Instrument Dual in a Multi

[Iceman21]

Have you not read this thread?

(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

Yes I have read the thread. I am reasearching this more. The reason I say it can be done is because I have done it, with the knowledge of the issuing DE and the FSDO. I taught instruments only for 6 months before I got my CFI-A.

The FSDO knew about it and never batted an eyelash.

 

[Ralgha]

As has been stated before in other threads, the only opinion that matters is that of the FAA legal counsel. The regs state that you can't, so unless the chief or regional counsel has ruled otherwise, what the FSDO or local DE says doesn't mean squat.

 

[huncowboy]

Is there a collection of these FAA legal counsel interpretations published anywhere? It would make for a handy book for sure.



Just by casually reading 61.195(c) I would have interpreted the sentence incorrectly:



"...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."



It could be read like:

1. you must have a CFI with instrument rating

and

2. you must have a pilot license with appropriate category and class.



It is not necessarily clear for everyone that it has to be both, the CFI, and the pilot license with a proper category and class. The only thing that made me think (and only afterward) was the lack of the ",". Since not everyone is a lawyer and not every CFI is good in interpreting legal text I can see how this can get someone in trouble.



Why couldn't they list it like this:



...must hold:

1. instrument rating on his or her flight instructor certificate; and

2. flight instructor certificate that is appropriate to the category and class of aircraft in which instrument training is being provided; and

2. pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided.

 

[huncowboy]

anyone knows why I am getting these double spaces? I can't get rid of them and they don't show up in the preview...

 

[Iceman21]

Well I have researched all I want to research tonight.

I disagree with most of you all on here. You can give instrument instruction in an airplane if you have a CFI-I and no CFI-A. You have been given a cerfiticate that allows you to teach in an airplane category. Look at your certificate, it will state

Certified Flight Instructor - Instrument Airplane

Not:

Certified Flight Instructor - Instrument

You also flew the airplane on the checkride showing that you were capable of teaching in an airplane. If the FAA will not allow to teach in an airplane without a CFI-A then why would you take the checkride in a sim.


Reference the Part 61 FAQs, what is discussed here is a CFI-I (instrument only) giving instrument instruction give an engine failure and Vmc demo. Have a look for yourself.

QUESTION: What are the privileges held by a CFI - Instrument Airplane “only” (no single or multiengine rating) on his CFI with respect to instructing instrument procedures in a multi-engine airplane. He has multi-engine rating on his commercial certificate. Can he, while instructing instruments, simulate engine failure? Can he demonstrate VMC? Can he simulate engine failure during takeoff prior to 50% of VMC? Etc.



ANSWER: Ref. § 61.193(f) and § 61.195(f); Per § 61.193(f), a person who only holds a Flight Instructor-Instrument Airplane (CFII) rating is authorized within the limitations of that person's flight instructor certificate and ratings to give training and endorsements that are required for, and relate to an Instrument‑Airplane rating. And per § 61.195(f), in pertinent part, states a flight instructor may not give training required for the issuance of a certificate or rating in a multiengine airplane unless that flight instructor has at least 5 flight hours of pilot-in-command time in the specific make and model of multiengine airplane. These sections 61.193(f) and 61.195(f) are the only regulatory requirements that even remotely addresses your question.



Since training on the Vmc maneuver and procedure is not a task associated with the Instrument-Airplane rating, a person who only holds a Flight Instructor-Instrument Airplane (CFII) rating may not give the training required for that maneuver and procedure.



Since the training on the simulating engine failure during takeoff prior to 50% of Vmc is not a task associated with the Instrument-Airplane rating, a person who only holds a Flight Instructor-Instrument Airplane (CFII) rating may not give the training required for that maneuver and procedure.



However, there is no regulatory requirement in Part 61, other than § 61.193(f) and § 61.195(f) that apply. There is nothing that legally prohibits a person who only holds a Flight Instructor-Instrument Airplane (CFII) rating and has at least 5 flight hours of pilot-in-command time in the specific make and model of multiengine airplane per § 61.195(f) from giving the training required for the maneuver and procedure on “One engine inoperative during straight-and-level flight and turns (multiengine)” because the maneuver and procedure on “One engine inoperative during straight-and-level flight and turns (multiengine)” is a task associated with the Instrument‑Airplane rating.



Likewise, there is no regulatory requirement in Part 61, other than § 61.193(f) and § 61.195(f), that legally prohibits a person who only holds a Flight Instructor-Instrument Airplane (CFII) rating from giving the training required for the maneuver and procedure on “One engine inoperative—instrument approach (multiengine)” because the maneuver and procedure on “One engine inoperative—instrument approach (multiengine)” is a task associated with the Instrument‑Airplane rating.



Unfortunately, Part 61 and every other rule does not regulate judgment! I can't imagine an owner of an aircraft or an insurance company ever allowing rental of their multiengine airplane to a person who does not hold an airplane multiengine rating on his/her flight instructor certificate when that person intends to give training on engine inoperative maneuvers.

If I ultimately have to call John Lynch and discuss this with him to shut you all up about it then I will, he's a very nice guy.

 

[midlifeflyer]

Reference the Part 61 FAQs, what is discussed here is a CFI-I (instrument only) giving instrument instruction give an engine failure and Vmc demo. Have a look for yourself.

If you go upstream on the thread, you'll see that this is the one that Lynch now says he was probably wrong about.

But the FAQ is probably one of the reasons so many think it =is= proper.

You can get all of the published Legal Counsel opinions in Federal Aviation Decisions: Chief Counsel Interpretations Civil Penalty Decisions from West Publishing Company. I think it's $575. You might be able to find it in a law library, but not that many carry it. Many of the opinions, but not all are also available on the Aviation CD ROM put together by Summit Aviation

 

[TEXAN AVIATOR]

I've always heard you can, but I wouldn't. Not with a simple over the phone interpretation of the regulations by the FAA, it must be in writing. Without that, I'd never do it. I’m no lawyer, but the regulations look like you can’t do so from my interpretation.

TA

 

[ThunderRun]

I've lost track after 37 posts. What's the final verdict--can you or not?

 

[TEXAN AVIATOR]

I've lost track after 37 posts. What's the final verdict--can you or not?

Yes you can eat BBQ while instructing in a twin for instrument privileges without the MEI; but the regulations don’t show this in writing as far as I know. Just some answers I got off an anonymous aviation message board. That is my answer to the FAA inspector.

 

[midlifeflyer]

I've lost track after 37 posts. What's the final verdict--can you or not?

The "official" interpretation is in transition.

The Part 61 FAQ currently says "yes."

The FAA Eastern Regional Counsel's office says "No"

John Lynch who writes the FAQ said that based on the Eastern Regional Counsel's office opinion, he now thinks the FAQ is wrong and that the answer is "no," but plans on speaking with the Legal office about it.

So far, the FAQ has not been changed.

Clear as mud.