but the sim time allowed for the IR, or currency must be with an "approprately rated", ie, "double-eye", CFI.

And you could provide a reference for that you would answer my question. I am not disputing the statement merely saying on the basis of 61.195 it doesn't appear you need an instrument rating to give instrument training in a sim.

 

[Tired Soul]

Can't quote it right now but there's another reg as far as logging FTD or Sim time, it can only be logged by the student if accompanied by a appropriately rated Instructor.......no solo SIM time allowed.
Meaning if the student wishes to log the time it would need to be a CFII.
Don't have a FARAIM handy right now but look at the "sim" regs.

 

[JediNein]

You're missing the Practical Test Standards.

If a CFI-Airplane wants to give "instrument instruction" in an FTD/simulator, either get the Instrument Rating added to the CFI certificate, the IGI, or AGI. It's one computerized test, either AGI or IGI, that as an active instructor, you can probably pass today without extra studying.

The way a pissed-off Fed will try to pursue your certificates is if one of your students attracts the attention of the FAA in a negative fashion, the Feds will review the guy's logbook, check out the credentials of the CFI/CFIIs that taught the guy, and if they notice any potential wrong-doing, they're going to go for a two-for-one violation special that includes you. They will use the PTS for the Instrument Rating and compare it to the logbook entries you made. If there is a task listed in the comments that is in the IFR PTS and not the Private/Commercial/Recreational/Sport/or ATP PTS, you were obviously exceeding your privileges as a CFI-Airplane.

Yes, it was nice to stop this angle on a violation investigation in its tracks by holding the AGI, and having the IGI for the buzz kill should that inspector have decided the regulations as written were also not in accordance with his worldview.

 

[nosehair]

And you could provide a reference for that you would answer my question.

61.65(5) "Receive and log training, bla-bla-bla from an authorized instructor in an aircraft, flight simulator, or FTD..."

The term "authorized instructor" means an instructor who is authorized to provide instrument training, ie, has a double-eye; 61.193(f)

 

[AC560]

The term "authorized instructor" means an instructor who is authorized to provide instrument training, ie, has a double-eye; 61.193(f)

(2) Authorized instructor means—
(i) A person who holds a valid ground instructor certificate issued under part 61 or part 143 of this chapter when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate;
(ii) A person who holds a current flight instructor certificate issued under part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or
(iii) A person authorized by the Administrator to provide ground training or flight training under SFAR No. 58, or part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.


You review 61.193 and you see privileges. Under 61.195(a)-(c) you see limitations.

You're missing the Practical Test Standards.

Look I am not trying to be obtuse and this maybe one of things where the only solution is to write a letter to FAA Legal. Another CFI was discussing the point with me and my response was same as Nosehairs/yours, one needs AGI/IGI or II. We looked over the regulations and really can't find anything which bars a CFI from giving ground instruction, sim time, or signing off for the knowledge test.

 

[nosehair]

(2) Authorized instructor means—
(ii) A person who holds a current flight instructor certificate issued under part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate;
You review 61.193 and you see privileges. Under 61.195(a)-(c) you see limitations.

I'm quoting your own quotes, and you must be able to see from these regulations that a CFI must hold an instrument instructor rating to provide instrument instruction towards an IR. Is that what we're talking about?

 

[AC560]

I'm quoting your own quotes, and you must be able to see from these regulations that a CFI must hold an instrument instructor rating to provide instrument instruction towards an IR. Is that what we're talking about?

And in the rest of the post "You review 61.193 and you see privileges. Under 61.195(a)-(c) you see limitations."

The only limitation placed on a CFI is that in order to give instrument flight instruction they must hold a valid instrument instructor rating. Note again it is specific it says flight instruction. Short of this restriction all other privileges are granted.

Again I am not trying to debate what we all assume this should be. I am trying to look for a definitive answer in the FAR's, not speculation.

 

[nosehair]

OK, look again at 61.65(A)(5) "receive training from an authorized instructor.."

It says "training", not "flight training",...

"...in an aircraft, sim, or FTD..."

"..on the areas of operation in paragraph (C).."


Paragraph (C) outlines the "training", whether in an aircraft, sim, or FTD, with an "authorized instructor", so if the training is towards an IR, don't you think the aviation community, as a whole, would think that the authorized instructor towards an IR would be a CFI-I?

61.65(e) talks about the use of a sim or FTD to meet some of the time requirements, if the training is done with an "authorized instructor".

 

[PURPLEHAZE21]

I would seriously call Flight safety and ask how they train in there sims in nterms of this question. They, as you know, deal with these problems more often then you or I. Good luck and let us know if you get any good intel.

 

[brokeflyer]

I would seriously call Flight safety and ask how they train in there sims in nterms of this question. They, as you know, deal with these problems more often then you or I. Good luck and let us know if you get any good intel.

They can do it in the sim because the applicant is already certificated. Also, a flightsafety instructor needs to have authorization from the FAA to do ANY type of flightcheck. This authorization superceedd any flight instructor requirement. A FSI instructors limitation for this ability is they can ONLY do instruction at FSI in a sim.

They can't go into YOUR airplane and give instruction.

 

[PURPLEHAZE21]

O.K. thanks for the info. But was the question in relation to instrument instruction in an approved sim ? Not all aplicants that go to flight safety are certificated. I've been there many times to see the various types of applicants go through training. I guess the answer might be the level or automation of the sim....I don't know, but thanks.

 

[brokeflyer]

A cfi can do instrument instruction, but he/she CAN'T give an endorsment for the practical test. The simulator has nothing to do with it.

You can do 50 hours of "instrcution" from someone who has an expired cert. But you can't log it as dual and he/she can't endorse the logbook.

 

[AC560]

OK, look again at 61.65(A)(5) "receive training from an authorized instructor.." It says "training", not "flight training",... "...in an aircraft, sim, or FTD..." "..on the areas of operation in paragraph (C).." Paragraph (C) outlines the "training", whether in an aircraft, sim, or FTD, with an "authorized instructor",

61.1 defines authorized instructor. 61.193 lists the privledges of instructors. 61.195 (a)-(c) lists the limitations. It is clearly listed in black and white. As written there is no way other to read it except that a flight instructor can give instrument sim time, ground time, and can endorse for the instrument written. The only restriction placed upon the flight instructor is he/she cannot give "Flight Instruction.

61.65 (a)(5) lists several categories the first of which is an aircraft which clearly would be flight instruction. As such an instrument instructor rating would be required. Listed after aircraft though is flight simulator or flight training device, it is these forms of training which we are dicussing.

don't you think the aviation community, as a whole, would think that the authorized instructor towards an IR would be a CFI-I?

Again I have said over and over I fundamentally agree with the concept that only a II should be able to the same way I agree with only an IGI should be able to give instrument ground instruction. Everyone including the FAA is in agreement they botched and aside from ground instruction for IPC or endorsing for the knowledge test and AGI can do all functions of an IGI (including giving instrument sim/ground time).

This isn't a matter of what I think it is what I can document to a student.

A cfi can do instrument instruction, but he/she CAN'T give an endorsment for the practical test. The simulator has nothing to do with it. You can do 50 hours of "instrcution" from someone who has an expired cert. But you can't log it as dual and he/she can't endorse the logbook.

Supporting regulations?

 

[Amish RakeFight]

Why would anyone want sim instruction from a person with only an IGI or AGI? A CFII would most likely be much more knowledgeable all around.

 

[brokeflyer]

Supporting regulations?

You already put the reg up there......good job.

so do you understand now?

 

[AC560]

Why would anyone want sim instruction from a person with only an IGI or AGI? A CFII would most likely be much more knowledgeable all around.

Relevance to question is?

so do you understand now?

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.

 

[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.