CFI(non CFII) giving instrument instruction

[Louie1975]

OK folks - Question!
I am a CFI at the Sierra Academy of Aeronautics. Currently I am only a CFI, but currently studying for the CFII. Now the three students assigned to me are just finishing up there Private. My plan was to start their instrument training after their private, and(aside from prepping them for the instrument rating) use the experience of teaching them instruments as a preparation for me to take my CFII checkride. Sounds good. My converstions with people and my casual reading of the FARs indicate that they only need 15 hours with a CFII. I would take the CFII ride right before the last 15 hours of their training. Sounds like a great plan to me. This is all being done under part 61, a lot of training is done on a Flight Training Device(PFC-MFD).
So I am reading the front of the Gleims book and it is describing the flight experience for the IFR rating and it says 'If the instrument training was provided by an authorized instructor, a maximum of 20 hours permitted in an approved flight simulator or flight training device.' So I am a little confused. Can a CFI only(non CFII) do the FTD portion of training, or not? I am again looking at the FARs and I would have to say yes, a CFI(non CFII) can do the FTD portion.
Once again, I intend to teach them most or all of the sims, and part of the airplane until the last 15 hours, at which point I would take my CFII checkride and then it would be OK to finish them up and sign them off. Please help.

 

[dc3flyer]

You can give them all instruction as a CFI with the exception of 15 hours and a signoff for the checkride, needed by a CFII. (It doesn't even have to be the "last" 15).

 

[Silverhawkpmm]

Hey Louie -

I don't have the FAR/AIM with me, ( I know.. such shame :laff: ) - but my instructor at the time was working on his CFI-I. We checked with the local FSDO said is was ok to complete BAI and I believe up until the last 15hrs (??) I'd have to dig out our notes etc...

This was going thru a 141 program.

Take care,

 

[nosehair]

The simulator training must be done with an 'authorized instructor'.

What are you teaching? Instruments? Oh, then an 'authorized instructor' is an 'instrument instructor'.

You have to have a double-eye to use the sim time towards a rating or to count towards currency, as in the 6 approaches.

But,...you can also do it with an Instrument Ground Instructor Certificate, which you can get by doing the FOI and IGI, which is the from the same bank of questions as the Instrument and double-eye.

Your plan is good. Just get the IGI right away before doing the sim time.

 

[MidlifeFlyer]

So I am reading the front of the Gleims book and it is describing the flight experience for the IFR rating and it says 'If the instrument training was provided by an authorized instructor, a maximum of 20 hours permitted in an approved flight simulator or flight training device.' So I am a little confused. Can a CFI only(non CFII) do the FTD portion of training, or not? I am again looking at the FARs and I would have to say yes, a CFI(non CFII) can do the FTD portion.

No. =Any= instruction that is going to be pointed to as counting toward the instrument instruction requirements for the instrument rating must be done with an instructor who as an instrument rating on her instructor certificate.

As far as I've been able tell looking a the FAR and various legal and quasi-official interpretations, it's as simple as this:

If it needs to be counted toward an "instrument training" or "instrument instruction" requirement for a certificate or rating, it needs to be done by an instructor who as an instrument rating on her instructor certificate.

If it doesn't need to be counted, a one-I is just fine.

 

[ClearedToThe]

No. =Any= instruction that is going to be pointed to as counting toward the instrument instruction requirements for the instrument rating must be done with an instructor who as an instrument rating on her instructor certificate.

As far as I've been able tell looking a the FAR and various legal and quasi-official interpretations, it's as simple as this:

If it needs to be counted toward an "instrument training" or "instrument instruction" requirement for a certificate or rating, it needs to be done by an instructor who as an instrument rating on her instructor certificate.

If it doesn't need to be counted, a one-I is just fine.

I disagree. You ONLY need a CFI-I rating to provide "15hrs from an authorized instructor, etc." and sign the student off for the IR checkride. A CFI (non -I) can also take up a student in actual conditions to provide instrument time (non included as part of the 15hrs stated above) towards the required 40hrs of sim/actual instrument time [this can also be done with a private student needing the 3hrs of instrument time]. Obviously, you should take that with a grain a salt and ask yourself how proficient you (the CFI) are on instrument flying from the right seat...but there is absolutely nothing illegal about doing it.

This was straight from the mouth of my FAA inspector during my CFI oral. exam.

Keep those needles centered :laff:

 

[MidlifeFlyer]

I disagree. You ONLY need a CFI-I rating to provide "15hrs from an authorized instructor, etc." and sign the student off for the IR checkride. A CFI (non -I) can also take up a student in actual conditions to provide instrument time (non included as part of the 15hrs stated above) towards the required 40hrs of sim/actual instrument time [this can also be done with a private student needing the 3hrs of instrument time].

I'm not sure what you are disagreeing with. We said the exact same thing. Those 15 hours are the only hours that need to be counted toward the requirements.

 

[tgrayson]

You ONLY need a CFI-I rating to provide "15hrs from an authorized instructor, etc."

The FAA, in writing, has never said that an CFI can provide "instrument training" or "instrument instruction", and various published interpretations have said that "instrument instruction" must be performed by a -II, even though the actual regulation is more permissive. The training required by the PPL is "flight by reference to instruments", not "instrument training".

While a non-II can fly with an instrument student for the remaining 25 hours of hood time required for the instrument rating, it would not be prudent for the instructor to log it as instrument instruction for either himself or the student.

 

[Louie1975]

I think I have had some insights overnight.
First off, thanks everyone for all the great and informative replies.
I think the FARs are trying to state that if you were to substitute some of that 40 hours of simulated hood time with FTD time, that FTD time would need to be with an 'authorized instructor(CFII).' HOWEVER....
Our program has way more than 40 hours for the IFR syllabus. In addition, since it is part 61, they must do 50 hours X-country PIC. Some of that 50 will be under the hood with me as CFI(or safety pilot, if you need to call it that). Therefore, at the end of the day, they will present themselves to an examiner with 40 hours of simulated instrument time, with 15 hours of instrument instruction from an authorized instrument instructor(from me - the newly minted CFII). Now I was very concerned because stage one of our instrument syllabus is mostly in the FTD, teaching BAI. My initial reading of the regs had me fearful that I would need to be CFII rated to do stage one with them. In my situation, at the end of the day, the FTD time will not even need to be counted toward the experience requirements to present the students for an instrument rating exam. They will have 25 hours of hood time, along with the 15 hours with a CFII.

 

[Louie1975]

TGrayson:
As far as logging the time, I don't see a place either in my logbook, or the student's logbook, for logging anything as 'instrument instruction.' I just have 'dual given' and 'dual received.' If I go fly with them as a CFI only, I will log it as Dual Given.
I believe the key here for us if we really need a clear cut technical answer, is that the FARs only require 15 hours of instrument instruction. Period. (From a CFII of course). The other 25 hours doesn't have to be called instrument instruction, but it can be Dual Given. Just as we, as CFIs, log the 3 hours of simulated instrument time during private training and call it dual given.
Hopefully more people can shed light on this.

 

[MidlifeFlyer]

TGrayson:
As far as logging the time, I don't see a place either in my logbook, or the student's logbook, for logging anything as 'instrument instruction.' I just have 'dual given' and 'dual received.' If I go fly with them as a CFI only, I will log it as Dual Given.
I believe the key here for us if we really need a clear cut technical answer, is that the FARs only require 15 hours of instrument instruction. Period. (From a CFII of course). The other 25 hours doesn't have to be called instrument instruction, but it can be Dual Given. Just as we, as CFIs, log the 3 hours of simulated instrument time during private training and call it dual given.
Hopefully more people can shed light on this.

I think you have it right Louie. But be aware that tgrayson, whose opinion I respect very much, and I disagree on this.


The only thing I would do is add something that differentiates the two in the logbook so that no one looking at it would "think" that you were trying to get away with something.

 

[Louie1975]

Good point, Midlife. Do you have any suggestions on what to add? I would just log 'Dual Given' and in the comments either the Sierra Academy lesson number or just what we did(ex. - ILS).

 

[tgrayson]

The other 25 hours doesn't have to be called instrument instruction, but it can be Dual Given. Just as we, as CFIs, log the 3 hours of simulated instrument time during private training and call it dual given.

I agree with that. I'd be careful to log it as "Flight by reference to instruments" or some such. Midlifeflyer has agreed with this caution as well in the past. Where I recall our disagreeing is that I believe the regulations do not explicity say that instrument instruction must be given by a -II.

 

[ClearedToThe]

Sorry Midlife - guess I misread your post the first go around. :banghead: Seems like we are all on the same page, so to speak. I am still of the belief that Louie can log it as "dual given" (even in actual IMC - assuming he is proficient in instruments from the right seat) as long as those hours logged aren't used as the 15hrs from an "authorized instructor". My inspector put it along the lines of "you can do anything as long as the regs don't prohibit it". In other words, just because the regs don't say you CAN do something, it doesn't mean you can't. [staying within personal limits obviously...i.e. taking a private student up in actual to satisfy the 3 hrs of flight w/ ref to instruments]. If ever in doubt, you can always call up the local friendy FSDO and get an inspectors interpretation of a reg.

 

[Louie1975]

Also, if I were not to log the 25 hours of hood time as 'Dual given', then my only other option would be to put down 'safety pilot.' Which would be weird, since if I am teaching him ILSs and holds, I am providing instruction, in addition to watching for traffic(safety pilot duties). But the instruction would be primary.

 

[MidlifeFlyer]

Good point, Midlife. Do you have any suggestions on what to add? I would just log 'Dual Given' and in the comments either the Sierra Academy lesson number or just what we did(ex. - ILS).

Hard to say. From discussions, I know that there are flight schools where one-Is do non-counted instruction o a regular basis, but I never heard how they differentiated.

Your idea of using the common 141 method of referring to the lesson number is one way. Another might be as simple as an asterisk or some other symbol that in a legend says this one counts. The idea with our logbooks is that it should always be clear what is going on without our having to be around to explain it.

 

[bLizZuE]

I interpret it as such:

As a CFI you can do everything for a instrument student except endorse em for the ride, and the 15 hours.

As a CFI theres nothing stopping you from given that student instruction towards a IR as long as you both know what the student needs to complete their training. A CFII to give them at least 15 hours of dual, and an endorsement.

Pretty simple I think.