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CFII must be CFI's too?


Curyfury
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Is it possible to be a CFII but not a CFI? I would thin thats like asking if you can have your instrument rating with your private rating, but since its only instructing, why not?

 

Well damn, i guess i should have googled this question first. Apparently it is allowed.

Edited by Curyfury
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There is no "private rating." You may hold a pilot certificate at one of several levels of certification, including Private Pilot.

 

The FAA does not issue separate certificates for "CFII" or "CFI."

 

An instructor holds a Flight Instructor certificate, and may rated for various instruction privileges.

 

One obtain certification as an instructor in instrument flight in airplanes or helicopters ("CFII") just as one could hold a ground instructor certificate just for instructing instruments ("IGI"); it's a privilege on the instructor certificate, rather than a separate certificate.

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So in clear words...no. Or is that a yes? Guess it depends on if I answer the OP's Title or the question in the post. Lol

 

One must first obtain the CFI rating. Then aditionally you can train and add on the CFI-Instrument. That also will be attached to the catagory and class your certified to instruct in.

 

Such as: Commercial Pilot, Rotorcraft- Helicopter; Instrument- Helicopter

 

Thats what my certificate looks like. Then on the CFI certificate it just says

 

Flight Instructor, and the back has the same Catagory and class and Instrument allowances.

Edited by WolftalonID
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I remember back when I was training in multi-engine, I went up with an MEI and while we were talking he could go with me on a flight next time I took one of the Cessna 172s out. I was already a CFI in airplanes (single engine) I said sure. He told me he had never flown, or even flown in a single engine airplane. So the guy was a multi-engine instrument instructor and had never flown a single engine airplane. Whooda thunk it possible.

 

But, I think to answer your initial question, no, you cannot be a CFII without first being a CFI. Your post says you found where its allowed? Id be curious to know what you found that says that?

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Guys,

 

It is totally possible to be CFII without first being CFI in either airplanes or helos +.

 

The problem arises of providing only Instrument Instruction without providing "other" basic instruction and logging it all as instruction given or received by the pilot.

 

Think "authorized instructor".

 

This question was brought up at Heli Success some years ago. Any DPE or FAA/ASI will confirm this.

 

The best path is CFI and then CFII but it is not required.

 

Best Wishes,

 

Mike

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Mike,

 

What would your authorization look like? i.e. is it a CFI certificate with limitations to instrument only? How do you delineate what category and class you're authorized to teach instruments in, but not anything else?

 

I'm just curious as to what the specifics are in a case like this.

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So you could do instrument instruction but not be authorized to go out and teach Chandelles and Lazy-8s?

This confirms my belief that the FAA needs to get out of the aviation business.

Although its possible then, I would have to imagine it would really be more work to be a straight CFII than to be a CFI first.

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Mike,

 

There is a direct letter of interpretation that conflicts with your statements. 61.195 covers it. The word "and" in that regulation is not the word "or".

 

Its like trying to be an instument only pilot without first being a pilot.

 

Edit... "Auhorized instructor" Ok, Mike in this case yes, I could see this being the case. However this case would be more specific to a "company" check instructor situation. The OP may not have really gone down that path of questions in his original question.

Edited by WolftalonID
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The FAA Chief Legal Counsel has been consistent in maintaining that in order to provide flight instruction toward a private, commercial, or ATP, one must hold a catetory/class rating for the aircraft on one's instructor certificate, as well as pilot certificate.

 

While a "CFII" can provide instrument instruction, the "CFII only" lacks the requisite class rating to provide instruction other than instrument instruction.

 

The 2012 Beard letter addressed the issue with regard to instruction and simulators, and the 2010 Grayson letter addressed the issue with regard to instruction given.

 

Yes, a "CFII" can be obtained first; the confusion here is that some think it's a different certificate. There is only one flight instructor certificate. Everything else is simply a privilege or rating placed on that certificate. A "CFII" is a certified flight instructor (CFI). One can't become a CFII and not be a CFI...because a CFII is a flight instructor. The question, then, is whether one can become a flight instructor limited to instrument instruction privileges, as the initial certification, and the answer is yes.

 

The problem for the holder of a flight instructor certificate with instrument instruction privileges only, however, is that the opportunities and scope of instruction are very limited. As the holder of a "CFII" only, you can't act as an authorized instructor outside of providing instrument instruction. You can't endorse for other training, either.

 

Yes, you can get your instrument instructor rating as your initial flight instructor certificate acquisition, but you're limited in what you can do with it. You can't give primary instruction or advanced instruction, other than instrument instruction.

 

Taylor Grayson had three letters of interpretation in 2010. The second is the relevant one to the question of this thread. Grayson's question asked if an instructor who doesn't hold class ratings on his instructor certificate can provide instruction in single engine or multi engine airplanes. The FAA Chief Legal Counsel was adamant that no, he could not. Simply holding those ratings on one's commercial certificate are insufficient. Therefore one who holds (in his case) Certified Flight Instructor, Instrument Airplane could give instrument instruction in airplanes, but lacking a single engine or multi engine airplane rating, could not give other instruction (eg commercial, ATP, etc), and is limited to only instruction as an instrument instructor.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/grayson-2%20-%20(2010)%20legal%20interpretation.pdf

 

The same holds true for instruction in helicopters. One who holds a "CFII' and who has not completed the checkride for a category/class rating on the flight instructor certificate, is limited to giving only instrument instruction in the category of instrument rating held on the instructor certificate.

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Avbug has it nailed above for us all except the CFI is "Certificated" flight instructor as the US does not certify or license pilots.

 

also, some major training schools have instructors that only teach instrument flying. Civilian and military.

 

What AvBug stated about only having on instructor certificate is true. It is about privileges and limitations as he put forth. A CFI with instrument privileges (only) could not endorse a pilot for solo, etc.

 

For awhile, i held a CFI -RH, Airplanes expired and attained a CFI SP (sport pilot instructor) via a proficiency check (log book endorsement was my CFI-SP). A year or two later the FAA got it together and placed the SP on my one & only CFI certificate.

 

Mike

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Mike,

 

What would your authorization look like? i.e. is it a CFI certificate with limitations to instrument only? How do you delineate what category and class you're authorized to teach instruments in, but not anything else?

 

I'm just curious as to what the specifics are in a case like this.

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In the past is was more common for people to obtain their commercial license before their instrument so that they could start working towing banners or something then save up for the instrument rating. In an instance like that it made more sense for someone to follow their instrument rating with the Instrument Instructor rating as they were current on the material. Now, it is more likely people will take a "pro pilot" course, where it makes more sense to do the Instrument after the Private in order to build time economically in a financial sense while on their way to Commercial.

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The regulations are very often just plain weird, so i don't doubt that there is some way that will allow a person to be a CFI-I and not a basic CFI in some category, but who would actually HIRE a person with only that cert if they were going to do more than maybe be a platform instrument instructor????

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The regulations are very often just plain weird, so i don't doubt that there is some way that will allow a person to be a CFI-I and not a basic CFI in some category, but who would actually HIRE a person with only that cert if they were going to do more than maybe be a platform instrument instructor????

 

We've already demonstrated the how and why, and cited legal reference.

 

I have worked places where all I did was provide classroom and instrument instruction. Whereas I was not providing instruction toward a pilot certificate, but instead providing advanced instruction to already certificated airline students, there was no need for privileges other than instrument instruction. While I do hold the other ratings on my instructor certificate, they were useless in that assignment.

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Avbug, thats the same as being an IGI. That privilage is strictly just ground. Under the term "authorized instructor" an IGI is not one. Thus the difference. Being noone here speaking has been or is a CFI-I and NOT a CFI should show some lack of regulatory comprehension. Show me where one can write an endorsement as a CFII? We dont, we endorse as a CFI. I have shown, as you and Mike have as well, regulations that specifically state, to teach instrument flying one must have the instrument rating on their pilot certificate in that same catagory and class AND on their CFI certificate.

 

Read that line literally word for word. The regulation states it as it is. Its an addition to a certificate a pilot already has....that being the initial CFI.

 

My argument is clarified by further reference to this letter of interpretation.

 

Griffith - 2008

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2008/griffith%20-%20(2008)%20legal%20interpretation.pdf

Edited by WolftalonID
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WolftalonID,

 

The reference that you give does not state that an applicant for a CFI-instruments is required to be a CFI first.

 

This is just like Avbug, FP and others have stated that a Airplane CFI does not have to be CFI single engine airplane before being a multi engine instructor. CFI is the certificate governed by privileges and limitations. So, someone that attains a CFII is a "CFI" limited to instrument instruction.

 

I know pilots that attained their CFII prior to initial CFI. This was discussed and verified at Heli Expo some years ago by Barry Lloyd and others. The discussion originated from the fact that very few rotorcraft helicopter pilots have a recognizable amount of actual IFR flight experience and it was suggested for those dual rated pilots to attain an airplane CFII to get that experience. HAA employers would love to hire pilots with a few 100 hours spent in the clouds, even if it was as an airplane CFII.

 

If you go to FAA-S-8081-9D, IFR/CFI PTS and look at pages 1-iii & 1-iv, Examiner's checklist, you will note the areas tested and the first one is FOI. This need not be tested if the applicant already has a CFI or GI.

 

Note, I am not recommending this to be the path for career helicopter pilots! I do recommend Pvt. IFR, Comm. CFI, CFII, and ATP when possible.

 

Best Wishes,

 

Mike

Edited by Mikemv
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Avbug, thats the same as being an IGI. That privilage is strictly just ground. Under the term "authorized instructor" an IGI is not one. Thus the difference. Being noone here speaking has been or is a CFI-I and NOT a CFI should show some lack of regulatory comprehension. Show me where one can write an endorsement as a CFII? We dont, we endorse as a CFI. I have shown, as you and Mike have as well, regulations that specifically state, to teach instrument flying one must have the instrument rating on their pilot certificate in that same catagory and class AND on their CFI certificate.

 

Read that line literally word for word. The regulation states it as it is. Its an addition to a certificate a pilot already has....that being the initial CFI.

 

My argument is clarified by further reference to this letter of interpretation.

 

Griffith - 2008

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2008/griffith%20-%20(2008)%20legal%20interpretation.pdf

 

I'm really not sure what your'e trying to say here, or if you're trying to contradict me. If you agree with what I've said, then you're right. If you don't, then you're wrong.

 

Your point isn't clear.

 

A flight instructor certificate limited to instrument instruction privileges is NOT the same as holding a ground instructor certificate limited to instrument instruction privileges. They're different certificates; issued as separate, physically certificates, and are not the same. The privileges of each are not the same.

 

An instrument ground instructor certificate will not allow the user to perform flight instruction. A flight instructor certificate will allow the user to perform flight instruction. A ground instructor certificate does not require the holder to possess an instrument rating, or a pilot certificate. A flight instructor certificate requires the holder to possess a pilot certificate and an instrument rating on that pilot certificate.

 

As I stated at the outset, there is ONE flight instructor certificate. One. There is no such thing as a CFII who isn't a CFI. CFII is a slang term which means instrument privileges on the flight instructor certificate. If one holds a "CFII," one holds a flight instructor certificate. However, if one obtains the "CFII" first, one is limited in what one can teach as an instructor.

 

The Brooks letter which you cited addresses the issue of what certification is required by an authorized instructor in order to endorse for an instrument proficiency check (IPC), and specifically asks if an instrument ground instructor (IGI) can endorse for completion of an IPC. The letter states that the IGI cannot do that.

 

You appear to be under the impression that the letter states that "The flight proficiency check contains a flight portion and hence requires an authorized flight instructor" then the holder of an instructor certificate with only instrument privileges ("CFII") cannot perform the IPC. If this is what you believe or have taken from the letter, then you misunderstood the legal interpretation. That's not what it says. A CFII is an authorized flight instructor who holds instrument privileges on his or her flight instructor certificate.

 

Yes, an applicant may hold a flight instructor certificate limited to instructing instruments, without other privileges on his or her certificate. In plain slang English, that means one can become a "CFII" before obtaining other instructor privileges. In context of your cited legal reference, a CFII can do what an IGI cannot, which includes administering an IPC.

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And how exactly would that 8710 form look like....the one where the applicant is applying for a CFII and not yet being a CFI.

 

You say one is the same as the other but then you say one is limited.

 

I guess one can be an instrument pilot but not a private or commercial?

 

Same application. Does not make sence, and there is not one regulation that backs up your argument.

 

Yet every regulation that is in print backs up mine. Once a catagory and class is added into the 8710 form, it allows that pilot the privilage of that certificate. A certificate that says CFI on it covers all privilages applicable to that certificate and its limitations.

 

I have yet to see a CFI CERTIFICATE that says...limited to CFII only.

 

So If you say there is only one CFI certificate, then why do you also say there are two separate ones?

 

Please show me the regulation. Or better yet....write the chief counsel and lets see what happens?

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Mike I have read that step before in the requirements of testing. However, once issued, it opens the door to full privilage of the CFI certificate.

 

I am not saying no one has yet done this. However so, was it done according to the intended regulatory process.

 

Many people have slipped through cracks from human error in the chain of issuance. But to obtain the CFI-I as the initial, the full spectrum of a checkride must have been given, which then...also allows full teaching privilages.

 

Take for example the SFAR 73 endorsement to instruct. I know its a separate step, but often done simultaneously with the CFI-I checkride. Why? So that the pilot can not just give flight instruction, instrument instruction, but also in the R-44.

 

Guys I get the fact a CFI-I is a CFI.....thats not confussing anyone here. But to Say one would be limited to just instrument only....makes no logical connection.

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Without checking the regs, I'm gonna ask a question I just thought up: Is a platform instructor ticket also called a CFI even though heshe can't "FLIGHT" instruct? Oh..and...is there such a thing as some certificate that allows instrument subjects or maybe even specifies competence in "instrument instruction" for non-flight scenarios?? I know that a lot of places want folks hired as platform (academic) instructors and/or sim instructors to have a CFI and/or a CFI-I and even a Type Rating in the aircraft they will be teaching and those cover any questions of competence or suitability for duty in those lines of work....Does the FAA even address this?

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There are non flying certificates like the Advanced Ground Instructor (AGI) or something like that. It has its own separate card... I can't tell you what it says because I've never carried mine, I just put it in the filing cabinet after it arrived. TBH, I'm not exactly sure why I even got it, I think it was a step in my quest for the atp or gold seal CFI

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And how exactly would that 8710 form look like....the one where the applicant is applying for a CFII and not yet being a CFI.

 

You say one is the same as the other but then you say one is limited.

 

I guess one can be an instrument pilot but not a private or commercial?

 

Same application. Does not make sence, and there is not one regulation that backs up your argument.

 

Yet every regulation that is in print backs up mine. Once a catagory and class is added into the 8710 form, it allows that pilot the privilage of that certificate. A certificate that says CFI on it covers all privilages applicable to that certificate and its limitations.

 

I have yet to see a CFI CERTIFICATE that says...limited to CFII only.

 

So If you say there is only one CFI certificate, then why do you also say there are two separate ones?

 

Please show me the regulation. Or better yet....write the chief counsel and lets see what happens?

 

You've read the thread and the referenced legal interpretations that spell it out for you, and really don't understand?

 

I did not say there are two separate flight instructor certificates.

 

I did show you the chief legal counsel interpretation. Did you not read the thread? Did you not read the Grayson letter?

 

It's sense. Not sence.

 

There is only one flight instructor certificate issued by the FAA. One. Not two.

 

A number of ratings may be placed on the instructor certificate. Simply holding a flight instructor certificate does not entitle one to act as an authorized instructor in any capacity. One must also hold the appropriate ratings on one's instructor certificate (and pilot certificate) in order to act as an authorized instructor.

 

"CFI" and "CFII" both refer to the SAME flight instructor certificate. They're slang terms that contribute to misunderstanding in the context of this thread. The former, "CFI" implies the common use of the term, which is an instructor certificate: in order for that certificate to be valid, it must hold ratings for various privileges; airplane, helicopter, etc.

 

"CFII" is slang and usually taken to mean instrument privileges on a flight instructor certificate. It does NOT imply or mean a separate certificate. It is nothing more than a reference to one rating and privilege which may be placed on a flight instructor certificate.

 

There is no such thing as simply "CFI," regardless of it's common slang use. In order for a flight instructor certificate to be valid it must hold some rating, whether it's single engine airplane, or rotorcraft helicopter. One can only instruct in the category or class applicable to the privilege cited on the certificate.

 

One may hold a flight instructor certificate which has as it's only privilege instrument-airplane or instrument-helicopter. One may earn that privilege as the initial practical test for flight instructor, and hold that as the only rating on the flight instructor certificate. In such a case, one is a valid flight instructor, but the only privilege one has with regarding to acting as an authorized instructor is that which is cited on the flight instructor certificate; instrument instruction in airplanes or helicopters (or instrument-powered lift).

 

14 CFR 61.5( c ) spells out the ratings which may be placed on the flight instructor certificate:

 

( c ) The following ratings are placed on a flight instructor certificate when an applicant satisfactorily accomplishes the training and certification requirements for the rating sought:

(1) Aircraft category ratings—

(i) Airplane.

(ii) Rotorcraft.

(iii) Glider.

(iv) Powered-lift.

(2) Airplane class ratings—

(i) Single-engine.

(ii) Multiengine.

(3) Rotorcraft class ratings—

(i) Helicopter.

(ii) Gyroplane.

(4) Instrument ratings—

(i) Instrument—Airplane.

(ii) Instrument—Helicopter.

(iii) Instrument—Powered-lift.

One does not need to hold all of those ratings, but one must hold at least one of them. One may hold a flight instructor certificate with only an instrument rating, such as instrument-helicopter. In such a case, one is restricted to providing authorized instruction within the scope of 91.195( b ), which specifically states:

( 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.

The holder of a flight instructor certificate bearing only the privilege Instrument-Helicopter may only provide instruction for the issuance of an instrument rating (or proficiency check) in a helicopter, and may not provide training toward the private, commercial, or ATP ratings, as those privileges are not included on the flight instructor certificate.

Which part do you not understand?

Edited by avbug
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