CFII privileges and limitations

J

Jordan Delaney

Well-Known Member
Hello all,

I have a question in regards to doing the CFII as the initial. I've read quite a few posts on this forum about doing so, and I understand that a CFII is not permitted to conduct flight training in an airplane without having their CFI or MEI. However, I can't figure out then what are the privileges and limitations of a CFII if they do not have their CFI or MEI.

I'm hoping some of you have gone through their CFII checkride as their initial and can provide some insight. My concern is that the FAA examiner will ask what my privileges and limitations are as a CFII and honestly I can not find a clear cut answer from the regs. It is also very unclear whether a CFII can conduct training in an FTD/ATD.

Thanks in advance for your help :)
 
When preparing for a CFI ride, you have to start ignoring what you've been told about the regs and start referencing the regs directly. As a CFII you are a flight instructor. So reference 61.195 - flight instructor limitations and read it. Start at the beginning, don't skim.

Just to make things easy I'll post it:
------------
§61.195 Flight instructor limitations and qualifications.

A person who holds a flight instruc- tor 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 in- structor certificate with the applicable category and class rating; and
(2) If appropriate, a type rating.
-----------
If you don't hold a flight instructor certificate with the appropriate category and class ratings, you cannot give flight instruction. Period.
 
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I passed my CFI-I as my initial about a week ago. Taking my CFI-A add on Thursday. All the above is correct (obviously) but sim instruction doesn't and shouldn't need a CFI-A for instrument instruction. At least that's what I have been told for what I can give instruction in right now until I get my add on. I can only do sim lessons or ground. Haven't found any reg stating otherwise for FTD/ATD.

My examiner didn't bother bringing this up in the checkride if they know you're getting your CFI-A or not. Most places won't even hire you with just a CFI-I anyways. I did get asked "what endorsements can I give as an instrument instructor" which I listed the ones from AC61-65E Chg 1 and IPC's but I kept it bare and simple answer like that. If you don't open the can of worms as far as "well technically since I'm just a CFI-I" then you should be fine. If he pursues to ask you, now you have your answer.;)

Just keep it simple and don't over think your answer on the xride. That's what gets people digging.
 
tcco94 said:
I passed my CFI-I as my initial about a week ago. Taking my CFI-A add on Thursday. All the above is correct (obviously) but sim instruction doesn't and shouldn't need a CFI-A for instrument instruction. At least that's what I have been told for what I can give instruction in right now until I get my add on. I can only do sim lessons or ground. Haven't found any reg stating otherwise for FTD/ATD..
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I won't argue with you about the "should" but, with respect to the "doesn't", you need to read the 2012 Beard Letter (which hold some future hope out, although I haven't seen anything)
 
Just get all the ratings. I love how people like to hold up technicalities. You're really gonna be earning a lot just on sim work. Like can a non multi CFI give instrument training in a twin. Technically yes but why would they?!
 
Also can a CFI give instruction with no medical. Yes if the student is pic. Again why would they, it's legal but not prudent. CFI should always be current and considered PIC, and any exceptions should be red flagged and treated with caution.
 
MidlifeFlyer said:
I won't argue with you about the "should" but, with respect to the "doesn't", you need to read the 2012 Beard Letter (which hold some future hope out, although I haven't seen anything)
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Well I stand corrected. Looks like the FAA could use a gotcha for that. I was told that I could be hired and work sims and ground until I get my CFI-A, but I guess not. That's the gem of legal interpretations. It would be easier I think the clarify that in the regs but that could be said for a lot of things. Either way thanks for finding that and making me aware.

Like @ahw01 said, just plan on getting both. I only took my initial as CFII because I was more ready for that and felt more comfortable because it was the initial. The day after I was back to the books for my CFI-A because even though I knew I was an instructor, I pretty much felt like I couldn't do anything. Don't cut corners, just do it the right way and you'll be fine down the road. :)
 
tcco94 said:
Well I stand corrected. Looks like the FAA could use a gotcha for that. I was told that I could be hired and work sims and ground until I get my CFI-A, but I guess not. That's the gem of legal interpretations. It would be easier I think the clarify that in the regs but that could be said for a lot of things. Either way thanks for finding that and making me aware.
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A lot of folks thought the requirement wouldn't apply to a sim. After all, even the best device is not an "aircraft" as defined in the FAR and once we get below the below the level of Part 142-style full motionsims that emulate specific types, they tend to be very generic. IMO they are really nothing more than procedure trainers and there really isn't too much reason for a commercial pilot with a CFI certificate and an instrument airplane rating to not be able to teach in one. You can almost detect a bit of apology between the lines.
 
You have cfi airplane single engine and CFI instrument, but not MEI. If the student is multi rated and the instruction is for instrument rating only, you can instruct.
 
ahw01 said:
You have cfi airplane single engine and CFI instrument, but not MEI. If the student is multi rated and the instruction is for instrument rating only, you can instruct.
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No you can't. Read the LOI from the FAA Chief Counsel.
 
Blackhawk said:
No you can't. Read the LOI from the FAA Chief Counsel.
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Isn't that just black and white in the regs though?

61.195 Flight Instructor Limitation and Qualifications
(c) Instrument Rating: A flight instructor who provide instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and ATP must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.
 
ahw01 said:
Also can a CFI give instruction with no medical. Yes if the student is pic. Again why would they, it's legal but not prudent. CFI should always be current and considered PIC, and any exceptions should be red flagged and treated with caution.
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Why? I've known a number of CFIs who have taught with no medical. Uniformly, they were THE experts in their field.

I'm not sure why you see a red flag with, for example, a pilot visiting Colorado in his own airplane and taking mountain flight instruction from one of the CFIs who literally created the whole concept of "mountain flying" as a course (there are unfortunately not too many of them left) just because the CFI no longer qualifies for a medical or decided not to apply again. A medical is required in order to act as PIC or as a required crewmember. I think the whole idea of separating piloting from instructing was in order to allow pilots to get the benefit of instruction from our most experienced instructors.

ahw01 said:
Just get all the ratings. I love how people like to hold up technicalities. You're really gonna be earning a lot just on sim work. Like can a non multi CFI give instrument training in a twin. Technically yes but why would they?!
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As others pointed out, technically no. Yes, at one time he could but that was specifically changed by an FAR amendment 6 years ago, after contrary interpretations from different parts of the FAA led to a lot of confusion on the subject.
 
There was a fellow at my previous school who is in his early 80's. He is a retired Air Force pilot, with lots of combat time in Vietnam. He has tons of time in aircraft such as bombers, fighters, tankers and many different kinds of training aircraft. The man has been shot at, seen his friends shot down, lived through two engine failures in single engine aircraft, has flown in nearly every corner of the world, and has successfully dealt with many emergencies in the course of his long career. He has also been instructing for more than thirty years!

He can get a medical, but my understanding is that it is only vaild for one year and requires a significant amount of money to obtain the waivers and a lot of paperwork so he no longer bothers with it. His solution? He doesn't have one and only provides instruction to students already rated in the aircraft. So essentially, a lot of spin instruction, I think CFI applicants are in there as well, and instruction for commercial pilot applicants. In the event that his health does fail in flight, his student should be more than capable of landing the airplane by themselves at that point, so no worries. He just wants to keep flying, and the experience that he can share with others is absolutely priceless in my opinion.

THAT is the kind of person that I wish we had more of in the CFI ranks, medical or not! We have all been taught how to deal with a dead stick landing, but this guy has done TWO for real, and is still here to teach someone else to do it! He has experience, which is something you can't get from a book! I would take him as in instructor over a 300 hour green CFI with a medical every day of the week!!!
 
Thanks for the replies guys, definitely very helpful. I will print out that interpretation and have it with me for the practical test. I still plan on getting my CFI-A and I don't plan on giving any instruction with just the CFII, but like I said I just wanted to know for the practical in case the topic came up.
 
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