61.195(c) Interpretation Help

MajorTom

MajorTom

Well-Known Member
"61.195 A person who holds a flight instructor certificate is subject to the following limitations:​

(c)Instrument Rating. ​

A flight instructor who provides 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 airline transport pilot certificates 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."​

If I were a CFI Airplane Single Engine, Could I give the required instrument instruction for a Commercial single engine applicant? I am sure I can give the 3 hours for the Private, but what about the Commercial?​
 
MajorTom said:
"61.195 A person who holds a flight instructor certificate is subject to the following limitations:​

(c)Instrument Rating. ​

A flight instructor who provides 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 airline transport pilot certificates 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."​

If I were a CFI Airplane Single Engine, Could I give the required instrument instruction for a Commercial single engine applicant? I am sure I can give the 3 hours for the Private, but what about the Commercial?​
Click to expand...

According to the bold, it would appear not; but I don't know if there are any loopholes or other mitigating arrangements or interpertations from the Feds.
 
MajorTom said:
"61.195 A person who holds a flight instructor certificate is subject to the following limitations:​

(c)Instrument Rating. ​

A flight instructor who provides 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 airline transport pilot certificates 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."​

If I were a CFI Airplane Single Engine, Could I give the required instrument instruction for a Commercial single engine applicant? I am sure I can give the 3 hours for the Private, but what about the Commercial?​
Click to expand...
No. That's what it says.

If an FAR refers to "instrument instruction" or "instrument training" it requires a CFI-I.

Read the reg that discusses the 3 hours for the private. You'll see that neither phrase is used.
 
Exactly as Midlife said. Instead it's worded as "flight training on the control and maneuvering of an airplane soley by ref. to instruments." The definition of inst. training can be found in 61.1.
 
MikeD said:
According to the bold, it would appear not; but I don't know if there are any loopholes or other mitigating arrangements or interpertations from the Feds.
Click to expand...
Actually, the Chief Counsel interpretations are stricter, suggesting that a one-I can't give any "instrument training" whether or not it "counts" toward a certificate or rating. As I recall, if you search for letters to our old friend Taylor Grayson in the Chief Counsel database, you'll find at least one of those.
 
Thanks for the interpretation, ended up taking the Intial CFI-A today, passed, and did not get asked this question.
 
Don't really have to. It's just the hood work that requires the II. And if the student already has an instrument rating probably not even that.
 
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