Does an IPC count as a BFR?

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Richard Kaplan, CFII

www.flyimc.com
"Michael" wrote in message
om...
"Richard Kaplan" wrote
Related to this question of earning a CFII but not a CFI, I have not
done
what follows and I am not sure the regs make sense in this area, but
from a
strictly legal perspective I believe I can give an instrument
proficiency
check in a multi-engine airplane even though I am not a multi-engine
pilot.
My certificates are Commercial Pilot (ASEL + Instrument Airplane) and
CFI
(Airplane Single Engine + Instrument Airplane).

I do not believe this is correct.

61.195 Flight instructor limitations and qualifications.
A person who holds a flight instructor certificate is subject to the
following
limitations:
(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

For purposes of an instructor certificate, there are two classes
within the airplane category - ASE and AME. For purposes of a pilot
certificate, there are four classes within the airplane category -
ASEL, ASES, AMEL, and AMES. Thus, since you do not have a pilot
certificate with airplane category and multiengine land class (AMEL)
rating, I do not believe you could legally provide flight training in
a multiengine airplane.

Perhaps somewhat more practically speaking, I see no reason why I could
not
sign off an IPC done with my simulator (Level 3 FTD) in twin-engine mode
since I do not need to be PIC to "create" IMC in the simulator and my
CFI
instrument privileges refer to instrument airplane and not specifically
to
single- or multi-engine airplanes.

You may be right, but this would be meaningless.

61.57(d)(1) The instrument proficiency check must be --
(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight training
device
that is representative of the aircraft category;

Note that there is no requirement for the simulator to be
representative of the class of aircraft, only the category. There is
no requirement for a multiengine pilot to take his IPC in a
multiengine airplane - any airplane will do. I see no reason why you
couldn't do this, but I also see no reason why anyone would ever want
to. It would have no regulatory purpose, and if you lack multinegine
experience it would have no practical purpose either.

Indeed, extending this further, my understanding is that a non-pilot
could
pass the written exam to become an Instrument Ground Instructor and then
without ever setting foot in an airplane he could do an IPC in the
simulator
(again a Level 3 FTD) and this non-pilot would have the authority to
sign
off the pilot of a cabin-class twin as safe to fly in IMC.

Maybe, but I don't see that as obvious.

61.215 Ground instructor privileges.
(c) A person who holds an instrument ground instructor rating is
authorized to
provide:
(2) Ground training required for an instrument proficiency check;

61.57(d)(2) The instrument proficiency check must be given by --
(iv) An authorized instructor;

So the question would be - is the sim training ground or flight
training? If it's ground training, then an IGI would be an authorized
instructor and this would be legal. If it's flight training, then he
would not be authorized and it wouldn't be legal.

Michael