CFI Renewal through Duties and Responsibilities

We keep dancing around and I guess I'm still not getting it...

DV8Pilot, in an above posts, said this:
"SAN FSDO will renew 121 or 135 PIC..."

Do you think he's wrong?

You also said this:

"I wouldn't be surprised if some inspectors take the view that a Part 121 or 135 multi-crew captain needs to evaluate his pilots every day and might do a signoff on that basis"

So, are you saying if I walked into the SAN FSDO as a 121 Capt, and I got an inspector to sign off my CFI, I should not consider that legal or valid?
 
DE727UPS said:
So, are you saying if I walked into the SAN FSDO as a 121 Capt, and I got an inspector to sign off my CFI, I should not consider that legal or valid?
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FAR 61.197(a)(2)(ii) allows for renewal of a CFI certifciate in a number of ways:

  1. passing a practical test for a CFI rating
  2. doing an FIRC
  3. presenting an authorized Flight Standards Inspector a record showing you qualify for the 80% passing rate renwal
  4. "presenting an authorized Flight Standards Inspector a record showing that, within the preceding 24 calendar months, the flight instructor has served as a company check pilot, chief flight instructor, company check airman, or flight instructor in a part 121 or part 135 operation, or in a position involving the regular evaluation of pilots"
The last part of that fourth one is the only basis I'm aware of that would allow an FAA Inspector with the authority to give CFI renewals to renew a 135 or 121 captain's CFI based on, as KLB put it, "duties and responsibilities."

I have not seen anything official one way or another, but I can see where FSDOs and individual inspectors would take the position that a 121 or 135 captain in a multi-pilot crew is "in a position involving the regular evaluation of pilots" and would sign the renewal. In the absence of official guidance to the contrary, I don't see anything wrong with it.

But if you're looking for it, I don't see "I don't know this guy from a hole in the ground and he's shown me nothing, but heck he's a #%^&%#$ 121 captain and has a pretty uniform to prove it so let it go," sorry, I don't see it in the 61.197 list. Do you?

To be valid, the inspector would have to hang it on something, most likely the FAR provision already quoted more than once.
 
KLB said:
Well it looks that I just going to have to break down, pay the 150 bucks, and do the American Flyers online course. Anybody know how to do it in less than 16hrs?:)
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Dude to bad you and Mary couldve finished it together all last week in San Diego!
 
Perhaps this will help clear things up. It's from FAA Order 8700.1, the GA Inspectors Handbook Vol 2, Chapter 11, Section 1(C) (The reference to the "old" rule is the way the FAR provisiun read before the 1997 revision - as I thought, apparently there was some special rule for 121 captains back then):

==============================
Section 61.197(a)(2)(ii). Individuals have asked FAA about the intent of the statement, “. . . in a position involving the regular evaluation of pilots” in § 61.197(a)(2)(ii) and whether it has the same meaning as the old provision in § 61.197(b). The FAA rewrote § 61.197 to expand the renewal provisions, mainly to include other PICs. For example, the following PICs, who regularly evaluate pilots, have the same reward provisions as a PIC in a part 121 operation:
• A PIC of a multiple pilot flightcrew aircraft under part 135
• Corporate PICs of a multiple pilot flightcrew aircraft under part 125 or 133
• U.S. military pilots who are PICs of a multiple pilot flightcrew aircraft
• U.S. military instructor pilots and examiners who regularly evaluate pilots under part 125 or 133
• Flight instructors who actively instruct in part 61 schools

NOTE: FAA ASIs should review evidence of the applicant’s employment, which should clearly show that the applicant is in a position involving the regular evaluation of pilots. ASIs also should have personal knowledge of the applicant’s flight instructing capabilities and qualities before renewing that applicant’s flight instructor certificate.
==============================

So the requirements are:
  1. in a position that involves evaluation of pilots, such as captain of a multi-pilot crew
  2. some record that shows what the pilot's position is and her evaluation duties
  3. personal knowledge of the pilot's instructional capabilities

Does that help?
 
Well I've rapped up the online FIRC. I went with Don's advice and did the Gleim course.

Overall it was pretty simple. I didn't like that they just wouldn't let breeze right through the pre-quiz part. If you spend less than 30 seconds answering one of the true or false question (after about the 3rd or 4th consecutive one) red writing would appear warning that you are doing it to fast. If I know the answer, why would I have to waste time waiting 30 sec?:sitaware:

The TSA portion of it was a complete joke IMHO!

Now I have to set an appointment with a FSDO somewhere between Texas and California by Thursday.:)
 
I know one FSDO that won't do it: MEM. Even though PCL CAs are all pretty much check airmen at this point with the low time guys in the right seat. Every CA I've flown with has had to fill out some sort of eval on an FO sometime in the past 3-4 months. All the probationary FOs get evals filled out multiple times. I didn't even know I was being evaluated until my probation was almost up and a CA showed me the form he was filling out. What's the good of evaluating if you don't give the poor guy feedback on how he's doing until it's too late?

Anyway, I digress. MEM FSDO won't do it based on being a 121 CA. Now, if you know the right guy AND you're a check airman, then you're golden so I've heard.....
 
"The TSA portion of it was a complete joke IMHO!"

It was a total joke. But it made me legal. If it wasn't for the TSA part of the Gleim FIRC, I'd still be blowing that TSA CFI security stuff off.
 
Well I have gotten my CFI renewal all done and taken care of at the Fort Worth FSDO. They don't reward a renewal on the basis of "duties and responsibilities" btw.

After looking at the inspector all squinty eyed and asking him about finding a FSDO that did reward the renewal on the basis of "duties and responsibilities, he replied that renewal would be legit. As far as he knew, it had been done away with across the board though.

Of course, I could have walked into the next office and have gotten a totally different answer.:)
 
KLB said:
Of course, I could have walked into the next office and have gotten a totally different answer.:)
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Ahh, the beauty of FAA bureaucracy. Everybody has an interpretation of the regs and they're all right. Or wrong depending on what day it is and the color of the shirt you're wearing, or is it the time of day and the color of your shoes. I can never quite figure out the formula.

When did my renewal a few weeks ago there was a rather loud conference call going on in the next cubicle involving the legality of a one-armed flight attendant for a to remain nameless large charter operator in the northeast. It was all I could do to stop from laughing several times as I was waiting for them to come back with my paperwork.
 
Same thing with mine. The phone conversation went a little something like this:

Faa guy: Yeah you're a student pilot who made a mistake. Hey they happen. You should make sure you check for TFR's from now on when you go on those solo flights......Oh your instructor was with you? Your instructor was in the plane with you? I didn't no that. Yeah..... Whats his name?:)
 
Just to set things straight...

I just renewed my CFI through 61.197(a)(2)(ii) this morning, in our nations capitol, at the Washington DC (Dulles) FSDO. I had the 8710 filled out prior and literally spent no more than 10 minutes in the FSDO. Luckily... the FSDO building is actually connected to our hotel on that overnight.

Bob
(A happy CFI!)
 
Well, I think now that we have our answer, I'm gonna go ahead and close this up just to avoid re-starting an old argument.
 
The Fed who did my captain's ride signed my 8710 for my CFI renewal after we were done.

She also did OldTownPilot Dad's Fed ride back in the day I believe. Very nice lady!
 
So....

You guys are saying just cause I'm a 121 Capt I can get my CFI renewed?

It might be worth a trip to the CoEx hotel at Dulles.

MQAAord, thanks for opening the thread back up. That was a good call. I was going to complain, too, but you're too nice.
 
DE727UPS said:
So....

You guys are saying just cause I'm a 121 Capt I can get my CFI renewed?
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That's pretty much what I'm saying... You may have to show how you are in "a position involving the regular evaluation of pilots". I brought in a couple copies of First Officer Proficiency Reports that I had done just in case... but... he never asked for anything like that.

All I did was show up in uniform this morning with all my ID, Certs, and a pre-printed 8710... I asked to speak to an Inspector about the renewal of my CFI. When he came out to meet me and asked what he could do for me... I simply said this verbatim:

"Hi there, I'd like to renew my CFI based based on 61.197(a)(2)(ii), being a PIC in a 121 carrier who is in a position involving the regular evaluation of pilots..."

He just said... "Oh yeah... we can do that... do you have an 8710 and your CFI cert. with you?"

10 minutes later... I'm having a breakfast sandwich in the lobby downstairs waiting for my shuttle to IAD.

Seggy said:
Probably depends on the FSDO and the inspector you get.
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:yeahthat:

I've had friends get denied or have Inspectors look at them cross-eyed when they bring up 61.197(a)(2)(ii). But... if I can get it done at the nation's FAA HQ... then I'd think you can get it done elsewhere.

May also want to look for an Inspector at an Air Carrier Office vs. just a standard GA FSDO. I would think that they would be much more familiar with the reg.

Bob

PS: Thanks Amber... I didn't even consider the "necroposting" angle". I just looked at it as an unresolved thread and I was playing "mythbuster". ;)
 
MidlifeFlyer said:
The fact that you can find some FSDO inspector who will sign you off because he knows your first cousin once removed wouldn't make it okay.
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Thats about how Dads CFI renewal went. He basically said "Hi, I need my CFI renewed" and they had the paper printed out 5 minutes ago. Then again he flew with half the FSDO back in the 80s and they know he owns a flight school.
 
Okay, well, when I un-necro this thread in about a year and a half I hope nobody cares. I'll need names and places, but I don't mind PM's.

It's an interesting concept. Could a trip to DC be less of a hassle than two days drinking beer and doing the Gleim course?
 
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