Who can provide training in a sim?

J

Josh

Well-Known Member
So, we've got a Elite based sim here. Got the letter saying what the unit can be used for in the FAA approval.

One of our CFIs doesn't have the CFII rating.

I'm trying to figure out of an IGI can give training in the sim, as an authorized instructor? So, he could just do a written test then, and be an IGI who could provide sim instruction, since that training is done on the ground.

It isn't flight time, so I believe that works.

From 61.215:
(c) A person who holds an instrument ground instructor rating is authorized to provide:
(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;
(2) Ground training required for an instrument proficiency check; and
(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.


Does the sim time fall under subsection 2 above? Any comments?

Thanks,
Josh
 
Josh said:
So, we've got a Elite based sim here. Got the letter saying what the unit can be used for in the FAA approval.

One of our CFIs doesn't have the CFII rating.

I'm trying to figure out of an IGI can give training in the sim, as an authorized instructor? So, he could just do a written test then, and be an IGI who could provide sim instruction, since that training is done on the ground.

It isn't flight time, so I believe that works.

From 61.215:
(c) A person who holds an instrument ground instructor rating is authorized to provide:
(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;
(2) Ground training required for an instrument proficiency check; and
(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.


Does the sim time fall under subsection 2 above? Any comments?

Thanks,
Josh
Click to expand...

If he is a CFI, yes. He just needs 15 hours under 61 from a double-eye, the rest can come from an eye.

Edit: From what I understand, I could be wrong, an IGI can not do sim instruction.
 
Douglas said:
If he is a CFI, yes. He just needs 15 hours under 61 from a double-eye, the rest can come from an eye.

Edit: From what I understand, I could be wrong, an IGI can not do sim instruction.
Click to expand...

I agree with the first part.

I am unsure about the second, but I suspect you are right douglas, I would imagine the IGI can not do sim instruction, at least not for the purposes of a rating.
 
I kind of think that sim instruction is still flight training, though I could be wrong. If I am correct though, you would need at least a cfi to provide sim training. Now there is nothing stopping an IGI from providing sim training for just knowledge sake, but the student could not count that time towards the issuance of a rating or certificate requiring instrument time.

Again I could be wrong on this.

TO the FARS I GO!
 
61.51.h

(h) Logging training time. (1) A person may log training time when that person receives training from an authorized instructor in an aircraft, flight simulator, or flight training device.

My assumption is that since it is dealing with logging flight instruction it would need to come from a flight instructor...that's the authorized instructor.


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

again with the authorized instructor.

Anyone no where to find anything telling me how I can log sim time as total time?
 
Josh said:
Does the sim time fall under subsection 2 above? Any comments?
Click to expand...

Reference 61.1 for the definition of "Ground Training":
(8) Ground training means that training, other than flight training, received from an authorized instructor.
​
Clearly, training in the FTD is not flight training, which means it must be ground training.
 
tgrayson said:
Reference 61.1 for the definition of "Ground Training":
(8) Ground training means that training, other than flight training, received from an authorized instructor.
​
Clearly, training in the FTD is not flight training, which means it must be ground training.
Click to expand...
hmm, so does that mean all the people I work with who are having their students log it as total time are full of ca ca? Not being a smart ass...this is sort of a real murky area for me.
 
poser765 said:
hmm, so does that mean all the people I work with who are having their students log it as total time are full of ca ca? Not being a smart ass...this is sort of a real murky area for me.
Click to expand...

The reason it's murky is that there is no such thing as "total time". The FAA only defines two types of time that are similar: pilot time and flight time. FTD time is pilot time, but it's not flight time.

The question is which of these two types of time do you assume your total time column represents? If you construe it to be pilot time, then it's fine to log the FTD time there; if you consider it to be equivalent to flight time, then FTD time doesn't be long there.
 
tgrayson said:
The reason it's murky is that there is no such thing as "total time". The FAA only defines two types of time that are similar: pilot time and flight time. FTD time is pilot time, but it's not flight time.

The question is which of these two types of time do you assume your total time column represents? If you construe it to be pilot time, then it's fine to log the FTD time there; if you consider it to be equivalent to flight time, then FTD time doesn't be long there.
Click to expand...
So it's a log it as you feel it sort of deal?

Reference 61.1 for the definition of "Ground Training":
(8) Ground training means that training, other than flight training, received from an authorized instructor.
Clearly, training in the FTD is not flight training, which means it must be ground training.
Click to expand...

(c) A person who holds an instrument ground instructor rating is authorized to provide:

(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;

(2) Ground training required for an instrument proficiency check; and

(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.

No where does it say that an IGI can provide training to meet the aeronautical experience for an instrument rating. Where you trying to say a few posts back that you could log instrument time in a sim with an IGI to meet the requirements in part 61 for an instrument rating?
 
poser765 said:
So it's a log it as you feel it sort of deal?
Click to expand...

Well, I'd say log it with the understanding of what you're logging. Hopefully, you will make this determination using something more rational than a feeling.

No where does it say that an IGI can provide training to meet the aeronautical experience for an instrument rating.
Click to expand...
Agreed.

Where you trying to say a few posts back that you could log instrument time in a sim with an IGI to meet the requirements in part 61 for an instrument rating?
Click to expand...
No, the context as I understood it was for an instrument proficiency check, since that's what the OP referenced in the regulations.
 
Ok thanks for clarifying...my mix up. Yeah I don't let my kids log sim time as total time. Some of the other instructors do. I figure it's only a few hours anyway and why risk MAYBE having to explain it to someone someday.
 
tgrayson said:
Well, I'd say log it with the understanding of what you're logging.
Click to expand...

Just my 02, I put () around any sim time in my log book in the total time column, that way I always know what it is without having to scan other columns.
 
Ok, so my question after this discussion remains.

Can a CFI sit there, and provide "ground training" which in this case is on the ground, via the sim?

Or does that CFI not fit the definition of authorized instructor, since they are not a CFII?

I think a lot of the problem, is the FAA does not clearly designate who is "authorized" in this case (and in many other cases quite frankly).

My purpose here, is to have the CFI sit there and do an IPC for me, as I'm not current, and need one (and can't provide the "authorized instructor" as myself for myself :insane: ).

And, if someone wanted to log a bit of extra time (beyond the 15 for the rating) in the sim, could this instructor provide that?

I think those are two different issues, but they both hinge on what "authorized" means in this case.

Thanks for the continued discussion,
Josh
 
Josh said:
Ok, so my question after this discussion remains.

Can a CFI sit there, and provide "ground training" which in this case is on the ground, via the sim?

Or does that CFI not fit the definition of authorized instructor, since they are not a CFII?

I think a lot of the problem, is the FAA does not clearly designate who is "authorized" in this case (and in many other cases quite frankly).

My purpose here, is to have the CFI sit there and do an IPC for me, as I'm not current, and need one (and can't provide the "authorized instructor" as myself for myself :insane: ).

And, if someone wanted to log a bit of extra time (beyond the 15 for the rating) in the sim, could this instructor provide that?

I think those are two different issues, but they both hinge on what "authorized" means in this case.

Thanks for the continued discussion,
Josh
Click to expand...
If I remember from the old part 61 FAQ a double Eye IS required in order to give an IPC. so if your other instructor is not a CFI-I then he may not give you an IPC endorsement.

Yes a cfi (single Eye) can provide simstruction. However, that time may NOT be used towards the 61.65(d)(2)(i) 15 hours of instrument instruction.
 
Josh said:
My purpose here, is to have the CFI sit there and do an IPC for me, as I'm not current, and need one (and can't provide the "authorized instructor" as myself for myself :insane: ).
Click to expand...

That was not included in your original question.

and no, he can't give you an IPC.

Poser has it right.
 
TheRestoftheStory said:
www.aerodynamicaviation.com/documents/pt61FAQ.doc


There are a lot of misconceptions in this thread. Read the information at the link posted above.

.... and before someone comes up with the old line about the FAA pulling John Lynch's FAQs, remember, the reason wasn't because they were in any way in error. It was for purely internal reasons.
Click to expand...
You mean the number of times he had to be corrected by the FAA Chiref counsel's office had nothing to do with it?
 
On page 168 of that old FAQ:

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 § 61.193 (Flight Instructor Privileges) and § 61.195 (Flight Instructor Limitations). The only reference to a requirement for a CFII that I can find is in § 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 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}

How does this apply to the "authorized instructor" question that is at the root of all this. Do I believe this FAQ?

Thanks,
Josh
 
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