Multi Instrument

[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.

 

[DC8 Flyer]

You know, you make a very good point. The more I think about it, why couldnt someone give instrument training to someone who already has a multi instrument ticket? The only problem I see is how do you do the single engine approach training, if you are not a MEI??

Now if we are talking about giving dual to someone who already has a Multi Instrument ticket for the sake of equipement familiraztion (new GPS etc) then I see no problem since you are not training for category, class or instrument you are simply acting as a safety pilot.

Then again all my time giving training was in a 141 school where we trained for both the instrument, commercial and multi engine ratings at once so I am a little mis informed as to doing this in the part 61 world.

Keep it up man, your slowly turning me to the dark side

 

[DC8 Flyer]

AAAAAAH HAAAA! Almost got me to the darkside!

I think, again I think, the whole purpose of subsection (c) is to keep someone from having a Comm ASEL Instrument Airplane with a Multi Engine rating limited to VFR and also having CFI, CFII, MEI from providing instrument instruction in the twin. You could still give private and commercial instruction but not for instrument rating in a twin.

I believe you may be looking at subsection (c) the wrong way. It is not a loop whole to allow CFII(s) to provide instrument training in a twin without a MEI, but it is meant to close the loop hole of not having an instrument rating for the instructors multi engine rating. Likewise vice a versa, say for whatever reason you only have an AMEL Inst Comm and a Comm ASEL and CFI, CFII, MEI you could give instrument twin training but not instrument single engine training.

The problem is, most people go the normal route and get there ASEL Inst Commercial and CFI, CFII, then add the Comm MEL Instrument and MEI later so it really never comes up.

Good discussion though!

 

[BYUFlyr]

The only problem I see is how do you do the single engine approach training, if you are not a MEI??

I guess my response to that would be that as a CFII you're not teaching him how to fly the airplane with one engine out (the regs assume both you and the student already know how to fly on a single engine). All you're teaching is how to use the instruments to fly the same maneuvers you already know without having the benefit of visual references.

Think of the Cessna 152 example. How can a CFII (who does not hold a CFIA) give instrument flight training to a private pilot in a single-engine airplane? The instructor is not qualified to teach slow flight, steep turns, or even climbs and descents, but he can teach someone to fly by sole reference to instruments.

How's that? That's the best I can do....

 

[BYUFlyr]

I believe you may be looking at subsection (c) the wrong way. It is not a loop whole to allow CFII(s) to provide instrument training in a twin without a MEI, but it is meant to close the loop hole of not having an instrument rating for the instructors multi engine rating. Likewise vice a versa, say for whatever reason you only have an AMEL Inst Comm and a Comm ASEL and CFI, CFII, MEI you could give instrument twin training but not instrument single engine training.

It's not a loop hole. It's just not very clear.

Now, by your argument if I hold a Comm ASEL and a CFII (no CFI(ASEL) or MEI), then my CFII would be utterly useless. If this was the case, the FAA would impose the same restriction they impose in the Pvt-Ins scenario. You can not earn your Instrument Rating without having a current Private License. The reason they require a current Pvt is not because you don't know how to fly without one, because there are recreational pilots who fly better than even some brand new commercial pilots, but it is because you would not be able to exercise the privileges of an Instrument Rating without a current Pvt License.

If this was the same case with the CFII rating then the FAA would not allow a pilot to test for a license he/she would not be able to use. If I can not teach instruments in a multi-engine airplane without an MEI, then a CFII would not be able to give any instrument flight training without a CFI(ASEL) or MEI.

This we know to be false. A CFII can give instrument flight training without a CFI(ASEL) rating. By the same token a CFII can give flight training in a multi-engine airplane as long as both the instructor and the student are appropriately rated. Furthermore, a CFII who holds an MEI but does not hold a SEL pilot rating can not give instrument flight training in a Cessna 152.

What do you think? You over to the dark side yet?

 

[minitour]

It seems pretty simple to me.

61.195 B says...
You have to have the category and class ratings on your pilot certificate and your instructor certificate.

61.195 C says...
To give instrument rating instruction you have to have an instrument rating on your pilot license and instructor certificate appropriate to category and class.

Let's look at it this way.

1. 61.195 C doesn't say "61.195 B doesn't apply bla bla bla..."
2. You have to have the Commercial MEL and CFI-ME to give instruction in a Multiengine aircraft.
3. You have to have an instrument rating appropriate to category and class to instruct for instruments.
a. Commercial ASEL - IA & CFI - SE - IA
b. Commercial AMEL - IA & CFI - ME - IA

How the CFII only holders work, I have no idea. It says "instrument airplane" on the certificate...but what kind of airplane?

Other than that, it seems very, very simple to me...I agree with nosehair.

Easiest solution...get the MEI. From what I've heard, it's possibly one of the easiest checkrides (which is scarry). Fewest required task areas in the PTS if you've got the CFI/CFII already.

-mini

 

[DC8 Flyer]

It's not a loop hole. It's just not very clear.

Now, by your argument if I hold a Comm ASEL and a CFII (no CFI(ASEL) or MEI), then my CFII would be utterly useless.

Wouldnt be worthless because you could only give Instrument instruction, no private or commercial instruction. Because you have an instrument rating on both your Commercial ticket and your CFII ticket. I have no idea how that would be printed on your CFII ticket I have never seen one. I would think it would only say Instrument Airplane, but then that opens the can of works of not having both category and class on both your commercial and instructor ticket so maybe it would say "Single Engine; Instrument Airplane: Instrument Instructor Privelages Only"??

If this was the case, the FAA would impose the same restriction they impose in the Pvt-Ins scenario. You can not earn your Instrument Rating without having a current Private License. The reason they require a current Pvt is not because you don't know how to fly without one, because there are recreational pilots who fly better than even some brand new commercial pilots, but it is because you would not be able to exercise the privileges of an Instrument Rating without a current Pvt License.

If this was the same case with the CFII rating then the FAA would not allow a pilot to test for a license he/she would not be able to use. If I can not teach instruments in a multi-engine airplane without an MEI, then a CFII would not be able to give any instrument flight training without a CFI(ASEL) or MEI.

This we know to be false. A CFII can give instrument flight training without a CFI(ASEL) rating. By the same token a CFII can give flight training in a multi-engine airplane as long as both the instructor and the student are appropriately rated. Furthermore, a CFII who holds an MEI but does not hold a SEL pilot rating can not give instrument flight training in a Cessna 152.

What do you think? You over to the dark side yet?

Now if the student holds a multi engine rating, is where the grey area starts. I was arguing the fact if you are trying to give instrument instruction to someone who doesnt have any multi engine ratings.

If you are giving training to PVT AMEL student for a PVT Inst AMEL rating but you dont have an MEI how do you teach single engine approaches?? The instrument PTS requires single engine work on the checkride. You havent been "trained" to pull engines (not doubting you personally) just like a CFI can not give instrument instruction (for an instrument rating, not the instrument training required for PVT) even though they are instrument rated.

As far as the darkside goes, I would say the lightsabre is turning a light shade of pink

 

[BYUFlyr]

Ok, how about we just pull out the trump card:

http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_011_00.pdf

The FAA says you can give instrument flight instruction in a multi-engine aircraft without having an MEI.

A. Single and/or Multiengine Ratings. According to
FAR Par t 6 1 , 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.


How's that for a trump card?

 

[BYUFlyr]

If you are giving training to PVT AMEL student for a PVT Inst AMEL rating but you dont have an MEI how do you teach single engine approaches??

You don't teach single engine approaches, he already knows how to do that under VMC. The CFII teaches him how to rely on the instruments to do what the students already knows.

Remember this is instrument flight training not flight training.

 

[DC8 Flyer]

I guess my response to that would be that as a CFII you're not teaching him how to fly the airplane with one engine out (the regs assume both you and the student already know how to fly on a single engine).

I would say the regs assume the student knows how to fly on one engine in VFR conditions, you as the instructor are now tasked with teaching the student how to fly on one engine under IMC conditions. The real kicker here is, no single engine instrument testing on the MEI checkride is required.

All you're teaching is how to use the instruments to fly the same maneuvers you already know without having the benefit of visual references.

Think of the Cessna 152 example. How can a CFII (who does not hold a CFIA) give instrument flight training to a private pilot in a single-engine airplane? The instructor is not qualified to teach slow flight, steep turns, or even climbs and descents, but he can teach someone to fly by sole reference to instruments.

You are qualified, however, to teach slow flight, stalls, climbs and descents by sole reference to instruments as a CFII.

How's that? That's the best I can do....

Sorry for additional posts.

 

[DC8 Flyer]

Ok, how about we just pull out the trump card:

http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_011_00.pdf

The FAA says you can give instrument flight instruction in a multi-engine aircraft without having an MEI.

A. Single and/or Multiengine Ratings. According to
FAR Par t 6 1 , 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.


How's that for a trump card?

Thats a very good trump card, and I was hoping you weren't going to pull it


The thing with that is read the 15. Regulatory Requirements. It seems as though it contradicts itself. Specifically the part thats says, "The phrase "if appropriate" applies equally to and in combination with both certificates when instrument instructor ratings are involved."

As you read on it does give the appearance you can give instruction in a twin without having an MEI for instrument rating BUT paragraph C limits that to if only the student has a multi engine rating. So yup, I was wrong on that one, just had to sit and read it over and over 20 times to get it to set in!

So I guess if your student has his/her PVT AMEL ticket you can give them training in a twin for an instrument rating if you have only a CFII.

Doesnt sound right, but thats what the book says. The lightsabre is getting a little more red .