CFI teaching Instrument

escapepilot

escapepilot

Well-Known Member
I know this in a thread somewhere, but couldn't find it. Someone please verify that I've read this correctly.

"61.65(d)(i) At least 15 hrs of instrument flight training from an authorized instructor in the aircraft category for which the instrument rating is sought;". Means that as a CFI w/o II, I can teach instrument students everything for the instrument rating except for the final 15 hrs and the instrument ground (no IGI either).

Hopefully this summer I'll have the II and this will be moot.
 
Thanks, guys. I've never had a demand for instrument instruction so never got it, but now I've got a few private students that want to start the instrument when they finish the private.
 
escapepilot said:
Means that as a CFI w/o II, I can teach instrument students everything for the instrument rating except for the final 15 hrs and the instrument ground (no IGI either).
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Just because the student only needs a -II for 15 hours, it doesn't follow that you can provide any of the remaining instruction. The FAA position has been that anything labeled "instrument instruction" must be provided by a -II. That's why they went to the bother of labeling the training that a CFI provides a Private Pilot "flight by reference to instruments." It isn't instrument training, by decree.

No LOI has addressed this question specifically, but here is an excerpt from a similar question:
Since Section 61.65(e)(2) refers to "instrument instruction" by an authorized instructor, the instructor must have an instrument instruction rating. Section 61.107 refers to "instruction from an authorized instructor" and to "control and maneuvering an airplane solely by reference to instruments," rather than to "instrument instruction;" therefore, any certificated flight instructor (CFI) may give the type of instruction described in FAR 61.107. The instrument instruction required by FAR 61.129(b)(2)(i) must be given by a certificated flight instructor with instrument instruction rating. Other non-instrument instruction required by FAR 61.127 may be given by any CFI.
​
In another letter, it says
A flight instructor is authorized to provide this certificate, or "sign off", for instrument instruction if the instructor has an instrument rating on his or her flight instructor certificate.

​
It seems clear to me that a non-II cannot provide instrument instruction, although he can provide flight by reference to instruments to a PPL candidate.

The only way I can see you flying guilt-free with this student is by being a safety pilot. Although you might be able to provide some limited "flight by reference to instruments" refresher training, if you provided any more than that, the setup might start to smell to an FAA guy looking in to your relationship with the student.
 
escapepilot said:
Means that as a CFI w/o II, I can teach instrument students everything for the instrument rating except for the final 15 hrs
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Well, not exactly "the final 15 hours", as you put it.
Just be aware that 61.65(d)(2)(iii) means the instrument x/c has to be with a double-eye.
 
This came from a response to Tgrayson (props to you for asking!) in regards to a different but similar issue. A part of the reply provides more insight into thier thinking.

From the Office of Chief Counsel Jan 4 2010.

Revised § 61.195( c), which became effective on October 21, 2009, addresses flight instructor limitations and qualifIcations with regard to instrument ratings. It states that "[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 air 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.


We distinguished this requirement from the qualifications required for those instructors who provide flight training on the "basic instrument maneuvers" in § 61.107 and the "control and maneuvering of an airplane solely by reference to the instruments" in §61.109 necessary for private pilot certification. Flight instructors providing this type of flight training are not required to have an instrument rating on their flight instructor certificates.

I wouldn't sign off anything more than BAI. Once you start doing holds, arcs, IAPS its obvious it exceeds "basic instrument control and maneuvers" and if it came to questions surely the FAA would recognize an intent to teach the instrument rating without holding one on your instructor cert.

Beyond that..there are other reasons to get you II beyond just another professional achievement. One, you'll be in a position to attract even more instrument students. You'll need it for the multi/comm. And why let another instructor take your student to finish up the required minimum 15 hours? Thats a good way to never see your student again.
 
Codyjp said:
Your correct.

With a CFII your able to do just a few things:

The 15 hours for the instrument and IPC's
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It's a bit more than that. I don't agree with tgrayson's view, but, IMO the requirement for a CFII extends to every task that is listed as a required areas of operations in 61.65.

IOW, if you show up with 15 hours with a CFII but those 15 don't include everything in 61.65(c), the examiner would be well within his rights to send you home.

It's not that the one-I can't teach instruments; it's just that none of those sessions count in the least toward meeting any instrument rating requirement.

Legalities aside, the other issue is what value you are giving your student. Yes, there are instructor who can effectively teach out of their certification. There are non-instructors who can teach better than some instructors. But the situations I've heard of where both one-Is and double-Is have been used effectively involve the CFII doing th primary instruction with the one-I taking the role of assisting in practicing what's already been learned.
 
MidlifeFlyer said:
It's a bit more than that. I don't agree with tgrayson's view, but, IMO the requirement for a CFII extends to every task that is listed as a required areas of operations in 61.65.

IOW, if you show up with 15 hours with a CFII but those 15 don't include everything in 61.65(c), the examiner would be well within his rights to send you home.

It's not that the one-I can't teach instruments; it's just that none of those sessions count in the least toward meeting any instrument rating requirement.

Legalities aside, the other issue is what value you are giving your student. Yes, there are instructor who can effectively teach out of their certification. There are non-instructors who can teach better than some instructors. But the situations I've heard of where both one-Is and double-Is have been used effectively involve the CFII doing th primary instruction with the one-I taking the role of assisting in practicing what's already been learned.
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Agreed completely. I just didn't type enough...

I'm quite intrigued by Tgraysons thoughts and it certainly makes sense. I don't know if it would be something the FAA would bother to pursue though.

When I didn't have my CFII I stayed away from any type of IFR training besides the private training requirements because it certainly smelled like a rat.
 
Codyjp said:
Agreed completely. I just didn't type enough...

I'm quite intrigued by Tgraysons thoughts and it certainly makes sense. I don't know if it would be something the FAA would bother to pursue though.

When I didn't have my CFII I stayed away from any type of IFR training besides the private training requirements because it certainly smelled like a rat.
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I didn't. Or maybe I just read it differently.

Example:

Depending on the pilot, sometimes when I did FRs with VFR-only pilots, I would teach the basics and sometimes do an instrument approach. I thought that understanding the basics of an instrument approach would be a great thing to have in a pilot's bag of tricks. Nighttime VFR approaches to unfamiliar airports (which I've done), understanding the instruction to "intercept the localizer" which even VFR pilots would get at busier airports.

The problem is that, while limiting in some respects 61.109(a)(3) is actually pretty broad:
==============================
training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight;
==============================

Can you point out the tasks in 61.65(d) that do not fit into this? Even IAPs are nothing more than "the use of navigation systems/facilities and radar services appropriate to instrument flight."

The difference isn't what you can teach but what it can be counted toward.

IMO "instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR" means exactly that - instrument training that is used for the issuance of those ratings - to show that one has met the requirements for the rating.
 
MidlifeFlyer said:
Can you point out the tasks in 61.65(d) that do not fit into this? Even IAPs are nothing more than "the use of navigation systems/facilities and radar services appropriate to instrument flight."
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While this is true, at some point it becomes a mockery when you can look at the record of training and see a steady progression though the 61.65 requirements, only to be finished up by a -II. It looks to be a deliberate end-run around the intent of the regulations.

While only a minimum of 15 hours is required to be with a -II, it's still an assumption to say that this is what is meant in 61.195(c) when it says "A flight instructor who provides instrument training for the issuance of an instrument rating,...". Arguably, if a student needs 100 hours of instrument training, this is the instrument training for the issuance of an instrument rating.

In the end, in the FAA's eyes, a CFI is not competent to provide the training required for the instrument rating and there are many instances in which this is clearly being done, as in the case of the OP.
 
This is the discussion I expected. First, a little more background. I do plan on the II this summer. I the meantime, I was hoping to begin the BAI portion of 61.65(c)(4) Flight by reference to instruments w/ a few students that have requested it (i.e. Pattern A, Pattern B). Since these can be done VFR w/o a flight plan, it seem like its w/in the regs for a CFI to do that portion and that's where the 15 hrs w/ CFII comes in.

The main reason I don't have the II already is a previous FBO employer w/ whom I had a agreement w/ failed to follow through on their end of the deal (CFII and MEI).
 
tgrayson said:
While this is true, at some point it becomes a mockery when you can look at the record of training and see a steady progression though the 61.65 requirements, only to be finished up by a -II. It looks to be a deliberate end-run around the intent of the regulations..
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If you look at the training records and find that the CFII hasn't covered the required tasks, it's not just a mockery; it's a failure of the applicant to meet the requirements.

OTOH, if the CFII covered all of the tasks, I don't see it mattering much from the mockery standpoint whether the rest of the general instrument hours are with a CFI giving instruction or a safety pilot who is completely clueless.

So I guess we'll agree to disagree.
 
MidlifeFlyer said:
If you look at the training records and find that the CFII hasn't covered the required tasks, it's not just a mockery; it's a failure of the applicant to meet the requirements.
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Covering isn't the same as providing the required instruction.

Do you really think that if you posed this question to the General Counsel's office, they would endorse the idea of permitting the bulk of instrument training to be done by non-II instructors? I don't.
 
According to the FSDO at Scottsdale, as well as the info that went out in the fall, No instrument instruction beyond the Private instrument training, can be done by a CFI unless they hold the Double I as well. Can you put someone under the hood for a few tenths on a flight review, sure. Just can't do anything for the Instrument rating 61 or 141, or the Commercial under 141, and the limited commercial under 61.
 
tgrayson said:
Covering isn't the same as providing the required instruction.

Do you really think that if you posed this question to the General Counsel's office, they would endorse the idea of permitting the bulk of instrument training to be done by non-II instructors? I don't.
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If you load the question with the underlying assumption that it's improper and abusive and provide your own unopposed argument about why that's the case, you'll probably get an answer that prohibits CFI-As from flying with a pilot under the hood at all after he gets the private certificate (after all, there's nothing that the CFI can cover that is not a 61.65 task). There are plenty of areas in the law where the argument is all about what the question is; win that battle and you win the war.

OTOH, I would hope that "assuming that all required tasks in 61.65 are covered by an authorized CFI-I, is a CFI-A prohibited from providing additional instruction in those tasks," would get a no and "does instruction on the use of navigation systems/facilities and radar services appropriate to instrument flight' include instrument approach architecture and procedures?" would get a yes.

But if you're dead set against CFIs providing any post-private instruction on instruments, ask away.

(I just noticed juskl's post - apparently Scottsdale agrees with you - a CFI-A can't ever put a pilot under the hood after he gets his private.)
 
juskl said:
According to the FSDO at Scottsdale, as well as the info that went out in the fall, No instrument instruction beyond the Private instrument training, can be done by a CFI unless they hold the Double I as well. Can you put someone under the hood for a few tenths on a flight review, sure. Just can't do anything for the Instrument rating 61 or 141, or the Commercial under 141, and the limited commercial under 61.
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Explain exactly how you can put a pilot under the hood and not do anything that is a 61.65 or 61.129 instrument task.
 
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