Multi Instrument

[white knuckle]

Do you have to be a MEI to provide instrument instruction in a twin? Thank you.

 

[Kream926]

you have to be an mei to provide intsruction in a twin

 

[frascaflyer]

I beg to differ. I'm looking over FAA regulations and publications right now (to see just what a CFII who holds *only* a CFII can do) and FAA publication 8700 (http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_011_00.pdf) says this in chapter 11 (page 11-4):

"15. (A) Single and/or Multiengine Ratings.

According to FAR Part 61, flight instructors who hold an "instrument-airplane" rating only on their flight instructor certificate are authorized to give instrument flight instruction in single and/or multiengine airplanes for instrument certification, provided they hold single and/or multiengine ratings on their pilot certificate."

And it also says:

"15. (C) Ratings Limited to Instrument.

Instructors with ratings limited to instrument may not give instrument flight instruction to students who do not hold category and class ratings in the aircraft used, since this would be instruction for the addition of a rating that conveys other than instrument privileges. These instructors may not certify logbooks or recomment applicants for any aircraft category or class rating."

The way I read these is that you can provide instrument instruction in *any* aircraft for which you hold category/class/type as long as the student *also* holds category/class/type. So you couldn't give instrument multi to someone who holds only ASEL, but you could give instrument multi to someone who is adding an instrument rating to their multi private/commercial certificate.

Most (if not all) people get their instrument rating in a single *after* getting their private single, so someone with only a CFII could instruct that person for their instrument rating.

Thoughts?
FF

 

[Fly_Chick]

I would tend to agree with Frascaflyer. What you would not be "qualified" to do is give instrument instruction while teaching or simulating multi-engine procedures (ie simulated engine failure on the approach).

 

[Fly_Chick]

Check out these other posts:

http://forums.flightinfo.com/showthread.php?t=52447&highlight=multi+engine+instruction

http://forums.flightinfo.com/showthread.php?t=51640

 

[frascaflyer]

Good threads there. But I still maintain that you can give instrument instruction in a multi-engine airplane holding only a CFII and a Commercial Multi/Instrument *provided* the student has a private or commercial multi. Instrument instruction includes all and only the tasks set forth in the PTS for an instrument rating - and that includes single engine approaches. Is it smart to instruct in a multi with an engine shut down if you don't have an MEI? Probably not. Will an insurance company let you? Almost definitely not. But is it *legal*? I would have to say yes.

In those other threads there are two FAQs where John Lynch offers a concurring opinion, and one legal interpretation that seems to suggest that you need category and class ratings in order to give any flight instruction at all. If you look at the dates, the legal interpretation was issued in January 2004, and the FAQ answer (in response to Jedi Nein's challenge) is dated the end of 2004. Per Doc's FAR forum, and taking Jedi Nein at her word (http://www.propilot.com/doc/bbs/msgs//11190.html ), the legal interpretation is being changed to conform to John Lynch's FAQ ruling.

While I don't forsee a situation where I would give multi instrument instruction without an MEI, I believe that the FAA interpretations make it *legal*. And I definitely believe that I could train an applicant for a single-engine instrument rating (after their private) holding only a CFII. Think of it this way: if the student holds category and class ratings, either single or multi, presumably they are familiar and competant in all the areas of operation required for the practical tests in those areas. With instrument instruction, the new knowledge that you are imparting relates solely to things that they would not know - hence you can pull an engine in instrument training because they *know* how to deal with an engine failure, but not necessarily how to fly an approach with one inoperative. You're not teaching them how to deal with an engine failure; you are merely teaching them how to fly *instruments* with one shut down.

Thoughts?
FF

 

[nosehair]

FF, I have, for many,many years, thought of the II in twins the same as you.

However, 61.195(b) says:"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 ratings."

How do you get around that?

 

[BushwickBill]

You spend money at ATP to get your MEI

 

[frascaflyer]

nosehair:

I don't know how to get around that. All I can go by is FAA legal interpretations and the FAA FAQ that deal with that particular FAR. Jedi Nein says that the inspector changed his mind and agreed with John Lynch, and the Eastern Region is bringing their interpretation in line with the FAQ. I agree, the regulation seems clear, but it appears that the FAA's interpretation is different. I'm inclined to think that their interpretation will stand, for reasons stated above - the things you teach in instrument flying have already been tested for the CFII. You aren't providing *instruction* in any of the elements that lead to an ASEL or AMEL rating.

But like Bushwick Bill said, it's all moot if you just get the CFI and MEI. That's the best course.

FF

 

[white knuckle]

I read the other posts and see this does come up quite frequently. I should have dug a little deeper. Thank you for your replys.

 

[nosehair]

So, what's it gonna be, Whitesnake...I mean Whiteknuckle, ya gonna do it?

 

[white knuckle]

I will help my friend out in his twin while he is knocking the rust off, while I get the few ME PIC hours I need for the MEI. I will then get the MEI and we won't have to worry about any of this and I will then start putting dual received in his logbook. Thanks for all the replies. This board is a really good resource for questions except for the few A^*&*& I see raise their head in some posts. Thanks for all the good info.

 

[Kream926]

would it not be a good idea to be at least a CFII MER (just a MER) to give instruction in it. just seems right to me. what y'all think?

 

[DC8 Flyer]

For those that say you can do it without a MEI. I gotta ask. How do you conduct training in a twin without teaching multi engine procedures? Do you just fly around on one engine?

The regs make it perfectly clear. An instructor must have BOTH a category and class rating on BOTH his/her commercial/atp and CFI tickets. No way around it.
http://www.propilot.com/doc/bbs/msgs//11190.html

The above is bogus. The questions were simple, can I give "instruction" to someone who already has a Multi Instrument ticket, if I only have a CFII and a ASMEL Comm ticket. Well of course you can, you're not providing instruction for furtherance of a rating etc etc, all your doing is sitting there being a "safety" pilot.

Right from the regs:

61.195 Flight instructor limitations and qualifications.
A person who holds a flight instructor certificate is subject to the following limitations:

(a) Hours of training. In any 24-consecutive-hour period, a flight instructor may not conduct more than 8 hours of flight training.

(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.

 

[BYUFlyr]

(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.

This clears all doubts: All he needs is an instrument rating (CFII) and a pilot certificate (not neceseraly an instructor certificate) that is appropriate to the category and class of aircraft.

Maybe the punctuation is a little ambigious, but there is no doubt that it's how the FAA interprets it.

 

[nosehair]

This clears all doubts: All he needs is an instrument rating (CFII) and a pilot certificate (not neceseraly an instructor certificate) that is appropriate to the category and class of aircraft.

Maybe the punctuation is a little ambigious, but there is no doubt that it's how the FAA interprets it.

!!!...Incredible!! In your quote of this regulation, you insert in parenthasis, "not neceseraly an instructor certificate", where the actual words are, " and flight instructor certificate".

You must be a news reporter.

 

[BYUFlyr]

You must be a news reporter.

What are you like 8 or something? Do we tolerate name calling in this playground?

Anyways....

The grammatical structure of the regulation leaves room for ambiguity in its interpretation. Therefore, there must be one interpretation that trumps all others. In this case it is safe to say that the FAA trumps every other CFI's interpretation of the regulation.

However, I'll go ahead and elaborate on why I agree with the FAA's interpretation.

The regulation applicable to the original question would be 61.195 (c) [not (b)], which reads as follows: "(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."

Consider the grammatical usage of the second bolded phrase: "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"

If the sub phrase, "... that is appropriate to the category and class of aircraft..." also applied to the flight instructor certificate it would have to read, "... that are appropriate to the category and class of aircraft...."

Even if you do not agree with grammatical usage of "is" and "are", as it applies to the above regulation, it is how it is written and it is how the FAA interprets it. If a chief flight instructor interprets it differently then a CFII can not teach in a multi-engine aircraft at his school, but if I am an independent CFII I am only accountable to the FAA and other interpretations are, therefore, irrelevant.

 

[BYUFlyr]

FF, I have, for many,many years, thought of the II in twins the same as you.

However, 61.195(b) says:"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 ratings."

How do you get around that?

61.195(b) applies to flight training in pursuit of aircraft ratings not instrument ratings.

 

[DC8 Flyer]

61.195(b) applies to aircraft ratings not instrument ratings.

BYU I see what your saying and you raise a good point. However I dont think you can only read one part of that reg alone. 61.195(b) tells us what we must have to provide "instruction" ie AMEL Comm and an MEI to teach in multis, where subsection (c) tells us we must have an instrument rating on both commercial and instructor tickets (duh you have to have an instrument rating anyway to be an instructor) to teach instruments. Since the language on the tickets is "instrument airplane" the category and class is moot, unless you have a multi restriction thats is VFR only??

I see your argument but I dont think you can pull subsection (b) away from subsection (c) and voila you can give instrument instruction in a twin without haveing an MEI.

Going out on a limb here, if the FAA truly had the intent of allowing instructors to provide instrument instruction in multis to people who already possesed a VFR multi ticket I think the reg wouldnt have been written more clearly. IE, subsection (c) would read something along the lines...
---------------------------------------------------------------------------
"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.
(i) A flight instructor providing instruction for the addition of an instrument rating to an existing Multi Engine Airplane License need not posses a Multi Engine Instructor Certificate"
----------------------------------------------------------------------------------------

But again, I could be totally wrong, it has been years since I have instructed and dont even have my CFI,CFII and MEI anymore. Just tyring to point out how I see the regs as being read.

 

[BYUFlyr]

BYU I see what your saying and you raise a good point. However I dont think you can only read one part of that reg alone. 61.195(b) tells us what we must have to provide "instruction" ie AMEL Comm and an MEI to teach in multis, where subsection (c) tells us we must have an instrument rating on both commercial and instructor tickets (duh you have to have an instrument rating anyway to be an instructor) to teach instruments. Since the language on the tickets is "instrument airplane" the category and class is moot, unless you have a multi restriction thats is VFR only??

I see your argument but I dont think you can pull subsection (b) away from subsection (c) and voila you can give instrument instruction in a twin without haveing an MEI.

I see your point, but I believe the italic wording, Aircraft ratings and Instrument Rating (notice the capitalization on the latter) in (b) and (c) respectively, applies to the type of training being conducted as opposed to a categorical break down of the instructor's qualifications. Paragraph (b) does not even mention instrument flight training, only flight training. Paragraph (c), however, speaks of instrument flight training exclusively. There is a difference between instrument flight training and flight training. Your example in which the AMEL pilot has a VFR limitation (either because he/she does not posses an Instrument Rating or he/she opted to exclude the instrument maneuvers during the checkride) and wishes to remove it falls into instrument flight training. An ASEL pilot pursuing an AMEL ticket, with or without instrument privileges, can not receive training from a CFII who does not hold an MEI because he/she is receiving flight training (which may include instrument training).

In summary: flight training (b) includes the training given in order for the recipient to act as PIC in that category/class; additionally, instrument flight training (c) does not include flight training and can therefore be conducted by an instructor certified to give instrument flight training who is not certified to give flight training in that category/class (as long as he/she and the student are appropriately rated).

e.g.: A CFII who does not hold a CFIA can not give instrument flight training to a student pilot in a Cessna 152, but he can give instrument flight training in the same airplane or even in a multi-engine seaplane to a private pilot as long as both student an instructor are appropriately rated for that aircraft.