Instructing with an ATP

Hello all

I hear a lot of my buds say that FAR Part 61 allows a pilot holding an
ATP to instruct another pilot towards a qualification or a rating in
an airplane without having a CFI ticket. I say that the ATP-holder
can only do that if he's doing it as part of an air transportation
provider (Part 121, 135, etc).

Who knows the answer? Thanks

"T" Tung

"\"T\" Tung" wrote
I hear a lot of my buds say that FAR Part 61 allows a pilot
holding an ATP to instruct another pilot towards a qualification
or a rating in an airplane without having a CFI ticket. I say
that the ATP-holder can only do that if he's doing it as part of
an air transportation provider (Part 121, 135, etc).

You are correct in your understanding.

Section 61.167: Privileges

b) An airline transport pilot may instruct --

(1) 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;

(3) Only as provided in this section, 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 he or she is rated.

Bob Moore ATP/CFI

""T" Tung" wrote in message
...
I hear a lot of my buds say that FAR Part 61 allows a pilot holding an
ATP to instruct another pilot towards a qualification or a rating in
an airplane without having a CFI ticket. I say that the ATP-holder
can only do that if he's doing it as part of an air transportation
provider (Part 121, 135, etc).

Who knows the answer? Thanks

The answer is found in Part 61.167. I don't see any way to interpret that
to allow an ATP to provide instruction to just anyone. It's pretty clear
about limiting an ATP's instructional privileges to pilots who are "in air
transportation service".

Now, that said, that just means your interpretation is closer to the truth.
I don't see anything in the regulation that requires the training to be *as
part of* an air transportation provider. Simply that it can only be done
for pilots who are in air transportation service.

Maybe there's an FAA legal counsel interpretation around somewhere that
further limits the ATP's instructional privileges, but at face value, it
appears that an ATP without a flight instructor certificate could still
perform a BFR (for example) for a fellow ATP working as an airline pilot.

Pete

"Peter Duniho" wrote in message

.
I don't see anything in the regulation that requires the training to be
*as
part of* an air transportation provider. Simply that it can only be done
for pilots who are in air transportation service.

Maybe there's an FAA legal counsel interpretation around somewhere that
further limits the ATP's instructional privileges, but at face value, it
appears that an ATP without a flight instructor certificate could still
perform a BFR (for example) for a fellow ATP working as an airline pilot.

Pete, IMO you've misinterpreted the sentence structure.

Where the reg says
"...b) An airline transport pilot may instruct...other pilots in air
transportation service in aircraft of the category, class, and type, as
applicable, for which the airline ....."
I believe the phrase "...in air transportation service..." is the object of
the verb instruct, rather than an adjectival phrase modifying the noun
"pilots", in much the same manner that you might say "I'm giving him
instruction in mathematics".

My interpretation was always that an ATP can instruct other pilots in the
ups and downs (as it were) of air transportation. IOW, "I'm not teaching
you to fly, I'm teaching you to fly this aircraft professionally and
responsibly according to the policies and procedures of our employer, the
Certificate Holder." One gray area we always used to debate as CFIs was
whether an ATP without a CFI can give training to another pilot who is not
employed in air transportation in preparation for that pilot's ATP
checkride. I can't recall what we may have concluded, but it was all 30
years ago, so it is probably different now anyway. :-)

JG

"John Gaquin" wrote in message
...
Pete, IMO you've misinterpreted the sentence structure.

Could be. Consider, however...

* At best, the wording is ambiguous and without some other FAA reference,
either interpretation could be correct

* There's no official FAA "in air transportation service" rating or
endorsement. There is no prohibition against ANY pilot giving any other
pilot instruction in any manner of topics, even those related to flying and
operations. The flight instructor privileges are required for situations
where the FAA requires a certain amount and/or kind of instruction. So it
begs the question, if all that the FAA is allowing an ATP to do is to "teach
the ropes" to new airline crew, why do they need the regulation at all?
It's not like the ATP pilot would have been prohibited from doing exactly
that in any case.

[...] One gray area we always used to debate as CFIs was
whether an ATP without a CFI can give training to another pilot who is not
employed in air transportation in preparation for that pilot's ATP
checkride.

Well, that seems to be the whole point. Right? Whatever the conclusion, it
would illustrate the correct interpretation of 61.167. If the ATP without a
CFI can give such training, then the regulation is parsed as you suggest.
If the ATP without a CFI may not give such training, then the regulation is
parsed as I suggest.

Of course, even with that illustration, there would still be open questions.
But it seems like that illustration does exactly show the ambiguity.

Regardless, I think the original poster obviously has a more correct answer
than his "buds".

Pete

On 2003-12-11 19:16:51 -0800, "John Gaquin" said:

One gray area we always used to debate as CFIs was
whether an ATP without a CFI can give training to another pilot who is not
employed in air transportation in preparation for that pilot's ATP
checkride.

I don't see the gray. There isn't any instruction required for an ATP. You don't
need an instructor's signature on the 8710.

--
Larry Fransson
Seattle, WA

"Peter Duniho" wrote in message


... if all that the FAA is allowing an ATP to do is to "teach
the ropes" to new airline crew, why do they need the regulation at all?
It's not like the ATP pilot would have been prohibited from doing exactly
that in any case.

I think it is there simply to clarify some professional scenarios. For
example, it is clear that within the scope of this regulation, an ATP
(without CFI) can act as a simulator instructor of record for his airline,
providing required initial, upgrade, or recurrent training in a particular
aircraft. Without the above reg, a question could be raised.



Regardless, I think the original poster obviously has a more correct
answer
than his "buds".

Agreed.

JG

"Larry Fransson" wrote in message

I don't see the gray. There isn't any instruction required for an ATP.
You don't
need an instructor's signature on the 8710.

True, and in point of fact, I don't think any of us ever encountered any
circumstance that we imagined. This was rainy day hangar talk, where all
manner of unlikely scenarios are promulgated for debate. Fact is, I don't
think I know anyone who got a multi-engine ATP on his own -- it was too
expensive, and we were all hired by airlines who ultimately wound up footing
the bill. I did once encounter a retired AF fighter pilot who specifically
wanted to get a single-engine ATP.

JG

"John Gaquin" wrote
Fact is, I don't think I know anyone who got a multi-engine
ATP on his own -- it was too expensive, and we were all hired
by airlines who ultimately wound up footing the bill. I did
once encounter a retired AF fighter pilot who specifically
wanted to get a single-engine ATP.

Strange things do happen. When first hired by PanAm in 1967,
they gave all of the new-hires who qualified with the required
number of flight hours, the 3-day ATP knowledge test course and
sent us off to the FAA for the test. This was done because at
that time, FE time didn't count toward the ATP requirements, and
the 1200 hours had to be "recent". Company policy was that all
SICs hold an ATP certificate and be type rated in the aircraft.
This was due to the long range relief pilot requirements. It was
possible then to be upgraded to SIC without enough recent pilot
hours to qualify for the ATP written, however once passed, the
written was good for as long as you were employed by that airline
and were receiving recurrent training.

Three years later, when the furlough notices were issued, I saw
that my ATP written would now expire because of my employment
status. I rented a well equipped PA-28-140 and flew across the
Delaware river to the FAA office (GADO at that time) at the North
Philadelphia Airport and requested an ATP practical test. The test
was administered as a couple of extra approaches at the end of an
Instrument Instructor practical test.

This "ATP Certificate" would, in a couple of years be instrumental
in my being empolyed by Air Florida as a B-707 PIC when the three
pilots who had been employed as PICs failed to complete the B-707
type rating program and no-one else in training held an ATP of any
kind.

A few years later, during another PanAm furlough, I managed a Part
141 Flight Training Program (Burnside-Ott at Opa-Locka) that trained
B-707 and B-727 FEs and ATPs. This was a very profitable
business around 1976 due to all of the GI Bill money floating around.
Although all of my instructors held ATPs and were type-rated in the
aircraft, the FAA insisted that they also hold FAA Flight Instructor
certificates since the Part 141 school was not the "air
transportation service".

Bob Moore

On Thu, 11 Dec 2003 19:43:02 -0600, "\"T\" Tung"
wrote:

Thanks for the response!!!!

"T"