CFI not CFII Instrument Instructing

[ridethisbike]

I just took a look at the FAR again since this is the next rating that I am looking at. You don't have to have a CFII or any CFI for that matter to sign you off. You just have to meet the requirements of the regulation. As an instrument pilot you can fly the simulator and log the time. When you get the amount of time needed you simply apply for the certificate take the written and flight test. That's it. There is no requirement that you take any instruction for an ATP.

 

You might not need an endorsement for the ATP practical, but not needing a CFI-I while accruing the experience requirements is up for debate.

 

61.51

(g) Logging Instrument Time

(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs their person's logbook or training record to verify the time and the content of the training session.

 

 

Let's be real here, no one is going to go pay for FTD time just because. There will always be a reason for it. Recency, certificate, or rating. All three of which require a CFI-I signature. My opinion, based on 61.51/g/4, is that unless you acquire the instrument time in flight, you will need a CFI-I present.

 

That being said, I can understand the argument that you wouldn't need one since you're already instrument rated and could argue that you were using that FTD time for nothing more than gaining proficiency. Just not sure if would hold up if the FAA started asking questions...

[iChris]

 

61.195

© Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.

 

Simulator/FTD is not Flight Training, its not in an aircraft, then it must be a form of ground training. That authorized instructor could then possibly be a CFI exercising ground instructing privileges.

 

The intent:

The FAA disagrees that a non-instrument rated flight instructor should be able to teach the instrument training required for commercial pilot certification.

 

The FAA expects the instrument training required for commercial pilot certification to be more advanced and requires that the flight instructor who teaches instrument training at the commercial pilot certification level hold an instrument rating on their flight instructor certificate.

But thats not how the regulation is written- its written for flight.

 

No, it's written for training time. You had it right the first time.

 

Your question is specific to logging time in a flight simulator, flight training device, or aviation training device to meet part of the instrument aeronautical experience of §61.161 for the issuance an ATP pilot certificate.

 

Accordingly, the regulatory text of §61.51(g)(4) is clear that in order to log the time an instructor must be present to observe an individual using a flight training device or flight simulator

 

The instructor must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.

 

Since the instructor is providing helicopter training in a helicopter simulator the instructor must hold the appropriate category and class of the aircraft simulated.

 

§61.51 (g)(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

 

§61.1 Training time means training received—

 

In flight from an authorized instructor;

 

[ii] On the ground from an authorized instructor; or

 

[iii] In a flight simulator or flight training device from an authorized instructor.

Edited November 20, 2013 by iChris

[Retreating Brain Stall]

Thanks iChris

It was a good healthy debate and I appreciate everyones input.

Now to find a CFII to go with that free simulator...

[dankaten]

 

You might not need an endorsement for the ATP practical, but not needing a CFI-I while accruing the experience requirements is up for debate.

 

61.51

(g) Logging Instrument Time

(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs their person's logbook or training record to verify the time and the content of the training session.

 

 

Let's be real here, no one is going to go pay for FTD time just because. There will always be a reason for it. Recency, certificate, or rating. All three of which require a CFI-I signature. My opinion, based on 61.51/g/4, is that unless you acquire the instrument time in flight, you will need a CFI-I present.

 

That being said, I can understand the argument that you wouldn't need one since you're already instrument rated and could argue that you were using that FTD time for nothing more than gaining proficiency. Just not sure if would hold up if the FAA started asking questions...

According to 61.161 you just need the time. I use to have a Sim that I could use for free and I used to stay current using the device. That time can be used towards the minimums for the ATP.You can also use a safety pilot to keep yourself current in the actual aircraft. There would not be a CFII in the aircraft with you when you are doing this as well and the safety pilot does not have to be a CFII. You as an instrument rated pilot can log the time and the safety pilot doesn't sign your log book.

If what you are saying is correct then who signs your logbook for the 1200 hours of flight time? Once you get your Commercial you can build these times and as long as the FAA can look in your logbook and see that you have completed the requirements you are good to go.

[iChris]

According to 61.161 you just need the time. I use to have a Sim that I could use for free and I used to stay current using the device. That time can be used towards the minimums for the ATP.You can also use a safety pilot to keep yourself current in the actual aircraft. There would not be a CFII in the aircraft with you when you are doing this as well and the safety pilot does not have to be a CFII. You as an instrument rated pilot can log the time and the safety pilot doesn't sign your log book.

 

If what you are saying is correct then who signs your logbook for the 1200 hours of flight time? Once you get your Commercial you can build these times and as long as the FAA can look in your logbook and see that you have completed the requirements you are good to go.

 

That’s the way it was, we just wrote it in. That was the word on the street. Everyone did it. Why would flight instructors waste time with a student in a simulator when they could be out flying? Any way, it was more fun playing on the simulator without any instructor around. It was an easy way to log instrument time.

 

We never dreamed of actually reading the regulation. We wrote it in without ever thinking about it. The wrong information was being passed down for all those years. Some people picked-up on the right info and some didn’t.

 

Even the old rule required an authorized instructor; however, the way it was written there was really no accountability. We could always say an authorized instructor was present somewhere in the local vicinity. What the pilot wrote in their logbook was what the examiner had to accept as fact. However, the current rule adds some accountability.

 

Flight simulator or flight training device instrument time is no longer acceptable (to meet the aeronautical experience requirements for a pilot certificate, rating, or instrument recency experience) without an authorized instructor’s signature in your logbook or training record, verifying the time and the content of your training session.

 

The old:

 

61.51 (g)(4) A flight simulator or flight training device may be used by a person to log instrument flight time, provided an authorized instructor is present during the simulated flight. Historical REF:

 

The current:

 

61.51 (g)(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

 

 

“Many instructors and pilot schools believe that if an instructor is not required to be present when an airman is performing the approaches, etc. in an aircraft, then they should not be required to be present when an airman is performing the same tasks on a flight training device or flight simulator.”

 

REF: Office of the Chief Counsel

Edited November 20, 2013 by iChris

[iChris]

If what you are saying is correct then who signs your logbook for the 1200 hours of flight time? Once you get your Commercial you can build these times and as long as the FAA can look in your logbook and see that you have completed the requirements you are good to go.

 

You need to cross reference the ATP requirement of §61.161 with §61.51. Not all of that time requires an instructor’s signature. You need to be specific to the time required. Example, logging PIC time under §61.51[e][1] vs. logging training time under §61.51[h][1] and [2].

Edited November 20, 2013 by iChris

[dankaten]

 

That’s the way it was, we just wrote it in. That was the word on the street. Everyone did it. Why would flight instructors waste time with a student in a simulator when they could be out flying? Any way, it was more fun playing on the simulator without any instructor around. It was an easy way to log instrument time.

 

We never dreamed of actually reading the regulation. We wrote it in without ever thinking about it. The wrong information was being passed down for all those years. Some people picked-up on the right info and some didn’t.

 

Even the old rule required an authorized instructor; however, the way it was written there was really no accountability. We could always say an authorized instructor was present somewhere in the local vicinity. What the pilot wrote in their logbook was what the examiner had to accept as fact. However, the current rule adds some accountability.

 

Flight simulator or flight training device instrument time is no longer acceptable (to meet the aeronautical experience requirements for a pilot certificate, rating, or instrument recency experience) without an authorized instructor’s signature in your logbook or training record, verifying the time and the content of your training session.

 

The old:

 

61.51 (g)(4) A flight simulator or flight training device may be used by a person to log instrument flight time, provided an authorized instructor is present during the simulated flight. Historical REF:

 

The current:

 

61.51 (g)(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

 

Chris you know I looked over your post and then read the letter by the legal counsel that you posted a link too, and all I have to say is that as usual I was wrong. Here we go again with the FAA writing articles that contradict themselves. What I read in that article is that I can go out in an aircraft and fly and approach or say I flew an approach and log it but if I do it in a simulator I have to have someone else verify that I am not lying about it. This really makes me feel good since I am a CFII myself and I can't verify that I am meeting the minimums. Sorry kind of a deal.

Thanks for going the extra mile to keep the rest of us informed.

[WolftalonID]

So now, as usual in these discussions, I get confused. The OP linked to an article that was very well written, and referenced. In fact the whole authors web site is well put together.

 

So did the OP confuse the article with his position? Or are we seeing the traditional issue of the FAA not being consistent from one DPE or FSDO to the other?

 

As a CFI, I strive to be clear, but its so frustrating when a discussion like this erupts and so many valid references are linked and then contradict the topic. I remember being grilled by the DPE on endorsements, and while testing for my CFI finding endorsements in my log book that were NOT written correctly, approved and filed as certified by the DPE. Not that I didnt do the work, just endorsements that referenced the wrong FAR for the wording on them.

 

Legally speaking those endorsements fall back on e CFI and the DPE. So many CFI's just copy and paste from a list the school they work for gave them. How many CFI's open up their books and read the referenced endorsement locations to validate the legality of what they just signed off?

Edited November 22, 2013 by WolftalonID

[aeroscout]

What seemed to me to be a clear cut and dried issue, is not at all.

Even after I have read the whole thread, and think I have a better grasp of it, I'm not unshakably certain.

In addition, I used to think that an ATP could give instruction towards the attaining of an ATP. I understood that to mean any training since arguably it all leads to an ATP eventually.

[WolftalonID]

Omg did I type that here? No wonder I got confused. I was reading to much today and confused iChris's last reply here with a different thread altogether. The one about add on hours.....god I need sleep!

[dankaten]

What seemed to me to be a clear cut and dried issue, is not at all.

Even after I have read the whole thread, and think I have a better grasp of it, I'm not unshakably certain.

In addition, I used to think that an ATP could give instruction towards the attaining of an ATP. I understood that to mean any training since arguably it all leads to an ATP eventually.

It really isn't that complicated unless you throw in part 135 operations.

An ATP is nothing more than an Airline Transport Pilot which means that they can fly an aircraft that carries more than I believe 14 passengers. In other words he can fly an S92. With an ATP you are required to have a class I flight physical and in the case of being over 40 you have to get one every 6 months. An ATP cannot give instruction because he is not an instructor. Now all of that changes when you go to a part 135 operator. In part 135 you can be designated as an instructor as a commercial Pilot. Not a good idea and I could really tell you of some great times I have had with that exact situation.

To give instrument instruction you have to be a CFII unless you work for a part 135 operator. Now I know that even though I am a CFII when it comes to getting my ATP if I use a simulator I must have another CFII sign off the hours flown in that simulator. Still cheaper than renting a helicopter but still ticks me off.

[aeroscout]

It really isn't that complicated unless you throw in part 135 operations.

An ATP is nothing more than an Airline Transport Pilot which means that they can fly an aircraft that carries more than I believe 14 passengers. In other words he can fly an S92. With an ATP you are required to have a class I flight physical and in the case of being over 40 you have to get one every 6 months. An ATP cannot give instruction because he is not an instructor. Now all of that changes when you go to a part 135 operator. In part 135 you can be designated as an instructor as a commercial Pilot. Not a good idea and I could really tell you of some great times I have had with that exact situation.

To give instrument instruction you have to be a CFII unless you work for a part 135 operator. Now I know that even though I am a CFII when it comes to getting my ATP if I use a simulator I must have another CFII sign off the hours flown in that simulator. Still cheaper than renting a helicopter but still ticks me off.

It is more complicated than you indicate. ATPs can give instruction, but at least now in very limited constraints.

ATPs are not required to have a class 1 flight physical except in 121 and some 135 operations.

[Mikemv]

§61.167 Airline transport pilot privileges and limitations.

(a) Privileges. (1) A person who holds an airline transport pilot certificate is entitled to the same privileges as a person who holds a commercial pilot certificate with an instrument rating.

(2) A person who holds an airline transport pilot certificate and has met the aeronautical experience requirements of §61.159 and the age requirements of §61.153(a)(1) of this part may instruct—

(i) Other pilots in air transportation service in aircraft of the category, class, and type, as applicable, for which the airline transport pilot is rated and endorse the logbook or other training record of the person to whom training has been given;

(ii) In flight simulators, and flight training devices representing the aircraft referenced in paragraph (1) of this section, when instructing under the provisions of this section and endorse the logbook or other training record of the person to whom training has been given;

(iii) Only as provided in this section, except that an airline transport pilot who also holds a flight instructor certificate can exercise the instructor privileges under subpart H of this part for which he or she is rated; and

(iv) In an aircraft, only if the aircraft has functioning dual controls, when instructing under the provisions of this section.

(3) Excluding briefings and debriefings, an airline transport pilot may not instruct in aircraft, flight simulators, and flight training devices under this section—

(i) For more than 8 hours in any 24-consecutive-hour period; or

(ii) For more than 36 hours in any 7-consecutive-day period.

(4) An airline transport pilot may not instruct in Category II or Category III operations unless he or she has been trained and successfully tested under Category II or Category III operations, as applicable.

Edited November 23, 2013 by Mikemv

[aeroscout]

^Thanks Mikemv.

[dankaten]

As usual I stepped in it again. Thanks Mikemv that was very educational. I guess I should have read back in that part. I was correct about the physical though. You can have a Class II flight physical and perform as an ATP but only as second in command. If you want to perform as PIC you need a Class I physical. Of course if you are not acting as an ATP and you are just flying a Class II will work for commercial operations.

[iChris]

Legally speaking those endorsements fall back on e CFI and the DPE. So many CFI's just copy and paste from a list the school they work for gave them.

 

How many CFI's open up their books and read the referenced endorsement locations to validate the legality of what they just signed off?

 

What seemed to me to be a clear cut and dried issue, is not at all.

Even after I have read the whole thread, and think I have a better grasp of it, I'm not unshakably certain.

 

In addition, I used to think that an ATP could give instruction towards the attaining of an ATP. I understood that to mean any training since arguably it all leads to an ATP eventually.

 

Some DPE have fallen into this, ATPs can instruct trap. The phrase “air transportation service” is not defined anywhere within the FARs. The phrase is often ignored with respect to its meaning, as in the following legal case:

 

“Respondent related that he replied to DPE Carey that he was not a certified flight instructor (“CFI”), but that DPE Carey advised respondent that he could recommend Mr. Roberts for his practical test on the basis that respondent held an ATP certificate, was type rated in the aircraft, and had flown with respondent for more than 500 hours…”

 

The finding in that case on the phrase “air transportation service”:

 

“In this regard, we also take notice of a clarification posted on the FAA’s official web site. There, a question about the meaning of “air transportation service” within the scope of FAR section 61.167[1] is published. The officially-provided answer to the question (the source indicated on the web page is “AFS-840”) concludes that “what the phrase ‘ . . . [1] Other pilots in air transportation service . . .’ means in effect [is] that both pilots have to be employees of the same company in air transportation service and the training program must have been approved under Part 121 or Part 135 or 125 or 129, as appropriate....”

 

REF:

Administrator vs. Vecchie; NTSB Order No.EA-4816

 

The intent of § 61.167[a][2] where it states “other pilots in air transportation service” means the training program must be an approved air carrier training program and both the instructor and the pilot must be employees of the same air carrier.

 

As per § 61.167[a][2][iii], an airline transport pilot may instruct, “only as provided in § 61.167[a][2], unless the airline transport pilot also holds a flight instructor certificate, in which case the holder may exercise the instructor privileges of subpart H of Part 61 for which they are rated.”

 

Which means, if the training conducted or endorsement given are outside of an approved air carrier training program, the instructor must hold a flight instructor certificate with the appropriate aircraft ratings.

Edited November 25, 2013 by iChris

[iChris]

I used to think that an ATP could give instruction towards the attaining of an ATP.

 

I understood that to mean any training since arguably it all leads to an ATP eventually.

 

Yes, If…

 

1. Both the ATP instructor and the pilot receiving the training are employees of the same air carrier.

 

2. The air carrier has an approved ATP training program under its certificate.

 

Both 1 and 2 must be true otherwise; The ATP instructor must hold a flight instructor certificate with the appropriate aircraft ratings.

Edited November 25, 2013 by iChris

[aeroscout]

Good stuff iChris. As usual. Thanks.