CFI logging instrument time

On Wed, 29 Oct 2003 16:13:45 -0500, "Barry" wrote:

One can argue that a CFI without the CFII is not authorized to give
instrument flight instruction,

Nah. A CFI without the CFII is not authorized to give instrument
flight instruction that counts toward the "instrument training" or
"instrument flight instruction" that may be required for a
certificate, rating, or currency.

The restriction is on what may be counted for these purposes, on to n
giving instrument instruction.

Mark Kolber
APA/Denver, Colorado
www.midlifeflight.com
======================
email? Remove ".no.spam"

"Barry" wrote in message
...
| A CFI with airplane single-engine rating but not instrument-airplane (not
a
| CFII) gives flight instruction to a private pilot. Part of the flight is
in
| the clouds, with the private pilot flying. Can the CFI log instrument
time
| under FAR 61.51(g)(2):
|
| "An authorized instructor may log instrument time when conducting
instrument
| flight instruction in actual instrument flight conditions." ?
|

A CFI may give instrument flight instruction, but that flight instruction
cannot count for the instrument rating. The CFI in your case may log
instrument flight time.

"john price" wrote in message ...
Barry first of all, the scenario is not possible, since to be a single
engine CFI, I believe you need to have a single engine instrument
rating... If somehow, the instructor is not instrument rated in the
airplane, he has no business being in IFR conditions...

We're talking about instrument ratings on his INSTRUCTOR certificate.
You know, II.

"C J Campbell" wrote in message ...



A CFI may give instrument flight instruction, but that flight instruction
cannot count for the instrument rating. The CFI in your case may log
instrument flight time.

Finally....an answer to the question.

A CFI may give instrument flight instruction, but that flight
instruction cannot count for the instrument rating. The CFI
in your case may log instrument flight time.

Finally....an answer to the question.


But is this just a personal interpretation (which agrees with my own
interpretation), or does C.J. have a reference or precedent?

Barry

"Barry" wrote in message
...
| A CFI may give instrument flight instruction, but that flight
| instruction cannot count for the instrument rating. The CFI
| in your case may log instrument flight time.
|
| Finally....an answer to the question.
|
|
| But is this just a personal interpretation (which agrees with my own
| interpretation), or does C.J. have a reference or precedent?
|

FAR 61.196 c. The CFII is needed only for giving instruction for an
instrument rating or for a type rating not limited to VFR. There is no
prohibition against a CFI giving any other instrument training, including an
instrument proficiency check under FAR 61.57 (probably a loophole in the
regs that should be fixed). Under 61.51(g)(2) a flight instructor may log
instrument flight time if giving instruction in instrument flight
conditions. There is no provision limiting this logging of time only to
CFIIs.

"Ron Natalie" wrote in message om...
"C J Campbell" wrote in message ...



A CFI may give instrument flight instruction, but that flight instruction
cannot count for the instrument rating. The CFI in your case may log
instrument flight time.

Finally....an answer to the question.


and a mostly correct answer, with one small nit -- the instrument flight
instruction cannot count as part of the 15 hours required to be given
under 61.65.d.2.i-iii, but it certainly can count as part of the 40 hours
of actual or simulated instrument time required by 61.65.d.2 (before the
subparagraphs) -- assuming the non-instrument rated pilot was sole
manipulator of the controls.

mho,

g_a

FAR 61.196 c. The CFII is needed only for giving instruction for an
instrument rating or for a type rating not limited to VFR. There is no
prohibition against a CFI giving any other instrument training, including an
instrument proficiency check under FAR 61.57 (probably a loophole in the
regs that should be fixed). Under 61.51(g)(2) a flight instructor may log
instrument flight time if giving instruction in instrument flight
conditions. There is no provision limiting this logging of time only to
CFIIs.


This is your interpretation. Personally, I agree, but when someone asked me
this question and I started looking into it a little more, I realized that
other interpretations are possible.

FAR 61.51(g)(2), which I started with in my original post, states:

"An authorized instructor may log instrument time when conducting instrument
flight instruction in actual instrument flight conditions."

Note that it says "instrument flight instruction," not just "flight
instruction". FAR 61.1 unfortunately has no definition for "instrument
flight instruction," but it does define "instrument training" as "that time
in which instrument training is received from an authorized instructor under
actual or simulated instrument conditions." Is a non-CFII an "authorized
instructor" for instrument flight instruction? I couldn't find this exact
question in the FAA's Part 61 FAQ
(http://www.faa.gov/avr/afs/afs800/docs/pt61FAQ.doc , a 2 MB file), but
related issues are addressed there. In the section dealing with Commercial
Pilot requirements (page 325, Q&A-60), the FAQ states that only a CFII can
provide the instrument training required for the Commercial:

"Ref. § 61.1(b)(10); Yes, the instrument training required by § 61.129
requires a CFII (with the appropriate aircraft and instrument rating on the
CFI certificate) to provide the flight training."

On page 381 (Q&A-283), the FAQ draws a distinction between "real instrument
training" and the training given to student pilots:

"For years, the FAA has differentiated between the kind of training
described in § 61.109(a)(3) [i.e., “... 3 hours of flight training in a
single-engine airplane on the control and maneuvering of an airplane solely
by reference to instruments...”] and REAL “instrument training.” Therefore
.... a CFI-ASE can give the 3 hours of Private Pilot flight training on the
control and maneuvering of an airplane solely by reference to instruments
[i.e., §61.109(a)(3)] because the training is not REAL “instrument
training.”

So one could argue that a CFI (non-CFII) who instructs a student pilot in
the clouds could NOT log the instrument time, because he's not
conducting "instrument training". But what if the same CFI gives the same
flight instruction to a private pilot? It's not clear.

By the way, page 136 (Q&A-315) of the FAQ addresses your point about a CFI
(non-CFII) being authorized to conduct an IPC (no surprise, the FAA says a
CFII is required).

I should add that I disagree with some of the answers in the FAQ, and that
the FAQ includes a disclaimer stating that the contents are not legal
interpretations.

Barry

"Barry" wrote in message
...
| FAR 61.196 c. The CFII is needed only for giving instruction for an
| instrument rating or for a type rating not limited to VFR. There is no
| prohibition against a CFI giving any other instrument training,
including an
| instrument proficiency check under FAR 61.57 (probably a loophole in the
| regs that should be fixed). Under 61.51(g)(2) a flight instructor may
log
| instrument flight time if giving instruction in instrument flight
| conditions. There is no provision limiting this logging of time only to
| CFIIs.
|
|
| This is your interpretation. Personally, I agree, but when someone asked
me
| this question and I started looking into it a little more, I realized that
| other interpretations are possible.
|
| FAR 61.51(g)(2), which I started with in my original post, states:
|
| "An authorized instructor may log instrument time when conducting
instrument
| flight instruction in actual instrument flight conditions."
|
| Note that it says "instrument flight instruction," not just "flight
| instruction". FAR 61.1 unfortunately has no definition for "instrument
| flight instruction," but it does define "instrument training" as "that
time
| in which instrument training is received from an authorized instructor
under
| actual or simulated instrument conditions." Is a non-CFII an "authorized
| instructor" for instrument flight instruction?

Of course he is. As I pointed out, a non-CFII may give the required
instrument instruction to student pilots as well as possibly give instrument
proficiency checks.

However, the FAQ to part 61 does say that you have to be a CFII to give
instrument proficiency checks. Lynch claims that it is a requirement in
61.193, but the argument looks excessively weak:

QUESTION: Is it true that a CFI giving an endorsement for an Instrument
Proficiency Check must have an instrument rating (CFII) on his/her flight
instructor certificate? I can't seem to find anything in the current Part 61
that states that an Instrument Proficiency Check endorsement requires a
CFII. The §61.57(d)(2)(iv) requires an "authorized instructor". The
definition of "authorized instructor" now seems to come from FAR 61.193
(Flight Instructor Privileges) and FAR 61.195 (Flight Instructor
Limitations). The only reference to a requirement for a CFII that I can find
is in FAR 61.195(c).

ANSWER: Ref. §61.57(d)(2)(iv) and §61.193; A flight instructor who performs
an instrument proficiency check, as required by §61.57(d), must hold the
appropriate instrument rating for the category and class of aircraft that
the instrument proficiency check is being conducted in. As per §61.193, it
states in pertinent part, ". . . A person who holds a flight instructor
certificate is authorized within the limitations of that person's flight
instructor certificate and ratings to give training and endorsements that
are required for, and relate to:

* * * * *

(f) An instrument rating;

A flight instructor who does not hold an instrument rating on their flight
instructor certificate that is appropriate to the category and class of
aircraft that the instrument proficiency check is being conducted in is NOT
authorized to conduct the instrument proficiency check.

The term "authorized instructor" was intentionally used in §61.57(d) because
authorization to conduct an instrument proficiency check is not limited to a
CFII. A Ground Instructor Certificate - Instrument Rating is also an
"authorized instructor" and is authorized to give the instrument proficiency
check in an approved flight training device. Also, a Part 142 training
center instructor, who may or may not hold any certificate or ratings, can
be an "authorized instructor" who may give the instrument proficiency check
that is performed under an approved Part 142 training program in an approved
flight simulator, in accordance with a Part 142 approved training program.
Another example, a pilot who holds a Letter of Operational Authority (LOOA)
may give the endorsements for the instrument proficiency check to a holder
of a Letter of Authorization (LOA).) Holders of an LOOA give training for
the endorsement for the Letter of Authorization (LOA) allowing a pilot to
act as pilot in command in surplus military turbine or piston powered
airplane, in accordance with FAA Order 8700.1, Chapter 32. However, in this
case, the holder’s Letter of Operational Authority (LOOA) must specifically
state this authority to give the endorsements for the instrument proficiency
check. And so the rulemaking team that drafted the new Part 61

111FAQs Part 61 With Chg #18, 12/05/2002 All Q&A’s from #1 through #540

decided on merely stating . . . An authorized flight instructor . . ." But
notice in §61.57(d)(2)(v), we also included ". . . A person approved by the
Administrator to conduct instrument practical tests."

{Q&A-315}

"C J Campbell" wrote in message ...

However, the FAQ to part 61 does say that you have to be a CFII to give
instrument proficiency checks. Lynch claims that it is a requirement in
61.193, but the argument looks excessively weak:

It is excessively weak because the FAR's don't support what he is saying.