Renewing my CFI?

[BamBamJet]

I got my CFI in February of 2002 then my CFII in November of 2002. Would I go by the 2 year rule for Fubruary or November. Also, I got my Commercial in January of 2002. My BFR would be do....with respect to my last Instructor rating? These things get confusing and when your nose isnt in it all the time you forget things! Thanks for the help.

 

[midlifeflyer]

I got my CFI in February of 2002 then my CFII in November of 2002. Would I go by the 2 year rule for Fubruary or November. Also, I got my Commercial in January of 2002. My BFR would be do....with respect to my last Instructor rating? These things get confusing and when your nose isnt in it all the time you forget things! Thanks for the help.

For your CFI, you should have received a new CFI certificate after your II ride. It shows the expiration date, which should be November 30, 2004.

As for the BFR, that's a separate issue, and a bit of a problem. The Part 61 FAQ takes the view that obtaining a CFI certificate or rating doesn't necessarily start the BFR clock over. Technically a CFI certificate is not a "pilot" certificate (read the instructor certificate — it contains a requirement that you also have your pilot certificate with you). And, at least in theory, you can take a CFI checkride without ever flying the airplane enough for your piloting skills to be evaluated (which is ridiculous in the real world). So the FAQ recommends that, to remove doubt, you ask the DPE or inspector at a CFI ride to sign off a flight review also.

 

[CitationLover]

61.56(d)

States anyone who has passed .... for a pilot certificate, rating, or operating privilege.... does not need the flight review as req'd by 61.56.

to me that seems ANY FAA flight certificate, airplane type rating, 121/135 check ride would extend a BFR. local DPE's in the Charlotte FSDO were asked this and they agree with this assesment.

hope it helps.

 

[stlpilot]

Same question came up in the STL FSDO 3 years ago. It ended up a split vote. The inspectors actually said they did not know if a CFI ride would count, while most the DE's said it would. In the end the inspectors said they would recognize the CFI or any other instructor rides so long as there was a flight involved. But simply renewing a certificate from an 80% student pass rate would not be enough if no flight occurred.

The flight school I worked for ended up with the conclusion to just do a flight review regardless, for the reason that if its a gray area with the FAA and the time comes that you get in any non related legal trouble, then they might interpret the BFR rule in their own favor and have yet another thing they can bust you for. It’s easy enough for a CFI to complete a BFR anyway and you’re just looking at a flight, no ground, if you already met the renewal requirements for the CFI. Just my .02 cents

 

[great cornholio]

Your CFI should have an expiration date on it. It would be 24 months after your last instructor rating. You still need a BFR for your commercial certificate though. Or you could do the wings program.

 

[Toy Soldier]

CitationLover nailed it!

Part 61.56 (d)

A person who has .......passed a pilot proficiency check........ for a pilot certificate, rating, or operating privilege need NOT accomplish the flight review.....

It seems like the CFI ride covers any need for an additional BFR ride for a commercial, ATP ticket privilege, etc...

 

[justmeinmsp]

How about this. I let my CFII expire in OCT of 2002. What is the least painful method to bring it current?

 

[starcheck1]

Have fun, there is no real painless way...you have to pass a practical test for one of your CFI ratings to get it reissued now. It's better not to let it expire if you want to continue to instruct.

 

[great cornholio]

Expired doh

If you actaully let your CFII expire then the only way to get it back is to retake the practical test. Not sure if you have to retake the written though. But it is not like you pretty much never had the rating. Also if you were a CFI CFII MEI then you have to do all 3 rides over again.

 

[bobbysamd]

CFI renewal and BFR

I appreciate Midlife's point of view about the controversy over a CFI ride counting as a flight review. But I would go along with the others' interpretation of 14 CFR 61.56(d). I never heard otherwise until I joined this board two years ago. The issue would indeed turn on whether there was a flight involved for the new rating.

Take a look at your CFI certificate. The expiration date printed thereon is when it expires. It's as simple as that. You have to renew by any of the various means before that date or else you are SOL. At that point you have to take a reinstatement ride. Pursuant to 14 CFR 61.199(a) , you can take a reinstatement ride in any aircraft in which you are rated to instruct:

Sec. 61.199 - Expired flight instructor certificates and ratings.

(a) Flight instructor certificates. The holder of an expired flight instructor certificate may exchange that certificate for a new certificate with the same ratings by passing a practical test as prescribed in §61.183(h) of this part for one of the ratings listed on the expired flight instructor certificate.

(emphasis added)

You do not have to retake the written(s).

I have understood for many years that if your CFI has expired that you can take a CFI practical for a new instructor rating and have it also count as a reinstatement ride.

 

[avbug]

There are many interesting ideas here, every one of which is completely incorrect except for Bobby and Midlife. They are both accurate in their statements.

Seeking advice or any sort of interpretation at the FSDO level is folly and an exercise in futility. The FSDO level is not authorized to provide this information, and is very often misinformed. Seeking this advice from a designated examiner is one step worse...don't waste your time.

If your instructor certificate has expired, the only legal way in which to proceed is reinstatement. This requires a practical test. You may take the practical test for any rating attached to your flight instructor certificate, or you may take the practical for a new rating. Adding a new category such as helicopter, for example.

If you hold multiple ratings, you do NOT need to take the practical test for each rating. Only one. If you are an instructor in airplanes, gliders, and helicopters, you may take the practical test in any one of them.

 

[A Squared]

Folks, the CFI-BFR question was answered correctly by the first respondant (midlifeflyer) The rest who weighed in on the question (CitationLover, stlpilot, and Toy Soldier) are wrong.

Look, this question gets asked over and over, and the answer never changes, a CFI ride does *not* equal a BFR.

The short explanation: FAA legal counsel has issued a letter of interpretation stating that a CFI test will not fulfill the need for a BFR. They say no, they make the rules.


Slightly longer explanation: Mark already posted this, but apparently not everyone was paying attention. 61.56(d) specifies a *pilot*certificate rating or operating privelige. Is your instructor certificate a pilot certificate? Can you legally pilot an airplane with just your instructor certificate? no. If it's not a pilot certificate, it doesn't satisfy 61.56(d)

I don't have time to dig out the Letter of Interpretation right now, but it's been posted countless times. Do a search

I second what Avbug says about polling FSDOs. It really doesn't matter that 8 out of 10 FSDO employees agree on a legal matter, thier opinion is completely irrelevant and very likely incorrect. The opinion that matters is FAA legal counsel.

 

[justmeinmsp]

So, my CFI-CFII is expired, are you saying that if I get an MEI added(I don't have it now) that will reinstate my CFI-II?

 

[avbug]

Justmeinmsp,

Your CFI-CFII didn't just expire, because you don't have one; there's no such thing. You hold a flight instructor certificate. That expired. The "CFII" denotes a rating on that certificate. That didn't expire, but the certificate did.

This may seem splitting hairs, but it's not. It's the certificate that's expired. You may reinstate it by sucessfully passing the practical test for any rating appended to that certificate, or by passing the practical test for a new rating to be added to that certificate.

In answer to your question, then, by adding a multi engine rating to your flight instructor certificate, you reinstate the certificate. When you reinstate the certificate, you reinstate it in full, to include any ratings that are on that certificate.

For example, if you held a "CFII" and held glider and rotorcraft privileges on your flight instructor certificate, you may add the multi engine privileges in an airplane and reinstate all of them...glider, helicopter, all of it. These are all ratings on one certificate, and it's the certificate you're reinstating. By adding another rating, you reinstate all the ratings, because they're already on the certificate. You needn't reinstate separate ratings.

You would not, for example, need to take separate practical tests in gliders and helicopters...it all comes back to life again, is reinstated as one big ball of wax, by adding the rating, or passing the practical test for any rating you already hold on that certificate. If you take the practical test for reinstatement in a helicopter, and you hold glider and airplane privileges, then you get those back too...no need to take a ride in a glider or airplane, and so on.

As for the previous questions regarding flight reviews, A Squared is correct. To clarify that, renewal of a flight instructor certificate will count for the one hour of ground training required for the flight review, as specified in 14 CFR 61.56(f). It should be noted that this applies to the renewal of a current flight instructor certificate, not the reinstatement of an expired flight instructor certificate.

The wisest thing to do in the case of compliance with 61.56 for the purposes of obtaining credit for a flight review, is to request a specific endorsement from the examiner showing that you have completed a flight review. Do not simply try to fiat this by making reference to your practical test, because it doesn't count. Get an endorsement showing completion of a flight review, by the examiner or inspector providing your practical test, and then you are fully covered. Most examiners or inspectors should have no problem providing this endorsement at the same time you complete your practical test.

Again, note that this is a separate, specific endorsement showing that you have completed a flight review. This endorsement is separate, and over and above any other paperwork you receive from the examiner or inspector.

 

[Toy Soldier]

Here is what the AOPA interpretation has to say about it. This information is made available to AOPA members in the "members only" section.

AOPA quote
Alternatives to the Flight Review
A Flight Review is not required if the pilot completed within the 24 calendar month period:
1. any phase of the "wings" program
2. received a new certificate (private, commercial, ATP and CFI)
3. received a new rating (instrument, multi-engine, glider)
4. flies for a Part 121 (Air Carrier) or 135 (Air Taxi) operation and satisfied the appropriate proficiency checks

The following ONLY applies to someone that has renewed their certificate by doing the on-line courses, NAFI Master CFI program, flight instructor refresher clinics, etc. NO FLIGHT is required using these CFI renewal techniques - therefore, the following statement applies...

AOPA quote
Current flight instructors who renew their CFI certificate by attending a flight instructor refresher clinic need not complete the one hour of ground, but must complete the minimum one hour flight.

 

[avbug]

The information is also clearly printed in the regulation.

To sum that up: renewal of the flight instructor certificate does not take the place of a flight review, but as previously stated, does take the place of an hour of ground in credit toward the flight review as stated in 14 CFR 61.56(f).

No joining AOPA required.

You stated that

Current flight instructors who renew their CFI certificate by attending a flight instructor refresher clinic need not complete the one hour of ground, but must complete the minimum one hour flight.

This is correct, however, you incorrectly stated that

ONLY applies to someone that has renewed their certificate by doing the on-line courses, NAFI Master CFI program, flight instructor refresher clinics, etc.

This is not the case. The error is in the use of the word "only." Renewal of a flight instructor certificate counts for the hour of ground required by 61.56...but there are more ways to renew a flight instructor certificate than simply a clinic, an on-line course, r the NAFI master cfi program. 61.56(f) refers us to 61.197, which also includes passage of a practical test, and renewal by presentation of a successful student pass record.

 

[Toy Soldier]

Avbug

Yes, you are right about not having to join AOPA to read the reg on needing the one hour of flight if you "renewed" the CFI ticket.

However, The confusion in the earler posts was relating to taking a CFI ride and having it count towards the BFR.

Original post by A Squared
-------------------------------------------------------------------
Look, this question gets asked over and over, and the answer never changes, a CFI ride does *not* equal a BFR.
-------------------------------------------------------------------

AOPA's quote differs...

AOPA Quote
-------------------------------------------------------------------
Alternatives to the Flight Review
2. received a new certificate (private, commercial, ATP and CFI)
-------------------------------------------------------------------

The operative word here is "new", not renewed. If the ticket is new, then no BFR is required. If the ticket is renewed, then one hour of flight is required. Unless it was "renewed" via a checkride.

Correct me if I'm wrong. But are we talking about the same thing?

 

[justmeinmsp]

Thanks for the clarification Avbug.

 

[A Squared]

Correct me if I'm wrong.

You're wrong, you seem particularly uninterested in being corrected. I'll try one more time.

We are not talking about a renewal by a seminar or by instructional record, or anything else. Obviously that wouldn't satisfy the requirement for a BFR

Yes, we are talking about the initial issue of a Fiight instructor certificate as the result of a successful checkride. No, it will not take the place of a BFR.

Once again, a flight instructor certificate is not a pilot certificate, 61.56(d) specifies a *PILOT* certificate.

Once again, the FAA's legal counsel has issued an interpretation which stated explicitly that a CFI checkride does not take the place of a BFR. I have copied the legal interpretation below.
Here's the relevant text:

"Accordingly, a CFI practical test will not per se fulfill the flight review requirement."

The AOPA website is obviously incorrect. Look at it this way; AOPA takes your money and gives you little stickers to go in your car window. They say that a CFI ride counts as a BFR.


FAA legal counsel takes your certificate and gives you suspensions. They say that a CFI ride does not as a BFR.

Who does it make more sense to believe? AOPA or the FAA?

Think about it for a minute. The answer will come to you






1 Aviation Plaza
Room 561
Jamaica, NY 11434

RE: Interpretation of FAR 61.56(d)

Dear Mr. Dennstaedt:

This is in response to your letter dated August 25, 2001, wherein you ask whether an airman can satisfy the flight review requirement under 14 C.F.R. (Federal Aviation Regulation [FAR]) 61.56 by passing a practical test to become a certified flight instructor (CFI), as required by FAR 61.183.

Under FAR 61.56(c)(1), one may not act as pilot-in-command of an aircraft unless, within the preceding 24 calendar months, he has "accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor." Under FAR 61.56(c)(2), the airman must receive a logbook endorsement from the authorized instructor certifying that he has satisfactorily completed the review. Under FAR 61.56(a), a flight review must include: (1) a review of the current general operating and flight rules of Part 91; and (2) a review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.

Under FAR 61.56(d), however, the flight review requirement of FAR 61.56(c)(1) does not apply to one who has "passed a pilot proficiency check conducted by an examiner, an approved pilot check airman, or a U.S. Armed Force, for a pilot certificate rating, or operating privilege."

The issue you raise is whether passing a practical test to become a CFI can fall within the exception to the flight review requirement that is provided by FAR 61.56(d). Under FAR 183(h), to be eligible for a flight instructor certificate or rating, the applicant must "pass the required practical test that is appropriate to the flight instructor rating sought." The FAA Practical Test Standards (PTS) for the airplane flight instructor examiner (sic) requires that the examiner ensure that the flight instructor applicant has the "ability to perform the procedures and maneuvers included in the standards to at least the commercial pilot skill level."

Thus, the instructor has broad discretion in conducting a flight review. A CFI practical test encompasses the demonstration of various basic maneuvers that an instructor is likely to cover in a flight review. Incorporating a flight review into the CFI practical test could be accomplished, therefore, with little, if any difficulty.

Accordingly, a CFI practical test will not per se fulfill the flight review requirement. A practical test for a CFI rating under FAR 61.183, taken within 24 months of a prior flight review, can readily meet the flight review requirement of FAR 61.56(d), however, if the examiner is satisfied that a flight review endorsement can be given. To ensure that the CFI applicant gets credit for successful completion of the flight review, however, he or she should ask the examiner to conduct the CFI oral and practical test so as to satisfy the flight review requirements as well, and to make a logbook endorsement for the flight review upon completion of the examination.

If you have additional inquiries, please contact Zachary M. Berman of this office at (718) 553-3258.

Sincerely,


Loretta E. Alkalay

 

[Toy Soldier]

A Squared

Now that's THE WAY to do business! Post the "book answer"!

I don't mind being "corrected". It's not about me being right - it's about me having the correct answer.

It also appears that there is some gray area. It seems like the CFI ride can count as a BFR - but there is some additional effort required to meet the requirement. It's not cut and dry like some thought it was.

Thanks for the copy of the letter. It helps greatly!

 

[avbug]

There is no ambiguity at all, no grey area, and no room for confusion. The regulation, repeatedly stated here, is crystal clear, even without the letter of interpretation or legal opinion.

Is there some confusion that a practical test for the flight instructor certificate, which is not a pilot certificate, counts for a flight review (no such thing as a "BFR")? None.

It may be "counted" for the hour of ground required in a flight review, in accordance with 61.56. That's it.

If an examiner is willing to sign off for completion of a flight review, then it's up to the examiner to take the responsibility to provide a specific endorsement stating that a flight review was conducted.

Of it's own accord, the practical test for the flight instructor certificate does not take the place of a flight review. There is nothing gray about it.

 

[Toy Soldier]

Splitting hairs I see. You just said the same thing I did - just in a different way.

I'll say it again - YOU ARE CORRECT

The "gray area" that I was alluding to was the OMMISSION of the fact that the DE needed to give the appropriate endorsement if the CFI ride was to count as a flight review also. Some folks don't realize that - hence, it's a gray area (not all the facts) for them.

Maybe I didn't use the "best" choice of words - but I meant what you said!

I am bowing humbly.

 

[aldassy]

Be careful with the MasterCFI method of renewal. I started three months prior to expiration applying to NAFI for the master designation. A month before exp. I got it. After the run around at the FSDO for three weeks, they decided not to recognize that as a means to renew (its not written in the regs so it must not be true) I showed them the website and other material I had from NAFI, but no dice. It expired and now I have to take the practical. I'm not too excited about spending another $500 to take a test that I feel I've already passed. Had I known about the rundown at the FSDO I would have done a FIRC long ago.
BTW, at the last minute I tried renewal by the 4 out of 5 passes on students practical tests. The FSDO's record did not match mine. Be prepared to bring EVERYTHING showing who you signed off, different people give you different answers on what is acceptable proof. Very frustrating.

 

[Toy Soldier]

aldassy

Sorry to hear about your Master CFI renewal problem! Mine went so smooth in Atlanta that it scared me!

1. Didn't NAFI give you a copy of the FAA letter stating that they would in fact accept the "graduation certificate" as a renewal?

2. Did you let NAFI know of the problem and what did they say?

It sounds like that FSDO has some issues anyway......

 

[cvsfly]

Welcome to the wonderful world of FSDOs. Not all are created equal and some think they are more equal than others. Ask 10 different FSDOs a question and you are likely to get 10 different answers. Ask for it in writing (which is a sure way to piss them off).

 

[avbug]

Why ask at all? You should already know and understand that the FSDO CANNOT give you an interpretation. They don't have the authority. An inspector can give you an opinion which carries no more weight than mine or yours...but it is not defensible, nor binding. Were that opinion written, it would be no more binding.

Does it matter that you would get ten different answers? Why be lazy and approach the FSDO to get information? Why not put in the effort to research and know the answer, instead of relying on the advice of a person who is employed by the government because he couldn't make it in the private sector?

Folks who are foolish enough to approach the FSDO level for answers to questions deserve what they get. Folks who are foolish enough to live by the advice or opinions they take from the FSDO level, when it's well known that such advice or information is unofficial and unauthoritative, deserve whatever befalls them. It's really just self-punishment for the lazy.

 

[TEXAN AVIATOR]

A Squared excellent post! I was searching through the archives for this subject; thought I’d bring it back to life might help someone else.

 

[JAFI]

Avbug, you wrote:

"relying on the advice of a person who is employed by the government because he couldn't make it in the private sector?"

I take exception to that remark. I work with many inspectors who got tired of going bankrupt "in the private Sector". It is hard to explain to the bank that the mortgage payment isn't going to come for a while because the "glory" of aviation isn't paying off well this decade. Many inspectors are in the job because they are trying to make a positive difference. You would not like someone to say that you are lesser because you never made it as an Airline Pilot.

To others:

As for the remarks that you will get 10 answers from 10 FSDO's, as Avbug pointed out that Inspectors do not give legal interpitations, you get those from FAA legal, in writing from a written request in the form of a letter.

As for a "Master CFI" renewal, I have not seen any FAA memo about using this as a renewal, no one has asked me to look into this yet. But with the crap I get from some pilots, I'm not in a big hurry.

 

[avbug]

I said private sector, and spoke not a whit about airline flying. Truth is that there are very few airline pilots that light my pipe either...I've met precious few that impressed me.

In all fairness, I know certain in the FAA that are qualified individuals, and whom have an adequate background. I know many more who do not, who are bureaucrats who are easily recognized as FAA because they're the only ones at the airport who's socks don't match.

I've known some darned fine individuals who were a credit to the agency, and to the industry. I've known some others who were not. It's of those individuals whom I spoke.

 

[Cosmo1999]

I still say you can use the CFI checkride to extend your BFR. It is not a pilot proficency checkride however it is a checkride for an operating privledge. Tell me how being able to teach is not an operating privledge. That letter was issued for the east coast region but does not apply to the west coast to the best of my knowledge. So if your in the west coast region its still a gray area. If your on the east coast just have anyone sign the endorsement. If you just go up and fly for fun with a buddy you can count that or have the DE sign the endorsement for you after the checkride.